[saus]

I'd have to agree with Ronaldo & aaron on this
The 2257 clauses are designed to allow law enforcement easy & quick access to documentation.

If american or cooperating law enforcement officers enter your premises, after seeing your content online, or receving a tip etc and you do not have immediate, easy access to full 2257 compliance that allows them to draw a straight line regarding your content they can rap you with charges on the spot, seize relevant portions of your business etc.

a tgp is a free site, in theory you are not supposed to be allowed to show provocative imagery on such sites that are accessible by US minors, to add questionable content which may fall under child pornography, or even fully legal aged models that are not documented according to the law is likely more than enough.

The issue of production is mute, putting together an html page and linking a single image is easily defined as a production.
You need a solid documented trail for your content to be covered, perhaps not the files on the premises, but clear documentation of exactly where those compliance files are, and public disclosure of that fact.

Greg Picconelli who was at the roundtable is counseling my associates with such issues, and he prefers even tighter controls, I think that merely wishing tgp would be immune is not realistic.. I said 5 weeks ago to those i work with that I'll wait for some action on the ground before worrying.. foot in my mouth as BIG time action was taken this week, no less than a full fledged sting operation!

Taas, I would consult with an attorney either way as opposed to interpreting the clauses myself. By itself such compliance may seem more minimal, but when combined with possible obscenity.. ouch!