Sir Moby, I think ignorance is rarely an acceptable defence.
Quote:
Whoever produces any book, magazine, periodical, film, videotape, or other matter which—
(1) contains one or more visual depictions made after November 1, 1990 of actual sexually explicit conduct; and
(2) is produced in whole or in part with materials which have been mailed or shipped in interstate or foreign commerce, or is shipped or transported or is intended for shipment or transportation in interstate or foreign commerce;
shall create and maintain individually identifiable records pertaining to every performer portrayed in such a visual depiction.
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The key is "other matter". A series of photo images is "other matter" - and this is doubly clear if the photoshoot was also videotaped.
Let me go a little further. Let's say you have a thumbtgp with 200 thumbs, all of them very softcore head shots, and one banner add with a girl suck a dick.
You have published a document with "one or more visual depictions made after November 1, 1990 of actual sexually explicit conduct". You now need to have documentation for EVERY image on the page.
Worse, if any 1 of those 200 thumbs is in fact an explicit image (known or unknown) then you again fall in it for all of the images.
It's not funny.
Alex