AI-generated Child Pornography Deepfake Litigation
Update: On March 16, 2026, Lieff Cabraser Heimann & Bernstein and Baehr-Jones Law filed a class action lawsuit today in the Northern District of California against xAI on behalf of three victims whose real photographs were used to produce AI-generated child sexual abuse material (CSAM) through xAI’s Grok tool. The complaint alleges that xAI knowingly designed, marketed, and profited from an AI image and video generator capable of creating sexually explicit content depicting real people, including children, while refusing to implement the industry-standard CSAM prevention measures used by every other major AI company.
The lawsuit details how xAI, under the direction of Elon Musk, deliberately designed Grok to create sexually explicit content, marketed a “Spicy Mode” to attract users, and configured the model’s system prompt to assume “good intent” when users referenced “teenage” or “girl.” Musk personally popularized and promoted Grok’s ability to undress people on X, fueling a viral trend in which users directed Grok to digitally undress real women and children. During an eleven-day period in late December 2025 and early January 2026, researchers at the Center for Countering Digital Hate estimated Grok generated approximately three million sexualized images and 23,000 images depicting apparent children.
After this was revealed, rather than disabling the feature, xAI restricted image generation to paying subscribers, and advertised “Spicy Mode” as a premium benefit. The complaint further alleges that xAI licenses access to its Grok AI model to third-party apps, using xAI servers and platforms to produce CSAM content requested by these apps’ customers, as an additional source of xAI profit. The Internet Watch Foundation has warned that many of these images have since migrated to the dark web, where they are being repurposed by predators.
“This lawsuit against xAI represents more than just another legal challenge for a Musk company. It’s a watershed moment that will test whether existing laws can adequately address the harms enabled by generative AI, and whether the industry’s current approach to content safety is sufficient. For xAI, the immediate concern is defending against potentially massive liability and class-action damages. For the broader AI industry, the case signals that the era of moving fast and breaking things may be over when the things being broken are children’s safety and dignity. How courts rule here will influence everything from AI development practices to venture capital risk calculations for years to come.”
— The Tech Buzz, 3/16/26, “xAI Hit With Child Exploitation Lawsuit Over Grok AI”
Previously, Lieff Cabraser had been actively investigating reports of artificial intelligence AI tools used to alter photographs of minors into hyper-realistic sexually explicit images and videos, including but not limited to Grok, various “nudify” and “undress” apps, Telegram bots, etc.
Once created, these images can be shared endlessly without the depicted victim’s knowledge and absent their consent.
In 2025 alone, the Internet Watch Foundation reported a 26,362% increase year over year in videos showing child sexual abuse — not a typo, that’s a twenty-six thousand percent increase. The Foundation also found that 65% of those 2025 AI videos were classified as “Category A” — the most severe legal classification involving the most extreme content.
If you or a family member suspect you have been the victim of such deepfake sexually explicit images or video, we urge you to use the form on this page to reach out to Lieff Cabraser partner Annika K. Martin about your case and potential recovery.
Talk to us today
Lieff Cabraser has been nationally-recognized for its work in championing the rights of children, women, the abused, and the marginalized and disenfranchised across the U.S. for over five decades. There is no charge for our review of your case, and the information you provide will help us hold these AI companies accountable for their dangerous and harmful actions.
Recognized National Child Advocacy Lawyers at Lieff Cabraser
Lieff Cabraser has litigated to protect and advance the rights of internet users, especially child and young adult internet users, for decades, including in cases aimed at curtailing the illegal and deceptive acquisition and monetization of young user’s deeply private and personal identity and location information as well as cases seeking to eradicate sex trafficking and related degradations across multiple social media platforms. Our civil rights and privacy cases have led to judgments and settlements for our clients valued at over $8 billion as well as significant and enduring changes to law and corporate policy for the benefit of all.
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March 16, 2026 - xAI Hit With Child Exploitation Lawsuit Over Grok AI
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March 16, 2026 - Teens sue Musk’s xAI, arguing Grok made child sexual abuse material
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March 16, 2026 - Lawsuit against Elon Musk’s xAI alleges Grok created sexualized deepfakes of 3 minors
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March 16, 2026 - Elon Musk’s A.I. Is Generating Sexualized Images of Real People, Fueling Outrage
The New York Times
January 9, 2026









