[T]he term `produces' means to produce, manufacture, or publish
any book, magazine, periodical, film, video tape, computer generated
image, digital image, or picture, or other similar matter and
includes the duplication, reproduction, or reissuing of any such
matter, but does not include mere distribution or any other activity
which does not involve hiring, contracting for managing, or
otherwise arranging for the participation of the performers depicted

I'm reading it backwards ..

it seems to me that the above statement puts secondary producers, like our company. back to the start .. having only to list our vendors.