That is obviously correct - where did I state/imply otherwise? V-Cards do not require new images, they're just a nice bonus if the companies involved are so inclined to allow it. For example, the Trek CC has permission from Paramount to use new images in order to create entirely new (virtual) cards - Lucasfilm does not, so the Star Wars PC has to make due with the existing images in that game.
Again, if a COMPANY wanted to produce a BRAND NEW card game based on LotR material found only in print and not at all from the movies, they would only need to license it from Tolkien etc and NOT New Line Cinema. I think you read that as an organization (PC) instead of company (Upper Deck). Being that the PC would be using the movies as its primary source document, as well as (possibly) other Tolkien works, they would need permission from all parties, whether or not new (or even old) images are involved.