Yep, plus you've got to worry about the card names (unless you're giving every single card a new name like Wizards did with "Through the Omenpaths") and whether

Yep, plus you've got to worry about the card names (unless you're giving every single card a new name like Wizards did with "Through the Omenpaths") and whether a judge thinks that "no we don't distribute the images, we just have a big button to download them all from a third party!" is a meaningful distinction or a fig-leaf.