http://www.********.com/read.aspx?ID=10230
According to this article if it's true, this guy called the DOJ and did an in depth interview with them. Asked a lot of questions and got a lot of answers that I don't think many will like.
Also as far as the DOJ interview goes there is no difference in text links vs thumbs.. They seem to expect you to have the info on the performers even if you link via text.
So according to this interview with the DOJ the difference between text and thumbs is a mute point. Seems like it would be easier to run your own paysite than to run a link list, blog or tgp and follow the rules.