Hi Maddog,
Very similar I agree, esp the mouth and nose, I took ages comparing the pics and could only find a small similarity, take a look at this pic I put together,
http://img130.imagevenue.com/img.php?image=85467_check_it_out_123_533lo.jpg
2 photos 1 from the bath set and one from the set you posted, look at the pic of her in the bath, see the mole on her breast indicated by the arrow, then check out the other,
ok, so its very faint, maybe it better looked at from the original url
http://www.atkgallery.com/gcfree/2006/080506/premium1/images/ale075OLE_125464065.jpg (copy 'n' paste)
Not compelling proof thats its the same girl, but something to go on at least, we need to find more pics from each set, or new sets. Normally you can check by the teeth when models smile
but she didnt in any of these!!
Its very likely it is the same girl and i would say im probably 60% sure it it, but the other 40% is still niggling away at me......
Janalover