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Heather, depends on who you are shooting for. If it is for your own website, then you are a primary producer or at worst secondary producer either way you have to have records at your place of business. No third party record keepers will be allowed.
SirMoby: I might be wrong, but my take is this:
1 - They don't require 2257 per image, but one 2257 document per session. In other words, shoot 100 images, you still only need 1 document - but you need a cross referenced list to all of those images.
2 - If there is sexually explicit content, you need a 2257 document.
3 - because of 1, the document in 2 would cover all the images and imply sexual content.
My feeling is that once you require 2257 for a set, all the images in it may be part of a sexually explicit production, and therefore cannot be seperated out.
Remember also that the image is defined by it's initial production. A girl getting fucked in a picture is getting fucked - even if you crop down only to her face, the initial image is sexually explicit and therefore subject to 2257 - and your records would indicate this.
Me thinks tough times ahead for thumb tgps.
Alex
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