the only thing that would affect this, i would think, would be the legal definition regarding this issue of the word "produce". if digitizing older content is to produce, then the regs would apply. if digitizing older content does not mean produce, then the regs wouldn't.

Quote Originally Posted by gaybucks_chip View Post
I've always been inclined to feel that way as well. I *think* that there's some new language in 2257A, but I don't, offhand, remember the specifics... and, of course, nobody's really weighed in yet on the interpretation of the new regs.