| CINEMATOGRAPH | It's used to make pictures or compare a thing differently (13) |
| KEEP | From the Old English meaning "to observe" or "compare", the donjon or tower at the heart of a medieval castle, used as a refuge (4) |
| INOTHERWORDS | Saying same thing differently |
| SERPENTSTOOTH | King Lear compares a thankless child to this |
| HIEROGLYPHICS | Ancient Egyptian writing using pictures or symbols (13) |
| CAMERA | American lost in changes to apparatus to make pictures (6) |
| IMAGES | Setter's given a long time to make pictures (6) |
| COLORS | Uses crayons to make pictures on a rainy day |
| FILM | A membrane or skin; thin pellicle; a gauze of fine threads; haze or mist; plastic wrap; a strip of Celluloid for capturing pictures; or, a movie (4) |
| LIMN | Member said to make pictures the old way (4) |
| ETCH | To make pictures of sweet chestnut trees (4) |
| ARTIST | One to make pictures is in stir, at some trouble (6) |
| ROPED | Bound to make picture frame stick out (5) |
| IMAGE | I'm given long time to make picture |
| EQUATE | To compare, a pointed question, you hear in short, about what was consumed? (6) |
| LICHEN | Said to compare a composite organ (6) |
| MINIATURIST | With onus on "tiny", a word for a limner or painter of small-scale illustrations, manuscript illuminations, pictures or portraits; or, one who makes toy-size figurines and furnishings for dolls' house |
| SNAPSHOT | Given break, chance to make picture |
| LIKEN | Compare a plant organism, as some pronounce it |
| AREAS | Characters compare a screenplay's parts (5) |