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I'd have an attorney look over what you have. You may have even bigger problems. There is a lot of confusion regarding the new regs and foreign shot content. Most people seem to be agreeing that the new regs don't allow for content shot in foreign countries to be used at all on US based sites. The rules appear to state that only if BOTH the producer and the Model have Foreign passports is it allowable. It doesn't even say Primary Producer. We have a lot of content shot in Prague and Argentina and so far every read on the law we have gotten says that we won't be able to use it anymore. I pray for an injunction.
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