It does define secondary producer in the original regs in 75.1 c...

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(c) Producer means any person, including any individual, corporation, or other organization, who is a primary producer or a secondary producer.

(1) A primary producer is any person who actually films, videotapes, or photographs a visual depiction of actual sexually explicit conduct.

(2) A secondary producer is any person who produces, assembles, manufactures, publishes, duplicates, reproduces, or reissues a book, magazine, periodical, film, videotape, or other matter intended for commercial distribution that contains a visual depiction of actual sexually explicit conduct.
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So pretty much after Sundance everyone (including me) just assumed that the DOJ's ability to enforce that part of the regs was deminished...... But if it really was diminished and no secondary producer language was drastically changed in the new regs, then what makes people think they can now surely enforce it all of the sudden?

You'll see in the Sundance documents that the language that got them off is actually still there in the new regs. They didn't even bother to update that.