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While some of you may be correct in your assumptions that just using a thumbnail of the model's face or only using "softcore" material may put you outside the scope of the 2257 regulations, the counsel I have been given is "why take the chance?"
It's a gray area that isn't worth risking your freedom over. If you don't have the ID's then don't post the content....if you have old pages with content that you don't have the ID's for then take it down, because the definition of "publish" when referring to a web page is also another gray area.
If you publish a page today that has porn movies from 1982 on it, is it exempt? Depends on whether or not the DOJ is looking at the day the movie was made or the day your page was published.
If you uploaded the page a year ago and haven't changed it....is that when the page was published? Or was it published today when I downloaded it from your server and a "copy" was made of the page?
The safest bet is to take down anything you don't have ID's for, period, the end.
It's not worth risking 5 years of your freedom and afterwards living the life of a convicted felon.....don't try to get "cute" with the law.
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