Sure, you have to use a non-pixel representation to make an image search index. I understand that. However, if the end result of the search is not an image, the

Sure, you have to use a non-pixel representation to make an image search index. I understand that. However, if the end result of the search is not an image, then is it the same? For example, you could learn some very basic features from an image, like "person's skin has this hue, their eyes are this color, etc." If you wrote that down and made it searchable, with the search target being a person's unique identifier (SSN or whatever), it would surprise me if that ran afoul of this rule, even if the features were extracted from an image. You can't be searching for a reference image if there is no reference image to search for. Maybe I'm wrong though. IANAL and honestly it doesn't matter. But if I were writing this law, I would write that no one would be allowed to use any system that extracts and searches using or makes searchable information about human faces. That would seem to cover my proposed workaround, and I doubt it would hurt any other use case that they meant to protect.