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It really isn't clear. With 2257 as it was, there was a specifric date (sometime in 1995, I think it is) where the law took effect. All images produced before that were exempt from 2257 (and you will see that on many websites notices).
The new "rules" are not really laws, they are "administrative clarifications", essentially Assclowns way of attempting to screw up all the porn sites. The wording to their changes is less than clear, and there is no real effective date. It is not clear from the text if the new rules for secondary producers (ie: website owners) applies to all 2257 material since 1995 or just new material going forward from the effective date of these new "clarifications".
I personally think these "clarifications" won't float in a court of law, but it won't stop assclown from being, well, an ass.
Good luck to all my american friends.
Alex
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