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Originally Posted by Chop Smith
The way I read it - the thumb TGP would be publishing the thumb. If they publish the thumb then they are also considered a producer. Therefore they must have the proper documentation in their files.
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Google Images also publishes the thumb. Both could be considered "electronic communication service providers" (traffic sources). Google Images and a thumb TGP is basically the same thing, except Google Images has more ads than a thumb TGP.
But this part may be where a thumb TGP get included as publisher:
snipped from the section Sinistress posted: "...editorial or managerial decisions concerning the sexually explicit content of a computer site or service"
A thumb TGP makes editoral decisions regarding what they post, SE's don't.