2257 as it relates to lowly gallery submitters.

Hire a lawyer.

Any attorney's opinion will be just that -- an opinion -- unless and until there are legal actions that clarify things, but if you're in this business, you owe it to yourself to have an attorney experienced in the industry to discuss your specific situation and advise you on the risks you face.

That said, here's what we've learned: 4472 eliminated the "secondary producer" designation that was present in 2257, so if you publish content at all, you become the custodian of records for anything you publish, and you need to have 2257 docs.

That's one of the reasons a lot of programs now offer hosted galleries... if the gallery is hosted by the sponsor, then the sponsor, and not you, are responsible for the 2257 docs.

Also, most of the attorneys I've spoken with have advised not hotlinking or using i-frames; the idea is, the feds will look at the URL at the top of the page to determine who should have the 2257 records. If you own that URL, you better have the records.

Doesn't that only apply to hardcore content?

A fully clothed photo could be considered as to require 2257 by the strictest interpretation of the law.

It depends on what the DoJ definition of a "set" is. By the definition of most of the First Amendment attorneys who have spoken publicly, if there is actually sexually explicit conduct (touching genitals, touching another person if both are naked), then 2257 compliance is required. If a male is erect, it is probably subject to 2257. If a subset of pics used in a gallery come from a larger set containing sexually explicit content, even if the subset pics themselves are clothed, some attorneys say that they are still subject to 2257 based on the way the regs are written.

I know some performers who'll never need ID if that's the case.