The same one that I make when I stand somewhere and describe what I see. So I hold a camera to do it more accurately. And then I get tired so I mount the camera on a trip setup instead.
ACLU of IL v. Alvarez (2012): "The act of making an audio or audiovisual recording is necessarily included within the First Amendment’s guarantee of speech and press rights as a corollary of the right to disseminate the resulting recording."