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Yeah, topless pics of a minor would probably not be considered sexually explicit, but you'd still be walking a fine line IMHO. Don't forget you cannot legally use them for commercial gain, as well. Not that it stops many sites.
Just on a side note, I want to say that those candid shot sites really creep me out, to know that some guy with a telephoto lens is snapping away at the girls on the beach. shudder
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