:::::::Yes, essentially.  This is a firmly and widely accepted interpretation it appears as a specific example on WP:NONFREE. I would eliminate the 48-hour period myself, and have actually proposed doing soI guess maybe the theory is that within that period you can advance evidence that the person is a recluse, or that particular photo is necessary to show a career-defining moment, etc. The three people above are a borderline case, because there they are in character for a TV show, which appears on the page about the TV show.  They wouldn't appear in public all together, and certainly not dressed as their characters.  So I think that that one is not replaceable, to show what the TV show characters look like.