I think this is the new law Bulger is referring to. I'm not sure if I'm reading it right but it seems like they wouldn't need permission if they already had the photo's. I'm not sure if they mean before 1905 or before October 1908. It appears they could have used an older photo of Plank or Wagner if they had one in their possession before a certain date and included them in the set without their permission.
The date on this is October 28th 1908
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