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Originally Posted by mardigras
I don't see where that is specifically clarified. It talks about sites using hyperlinks not requiring records. Technically a cropped thumbnail could still be construed as showing depictions of ?actual sexually explicit conduct?. 
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# The term ?actual sexually explicit conduct? does not include ?lascivious exhibitions of the genitals;? (i.e., mere nudity).
# Websites containing no depictions of ?actual sexually explicit conduct?
there ya go. if your thumbs aint explicit...no records needed. if your thumbs are explicit...you need records. what's so hard about that?