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It seems to me that the new regs force pic posts and TGPs that accept submissions from other webmasters (the usual model) to close. It doesn't matter that the images are served on the submitting webmaster's bandwidth. If the images are displayed on the pic post or TGP, the owner of that traffic resource is responsible for documenting them. There's no way to reasonably do that, of course, so I expect the U.S. based TGPs and pic posts will be shutting down.
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