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OK - nobody here seems to know, but I've tracked down the following from USCO -

  1. Publication occurs when copies of a photograph are offered to stock photography agencies for the purpose of licensing those copies to newspapers, magazines, and websites

 - which seems pretty clear to me. And as far as personal websites go, the following is also fairly clear:


If there is a notice on a website in the terms of service for the site or another obvious place indicating that a work or the content on the site cannot be downloaded, printed, or copied, the work or content may be deemed unpublished, because the end user is not authorized to download, print, or otherwise distribute copies


I hope this is helpful to others!




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