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'Making' nowadays can be as simple as viewing an indecent image online. Once you click that image, it's details are indelibly recorded on the computer's history - thus you have 'made' this image in a new location.

There have been some recent libel cases surrounding CPS charging announcements for this particular crime which may be of interest (the offender arguing that 'making' has a defamatory connotation of physically taking photographs).

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