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Two points on pulling content.
Sec 75.4 says that you need to keep the records for 5 years, so even if you pull the stuff, I think you still have to have the records.
And notice they say "producer", without the "primary" or "secondary" adjectives.
Sec. 75.3 has a little section saying "(including but not limited to Internet computer site or services)" that has me thinking that you may have to document the stuff even if you haven't used it on the net.
What happens if you just blew out 100+ gallery pages with a submit tool, but, haven't made the 2000+ entries in the DB yet when they knock on the door?
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