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Originally Posted by Dirty Dane
To make one thing clear: 2257 is about record keeping requirements, and there ARE other things to consider before making money in this biz, than 2257.
Read:
Further:
So it does not really matter if you are using thumbs or textlinks. You are still liable for what you link (advertise).
My best advise is to check the laws and their sponsors before they start importing galleries into their TGPs. "I did not know" will not hold in court!

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Yes...that was the second part to my question. As I read it...even using text links makes one a publisher and certainly an advertiser if one is advertising for an Affiliate Program...and even though one uses only text links...if one advertises an Affiliate Program's FHG's/sites and they are not fully 2257 compliant does this make the advertiser legally liable under the new proposed 2257...as one has entered into a "contract/agreement".
If there is a legal door open to them...I am satisfied that they will use it...if they so choose.