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umm.. if it is on your page then you are a publisher.
Even though you've acquired the content as a "secondary producer" as defined under 2257, publication of such makes you "primary producer" as defined under HR4472.
Note further that "secondary producer" exemptions do not exist unless you are an FSC member within the juridstiction of the 10th circuit.
HR4472 & 2257 as amended require ALL webmasters who display or publish on their pages any content that is sexually explicit to maintain their own records & be in physical possession of such, however, one may elect a custodian for such purposes but this custodian may NOT be the sponsor companies as the sponsor will not, nor will they, have records relevant to the location of content within your domains & sites.
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