Doe v. ClothOff (NJ Federal Lawsuit Over AI-Generated CSAM of Minor)

On October 16, 2025, Jane Doe, a New Jersey minor suing through her parents Jill and Jack Doe, filed a federal lawsuit in the U.S. District Court for the District of New Jersey against the operators of ClothOff, an AI 'undressing' application that generated non-consensual sexual deepfake images using her photos.

The lawsuit is the first U.S. federal lawsuit specifically targeting the ClothOff platform and is brought by Yale Law School's Media Freedom & Information Access Clinic (MFIA) and Lowenstein International Human Rights Clinic, together with attorneys Shane Vogt (Vogt Law) and John Gulygas (Barr & Gulyas, LLC).

ClothOff is operated from Belarus and incorporated in the British Virgin Islands, marketed and designed specifically to generate hyper-realistic non-consensual nude and sexual imagery from ordinary photographs. The platform had over 3 million users as of November 2024 and was accessible via a website, Telegram bots, and a network of 15+ affiliated services. Defendants are being served through the Hague Service Convention for foreign defendants.

The complaint alleges violations of:

• Federal CSAM laws: 18 U.S.C. §§ 2251, 2252, 2252A, 2260 (production, distribution, and exploitation related to child sexual abuse material)
• Federal obscenity statutes: 18 U.S.C. §§ 1465, 1466, 1466A, 1470
• 47 U.S.C. § 223(d) (offensive material to minors)
• New Jersey state law criminalizing AI-generated non-consensual intimate imagery (signed by Gov. Phil Murphy in April 2024; third-degree offense)

The case sits in the same broader pattern as the 2023 Westfield High School deepfake incident in New Jersey, where boys created AI nudes of female classmates. Plaintiff is a separate victim from publicly identified Westfield activist Francesca Mani.

• ClothOff platform marketed and designed specifically to generate non-consensual sexual deepfake imagery from ordinary photos
• Tool produces 'hyperrealistic' nude and sexual depictions indistinguishable from real photographs
• Platform accessible via web and Telegram bots, lowering barrier to mass-scale abuse
• Network of 15+ affiliated services (AI Cum, Nudify, Undress, DrawNudes) operates with hydra-like resilience
• Platform purpose-built to generate output that constitutes CSAM when applied to images of minors
• Generated images can be widely distributed and indefinitely re-uploaded after creation

ClothOff is a purpose-built deepfake-generation tool with explicit marketing for non-consensual sexual imagery. When applied to photos of a minor — as in this case, plaintiff Jane Doe — the platform produces images that constitute child sexual abuse material under federal law.

The harm mechanism extends beyond the initial image generation:

1. Image production: A user uploaded ordinary photos of plaintiff; ClothOff generated hyper-realistic sexual deepfake imagery of the minor.
2. Distribution: Generated images can be screenshotted, downloaded, and shared to Telegram, social platforms, and forums; once distributed, they cannot be fully recalled.
3. Persistent harm: Victims face ongoing psychological distress, fear of recirculation, anxiety in school and public settings, and reputational harm — all amplified by the indistinguishability of AI imagery from real photographs.
4. Training-data feedback: Victims' images may be used to further train the AI systems generating more CSAM.
5. Jurisdictional shielding: Operating from Belarus with BVI incorporation makes enforcement, image takedown, and discovery extremely difficult.

Federal lawsuit filed October 16, 2025 in U.S. District Court for the District of New Jersey (case 2:25-cv-16671-ES-JBC). Defendants being served via the Hague Service Convention given foreign incorporation. Plaintiff seeks: (1) declaration that ClothOff violates federal and state law, (2) injunction shutting down ClothOff operations entirely, (3) injunction against producing and disclosing CSAM and non-consensual intimate imagery, (4) deletion of all generated images, (5) deplatforming from Telegram and other services, (6) monetary damages. Major news coverage wave in January 2026 (TechCrunch 2026-01-12, NJ.com 2026-01-23). Telegram removed ClothOff bot in October 2025; ClothOff also banned from X, Discord, Google, and YouTube.