The question has to do with the definition of "producer". Some lawyers have suggested to their clients that operating a website with pictures on it makes you a "producer" of the content.
The important part at the end is:
"the term ''produces'' means to produce, manufacture, or publish any book, magazine, periodical, film, video tape or other similar matter and includes the duplication, reproduction, or reissuing of any such matter, but does not include mere distribution or any other activity which does not involve hiring, contracting for managing, or otherwise arranging for the participation of the performers depicted;"
The question is does operating a website contstitute producing or just distributing?
On the other side of the coin, many content producers are reluctant to provide full information on each performer beyond a certain point because they worry about violating those people's right to privacy. Imagine a girl does one set (and one set only), and then her personal info is sold to 100 people, 10 of which call her for more work. Was her personal info violated?
It is a can of worms... I haven't seen anything where people are getting hassled over this yet, but it has been mentioned as a possible was for Assclown and his posse to hassle people into retirement.
Paul is very correct, if you are buying content from Russia, as an example, I would demand full model releases, otherwise you can consider the content not valid.
Entire text of 2257 is here:
Cornell Law
Alex