What the evidence supports
AI involvement: supported. The complaint alleges the images of Doe were generated by ClothOff from her photo; the platform's purpose-built undress function is documented by the complaint and the Guardian/Bellingcat investigations. The allegations remain allegations against the unserved defendants; the platform's existence, function and operator identity are independently investigated.
AI-to-person relation
- Depicted or impersonated the person
Core relations are communication, acting on someone’s behalf, and depiction or impersonation. Decision and claim relations are retained as contextual cases.
Someone else’s AI use. Settings: Education, Justice.
Claim status: Documented
Jane Doe, a minor suing through her parents, filed the complaint on 16 October 2025 in the U.S. District Court for the District of New Jersey (2:25-cv-16671-ES-JBC, Judge Esther Salas, Magistrate Judge James B. Clark) against AI/Robotics Venture Strategy 3 Ltd. d/b/a ClothOff (BVI), Alaiksandr Babichau and Dasha Babicheva (of Minsk), and Telegram entities as nominal defendants.
Causal attribution: Established directly by the filing and the docket.
- Court filing (supports): Complaint caption and preliminary statement; ¶¶260-274, 338-340 (Telegram as nominal defendant).
- Court docket (supports): Docket D.E. 1 (filed 2025-10-16; assigned judges).
Claim status: Documented
On 20 October 2023 Doe, then 15, learned that ClothOff-generated CSAM of her and 'several other girls in her class' was circulating in a Snapchat group; the source was an ordinary photo of her at age 14 from Instagram, uploaded by a minor classmate; local authorities declined to prosecute.
Causal attribution: Established as the complaint's contents; they remain the plaintiff's allegations. The prosecution decline is TechCrunch's reading of the complaint, attributed.
- Court filing (supports): Complaint ¶¶33-40 (the discovery date, the Snapchat-group circulation, the age-14 source photo, the classmate uploader).
- News report (context): TechCrunch's complaint-based account, including that local authorities declined prosecution.
Claim status: Documented
The complaint describes ClothOff as a purpose-built 'undress' service producing hyper-realistic output 'indistinguishable from real photographs' without a watermark in three clicks, with at least 27 million visitors and about 200,000 images per day, at least ten affiliated services, Telegram bots and an API.
Causal attribution: Established as the complaint's contents. These are the plaintiff's allegations, not independently audited figures; the historical record's '3 million users' and '15+ affiliated services' were corrected to the complaint's figures.
- Court filing (supports): Complaint ¶¶1-6, 54-55 (visitors, image rate, watermark, three clicks), ¶¶220-255 (affiliated services), ¶¶695-697 (bots, API).
Claim status: Corroborated
Reporting before the suit identified the operators: the Guardian's Black Box investigation named Babichau and Babicheva (Minsk), a fake AI 'CEO', the Texture Oasis payment front and GGSel/GG Technology links, and tied ClothOff to the Almendralejo (Spain) and Westfield NJ school incidents; Bellingcat's independent investigation mapped the same network and its payment laundering six days earlier.
Causal attribution: Two independent investigations six days apart; they overlap on GG Technology/Bondarenko but were conducted separately. The complaint itself relies on the Guardian's reporting (per Yale).
- News investigation (supports): Guardian passages naming the operators, the fake CEO, Texture Oasis and GGSel/GG Technology; the Almendralejo and Westfield links; '>4m monthly visits'.
- News investigation (supports): Bellingcat's network map and payment-laundering account (G2A/Skinsback/Steam/PayPal/Stripe/Patreon), 23 Feb 2024.
Claim status: Documented
The 2026 docket shows continuing service efforts: a Rule 4(m) call for dismissal on 24 June 2026 (service not effected; the pseudonym motion administratively terminated), vacated by Judge Salas on 29 June after the plaintiff showed ongoing foreign-service efforts; an order allowing service by email on 8 July; and a motion for service by publication or email on 9 July, set for decision on 3 August 2026.
Causal attribution: Established by the docket through the RECAP mirror's end (15 July 2026); nothing later is visible in this review.
- Court docket (supports): Docket entries D.E. 12-20 (24 Jun notice; 29 Jun vacatur; 8 Jul order; 9 Jul motion and exhibits; 3 Aug setting).
Claim status: Disputed
X, Discord, Google and YouTube removed ClothOff following the clinics' summer 2025 letters (Yale); the historical claim that Telegram removed the ClothOff bot in October 2025 is contradicted by TechCrunch, which found the service still available through a Telegram bot on 12 January 2026.
Causal attribution: The platform removals are a party account (Yale); the Telegram-bot status is contradicted by later reporting and recorded as disputed rather than resolved either way.
- Party announcement (supports): Yale's account of the removal letters and platform responses (X, Discord, Google, YouTube).
- News report (contradicts): TechCrunch: the service was 'still available... through a Telegram bot' (12 Jan 2026).
What remains unknown
- The service-by-publication/email motion's outcome after 3 August 2026 is not visible in the RECAP mirror (ends 15 July 2026); whether default judgment or dismissal followed is unknown.
- Whether Doe's school is the Westfield High School of the earlier New Jersey incident is unverified: the complaint names only 'a high school in Union County', and the historical record's 'separate victim from Francesca Mani' is not established by any inspected document. The school is deliberately not inferred or named.
- The current availability of the generated images is unknown.
- The platforms' and registries' responses to the requested injunctions are not yet reported.
- The complaint's platform figures (visitors, image rate) are the plaintiff's allegations and are not independently audited.
Source reading, translation and location
Court filing · en · Source inspected
Complaint PDF (45 pages) fetched and read via pdftotext on 2026-09-15. The filing establishes its own contents; its allegations remain allegations.
This source shares an underlying account with another listed source.
Court docket · en · Source inspected
Docket reviewed on 2026-09-15 through D.E. 20 (mirror ends 15 July 2026).
This source shares an underlying account with another listed source.
Party announcement · en · Source inspected
Read on 2026-09-15. Party source (the clinics bringing the suit); used for the clinics' role and the X/Discord/Google/YouTube removal letters.
News investigation · en · Source inspected
Read in full on 2026-09-15 (29 Feb 2024, Black Box).
News report · en · Source inspected
Read in full on 2026-09-15 (12 Jan 2026); own interview with co-lead counsel.
News relaying wsj · en · Source inspected
Read on 2026-09-15 (17 Oct 2025). Relays the WSJ report; adds Telegram's ToS statement and the separate suit against the boy.
This source shares an underlying account with another listed source.
News report · Language unknown · Source unavailable
HTTP 401 paywall on 2026-09-15; not read; language not established.
This source shares an underlying account with another listed source.
News report · Language unknown · Source unavailable
HTTP 403 on 2026-09-15; not read; language not established.
Event countries: United States. Affected-person countries: United States. Court countries: United States.
Event: a high school in Union County, New Jersey (complaint; the school is not named and is not inferred). Affected person: the New Jersey minor. Court: U.S. District Court for the District of New Jersey. The defendants' BVI/Belarus connections are recorded without becoming event or court countries.
Reviewed for publication 2026-09-15: Restored under the 2026-09-15 charter as a harmful-artifact case (depicted_or_impersonated) with the federal complaint as the primary record. The plaintiff is a minor protected by court-ordered pseudonymity; no school, classmate or image description beyond the minimum case facts is reproduced. The complaint's contents are recorded as allegations; operator identity rests on two independent investigations.
What Happened
According to the complaint (¶¶33-40), on 20 October 2023 Doe, then 15, learned that ClothOff-generated child sexual abuse material of her and 'several other girls in her class' was circulating in a Snapchat group; the source was an ordinary photo of her at age 14 from Instagram, uploaded by a minor classmate. TechCrunch reports from the complaint that local authorities declined prosecution. The complaint (filed 16 October 2025 in the D.N.J. before Judge Esther Salas and Magistrate Judge James B. Clark) alleges ClothOff is a purpose-built 'undress' service producing hyper-realistic output 'indistinguishable from real photographs' without a watermark in three clicks, with at least 27 million visitors and about 200,000 images per day, at least ten affiliated services, Telegram bots and an API (¶¶1-6, 54-55, 220-255, 695-697). It names AI/Robotics Venture Strategy 3 Ltd. d/b/a ClothOff (Tortola, BVI), Alaiksandr Babichau and Dasha Babicheva (of Minsk, described as developing, maintaining and profiting from the service), and Telegram Group Inc./Telegram Messenger Inc. as nominal defendants. The Guardian's Black Box investigation (29 February 2024) had named Babichau and Babicheva, a fake AI 'CEO', the Texture Oasis payment front and GGSel/GG Technology links, tying ClothOff to the Almendralejo (Spain) and Westfield NJ school incidents; Bellingcat's independent investigation (23 February 2024) mapped the same network and its payment laundering. The suit seeks pseudonymity, deletion and destruction of the CSAM including Doe's, a bar on training AI on her images, permanent injunctions against operating or marketing any CSAM/NCII service, and injunctions binding registries, hosts, payment processors and platforms including Telegram. The 2026 docket shows service difficulties: a Rule 4(m) call for dismissal on 24 June 2026 (service not effected; pseudonym motion administratively terminated), vacated by Judge Salas on 29 June after the plaintiff showed ongoing foreign-service efforts, an order allowing service by email on 8 July, and a motion for service by publication or by email filed 9 July, set for decision on 3 August 2026; the RECAP mirror ends 15 July 2026 with no default judgment, dismissal or service resolution visible. X, Discord, Google and YouTube removals are confirmed by Yale (summer 2025 letters); the historical claim that Telegram removed the ClothOff bot is contradicted by TechCrunch (12 January 2026), which found the service still available through a Telegram bot.
Reported harm
ClothOff-generated CSAM of a 15-year-old circulated in her school's Snapchat group from an ordinary childhood photo — persistent image-based abuse of a minor that local authorities declined to prosecute, leaving the federal suit as the remedy path.
Psychological DistressReputational Harm