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V, the problem right now is that the definition of a "work" is very loose indeed. If a model poses for 20 pictures in a row, are they part of the same work or are they each unique instances?
If those still images are stills from a video, is that somehow different than 20 images taken with a still camera? Afterall, the video would be the underlying work, and therefore the images woudl be subject to 2257 if the model gets naked at any point.
It isn't clear. The only way for a US based webmaster or company to be safe is to require documents for all images that appear on an adult site, IMHO.
Good luck.
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