{ "meta": { "exportedAt": "2026-09-22T14:39:58.263Z", "formatVersion": 2, "selection": { "q": "class-action", "system": "", "harm": "", "context": "", "country": "", "role": "", "relation": "", "evidence": "", "year": "2025", "response": "regulatory", "severity": "", "verification": "", "view": "incidents", "sort": "added" }, "totalIncidents": 1, "coverage": { "cases": 1, "countries": 0, "languages": 1, "unknownLocation": 1, "locationPending": 0, "unknownLanguage": 0, "unknownDate": 0, "lawsuits": 0, "regulatory": 1, "minors": 1, "coreRelations": 1, "contextualRelations": 0, "mixedRelations": 0, "unknownRelations": 0, "relationPending": 0, "relationUnknown": 0 }, "countingNote": "Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.", "affectedCountNote": "Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.", "source": "NOPE Incident Tracker", "url": "https://nope.net/incidents", "license": "CC BY 4.0" }, "incidents": [ { "id": "2025-grok-non-consensual-image-generation", "caseFacts": { "claims": [ { "id": "c1", "status": "corroborated", "evidence": [ { "locator": "'image generation and editing are currently limited to paying subscribers'; the standalone app/X tab complied with undress requests including NBC's consenting test subject.", "relation": "supports", "source_id": "s2" }, { "locator": "AP: Grok let users 'undress people, putting females in transparent bikinis or revealing clothing'; some images appeared to include children.", "relation": "supports", "source_id": "s7" }, { "locator": "'Over the past several weeks, Grok allowed users to create and publicly post sexually altered images of real people at the click of a button.'", "relation": "supports", "source_id": "s8" } ], "assertion": "From late December 2025, Grok's image generation and editing on X and the standalone app let users generate sexualized images of real people at scale; xAI limited generation to paying subscribers on 9 January 2026, but NBC's own consenting test found the standalone app and X tab still complied with 'undress' requests.", "causal_attribution": "The conduct is established by NBC's direct test plus official accounts; the paywall change's limited effect is NBC's finding." }, { "id": "c2", "status": "reported", "evidence": [ { "locator": "Genevieve Oh's analysis: 7,751 sexualized images in one hour Wednesday, up 16.4% from 6,659/hr Monday.", "relation": "supports", "source_id": "s2" }, { "locator": "NYT via NC DOJ: 'generated and posted 4.4 million images, of which at least 41 percent were sexualized images of women' over nine days.", "relation": "supports", "source_id": "s8" }, { "locator": "CCDH via Engadget: 'an estimated 3 million sexualized images over 11 days, including 23,000 of minors'.", "relation": "supports", "source_id": "s9" } ], "assertion": "Scale analyses: Genevieve Oh's analysis found 7,751 sexualized images generated in one hour on a Wednesday (up 16.4% from 6,659/hour on Monday); the New York Times reported 4.4 million images over nine days, at least 41% sexualized images of women; an AP analysis of 20,000 images from 25 December-1 January found 2% appeared to be 18 or younger; CCDH estimated about 3 million sexualized images over 11 days including roughly 23,000 of minors.", "causal_attribution": "Each figure belongs to its own analysis (Oh; NYT; AP via Fortune; CCDH); none is platform-confirmed and they are not merged. The AP 20,000-image analysis is carried via Fortune. The Bloomberg ~6,700/hour, 84-85x figure is recorded as unavailable." }, { "id": "c3a", "status": "reported", "evidence": [ { "locator": "'I felt horrified, I felt violated, especially seeing my toddler's backpack in the back of it'; image of her at 14 undressed, up ~12 hrs, removed after the Guardian sought comment.", "relation": "supports", "source_id": "s3" } ], "assertion": "Ashley St. Clair said users sexualized images of her, including one of her at 14 that stayed up about 12 hours and was removed after the Guardian sought comment: 'I felt horrified, I felt violated.'", "causal_attribution": "Her account to the Guardian; her own lawsuit is a separate held row and is not merged here." }, { "id": "c3b", "status": "reported", "evidence": [ { "locator": "'dehumanised and reduced into a sexual stereotype'; 'others asked Grok to generate more of her'; 'While it wasn't me that was in states of undress, it looked like me and it felt like me and it felt as violating.'", "relation": "supports", "source_id": "s1" } ], "assertion": "Samantha Smith told the BBC she felt 'dehumanised and reduced into a sexual stereotype', and after she posted about it, others asked Grok to generate more of her.", "causal_attribution": "Her account to the BBC." }, { "id": "c3c", "status": "reported", "evidence": [ { "locator": "'had seen an increase in people using Grok to undress her'; the 'sticking plaster' quote.", "relation": "supports", "source_id": "s4" } ], "assertion": "Dr Daisy Dixon, a Cardiff University lecturer, told the BBC she had seen an increase in people using Grok to undress her and called the paywall change 'a sticking plaster'.", "causal_attribution": "Her account to the BBC." }, { "id": "c4", "status": "corroborated", "evidence": [ { "locator": "IWF analysts found 'criminal imagery' of girls aged 11-13 apparently made with Grok.", "relation": "supports", "source_id": "s4" }, { "locator": "AI Forensics' review: ~800 archived URLs, <10% apparent CSAM ('photorealistic people, very young'), ~70 URLs reported to EU regulators.", "relation": "supports", "source_id": "s5" } ], "assertion": "The Internet Watch Foundation told the BBC its analysts found 'criminal imagery' of girls aged 11-13 apparently made with Grok; Wired and AI Forensics reviewed about 800 archived Grok Imagine URLs with under 10% apparent CSAM and reported about 70 URLs to EU regulators.", "causal_attribution": "Two independent expert bodies' findings (IWF; AI Forensics); the minors are unnamed and uncounted per the counting rules." }, { "id": "c5", "status": "corroborated", "evidence": [ { "locator": "NBC: Ofcom 'urgent contact'; Starmer 'disgraceful... X has got to get a grip'.", "relation": "supports", "source_id": "s2" }, { "locator": "ICO announcement: formal investigations into XIUC and X.AI; follows the 7 January contact.", "relation": "supports", "source_id": "s6" }, { "locator": "AP via PBS: the EU's formal DSA investigation; 'materialized' risks; 'serious harm'.", "relation": "supports", "source_id": "s7" }, { "locator": "NC DOJ release: the 35-AG letter and its demands.", "relation": "supports", "source_id": "s8" }, { "locator": "Engadget: the Baltimore suit; City Solicitor Thompson's statement.", "relation": "supports", "source_id": "s9" }, { "locator": "TechPolicy.Press: the Amsterdam order of 26 March.", "relation": "supports", "source_id": "s13" }, { "locator": "Reuters headline (body unavailable): Ireland DPC inquiry of 17 February.", "relation": "context", "source_id": "s11" } ], "assertion": "Formal regulatory and legal actions followed: Ofcom's urgent contact (5 Jan; response by 9 Jan; investigation announced 12 Jan); the UK ICO's formal investigations into XIUC and X.AI LLC (3 Feb); the European Commission's formal DSA investigation (26 Jan, risks 'materialized' into 'serious harm'); Ireland's DPC GDPR inquiry (17 Feb); 35 US state attorneys general's demand letter (23 Jan); Baltimore's consumer-protection suit (24 Mar; D. Md. 1:26-cv-02103); and an Amsterdam court order to stop generating or distributing non-consensual sexualized images in the Netherlands (26 Mar, Offlimits suit, penalty up to €10 million).", "causal_attribution": "Each action is carried by an inspected official or news source; the California AG probe (NBC) and the Indonesia/Malaysia/Philippines blocks (Reuters bodies unavailable) are recorded in the outcome and reported in the narrative." }, { "id": "c6", "status": "corroborated", "evidence": [ { "locator": "AP: the X statement of 14 January ('bikinis, underwear or other revealing attire', where illegal).", "relation": "supports", "source_id": "s7" }, { "locator": "BBC (16 Mar): Musk's 'Literally zero' post of 14 January.", "relation": "supports", "source_id": "s10" } ], "assertion": "xAI's 14 January statement said it would stop allowing users to depict people in 'bikinis, underwear or other revealing attire' where illegal; Musk posted on 14 January that he was 'not aware of any naked underage images... Literally zero'.", "causal_attribution": "The company's and Musk's statements are recorded as their positions; the IWF and AI Forensics findings stand in tension with 'Literally zero' and are preserved as contrary evidence." }, { "id": "c7", "status": "reported", "evidence": [ { "locator": "BBC (20 Apr 2026): the 3 Feb raid, the summons, Musk's non-appearance, the DOJ refusal, and the probe's scope.", "relation": "supports", "source_id": "s10" } ], "assertion": "Paris police raided X's offices on 3 February and summoned Musk and Yaccarino for 20 April; Musk did not appear, and the US DOJ declined to assist France; the French probe includes complicity in possession or organised distribution of child sexual abuse material.", "causal_attribution": "Single inspected chain (BBC); attributed accordingly." } ], "effects": [ { "label": "industrial-scale non-consensual sexualized imagery of real people, including apparent minors, generated by Grok", "claim_id": "c1", "direction": "negative" } ], "sources": [ { "id": "s1", "url": "https://www.bbc.com/news/articles/c98p1r4e6m8o", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (2 Jan 2026). Samantha Smith's account.", "independence_group": "bbc" }, { "id": "s2", "url": "https://www.nbcnews.com/tech/internet/x-paywall-ai-image-grok-app-bikini-allows-sexual-deepfakes-rcna252647", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (8 Jan 2026). Paywall change; NBC's own consenting test; Genevieve Oh's analysis; Starmer and Ofcom accounts.", "independence_group": "nbc" }, { "id": "s3", "url": "https://www.theguardian.com/technology/2026/jan/05/elon-musk-ashley-st-clair-grok-fake-sexualised-images", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (5 Jan 2026). Ashley St. Clair's account.", "independence_group": "guardian" }, { "id": "s4", "url": "https://www.bbc.com/news/articles/c99kn52nx9do", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (9 Jan 2026, McMahon/Cress). Dr Daisy Dixon; the IWF finding.", "independence_group": "bbc" }, { "id": "s5", "url": "https://www.wired.com/story/grok-is-generating-sexual-content-far-more-graphic-than-whats-on-x/", "kind": "news_investigation", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (7 Jan 2026, Burgess/Varner). AI Forensics' review of ~800 archived Grok Imagine URLs.", "independence_group": "wired" }, { "id": "s6", "url": "https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/02/ico-announces-investigation-into-grok/", "kind": "regulator_announcement", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (formal investigations into XIUC and X.AI LLC; follows the 7 January urgent-information contact).", "independence_group": "ico" }, { "id": "s7", "url": "https://www.pbs.org/newshour/world/eu-investigates-musks-ai-chatbot-grok-over-sexual-deepfakes", "kind": "wire_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (AP, Kelvin Chan; 26 Jan 2026). EU DSA investigation; X's 14 January statement.", "independence_group": "ap" }, { "id": "s8", "url": "https://ncdoj.gov/attorney-general-jeff-jackson-leads-bipartisan-coalition-demanding-xai-stop-creating-and-remove-groks-nonconsensual-sexual-images/", "kind": "regulator_press_release", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (23 Jan 2026). The 35-AG letter; quotes the New York Times' 4.4M/41% figure.", "independence_group": "nc-doj" }, { "id": "s9", "url": "https://www.engadget.com/ai/baltimore-sues-xai-over-grok-deepfakes-214135922.html", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (24 Mar 2026). Baltimore suit; the CCDH estimate.", "independence_group": "engadget" }, { "id": "s10", "url": "https://www.bbc.com/news/articles/crk151nn7j3o", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (20 Apr 2026). Paris raid; Musk's non-appearance; DOJ refusal to assist France.", "independence_group": "bbc" }, { "id": "s11", "url": "https://www.reuters.com/sustainability/boards-policy-regulation/ireland-opens-probe-into-musks-grok-ai-over-sexualised-images-2026-02-17/", "kind": "wire_report", "access": "unavailable", "language": null, "translation_note": "HTTP 401 on 2026-09-15; headline and date verified from the URL and snapshot; body not read.", "independence_group": "reuters" }, { "id": "s12", "url": "https://www.bloomberg.com/news/articles/2026-01-07/", "kind": "news_report", "access": "unavailable", "language": null, "translation_note": "HTTP 403 on 2026-09-15; the ~6,700/hour, 84-85x analysis is attributed from the historical record and secondary references; body not read.", "independence_group": "bloomberg" }, { "id": "s13", "url": "https://www.techpolicy.press/dutch-court-orders-x-grok-to-stop-aigenerated-sexual-abuse-content/", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in English on 2026-09-15 (27 Mar 2026). Amsterdam court order in the Offlimits case.", "independence_group": "techpolicy-press" }, { "id": "s14", "url": "https://www.nbcnews.com/tech/tech-news/ashley-st-clair-sues-xai-grok-sexual-images-rcna254302", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read on 2026-09-15 (15 Jan 2026). St. Clair's suit; cross-reference to the related held row.", "independence_group": "nbc" }, { "id": "s15", "url": "https://www.pacermonitor.com/public/case/64870891/MAYOR_AND_CITY_COUNCIL_OF_BALTIMORE_v_X_Corp_et_al", "kind": "court_docket", "access": "read", "language": "en", "translation_note": "Docket page read on 2026-09-15 (D. Md. 1:26-cv-02103; SpaceX dismissed without prejudice 17 Jul; MTD briefing under way as of 29 Jul).", "independence_group": "court-record" } ], "version": 1, "ai_roles": [ "others_use" ], "contexts": [ "everyday_life", "justice" ], "unknowns": [ "The Bloomberg analysis (~6,700 images/hour, 84-85x leading deepfake sites) could not be read (403) and is recorded without its body.", "Whether the images remain hosted and downloadable (Wired's June 2026 follow-up, cited but not read) is unverified.", "The N.D. Cal. class action's pseudonymity ruling of 30 July is known only through a blocked summary (internetcases 403).", "The outcome of the Amsterdam order's penalty mechanism and xAI's compliance are not reported in the inspected sources.", "The Indonesia/Malaysia/Philippines blocks and lifts are recorded from the historical record and headlines (Reuters/CNN bodies unavailable); dates may shift one day across carriers.", "The historical claim of 'five countries acting within two weeks' is not precisely verified and is not claimed." ], "geography": { "basis": "The generation and consumption were global and not tied to an inspected event location, so event and affected-person countries remain unknown rather than inferred from regulators or the company's seats. Court countries are limited to the documented proceedings: the US (Baltimore D. Md. suit; the related US suits) and the NL (Amsterdam court order). Regulatory actions by Ofcom, the ICO, the EU, the DPC, Indonesia, Malaysia and the Philippines are not courts.", "court_countries": [ "US", "NL" ], "event_countries": [], "affected_person_countries": [] }, "publication": { "basis": "Restored under the 2026-09-15 charter as a harmful-artifact crisis (depicted_or_impersonated). Named victims are adults who spoke publicly; minors are never named and never counted from image statistics. Each scale figure is attributed to its own analysis; the victims' accounts are single-chain and recorded as reported. Related xAI suits (St. Clair, Tennessee minors, others) are separate held rows and are not merged.", "reviewed_on": "2026-09-15" }, "ai_involvement": { "basis": "NBC's own consenting test confirmed the standalone Grok app and X tab complied with 'undress' requests after the 9 January paywall change; the victims' accounts, the IWF and AI Forensics reviews, and xAI's own 14 January restriction all establish the AI generation. The scale figures are attributed analyses, not platform-confirmed numbers.", "status": "supported" }, "person_relations": [ "depicted_or_impersonated" ] }, "name": "Grok non-consensual sexual image generation wave (December 2025 - January 2026)", "summary": "From late December 2025, xAI's Grok image editing on X let users generate sexualized images of real people at industrial scale, including images of named women and apparent minors. Analyses attributed to Genevieve Oh (7,751 sexualized images in one hour, via NBC), the New York Times (4.4 million images in nine days, at least 41% sexualized images of women, via the NC AG), the AP (2% of a 20,000-image sample appearing to be minors, via Fortune) and CCDH (about 3 million sexualized images over 11 days including roughly 23,000 of minors, via Engadget) documented the scale. Named women — Ashley St. Clair, Samantha Smith and Dr Daisy Dixon — described being undressed by Grok and revictimized when they objected. The wave triggered formal actions by Ofcom, the UK ICO, the EU (DSA), Ireland's DPC, 35 US state attorneys general, the California AG, Baltimore (consumer-protection suit), an Amsterdam court order, country blocks in Indonesia, Malaysia and the Philippines, and a Paris police raid; xAI restricted generation to paying subscribers on 9 January and narrowed the feature on 14 January 2026.", "incidentDate": "2025-12-25", "incidentEndDate": "2026-01-14", "incidentKind": "bounded_series", "incidentDatePrecision": "range", "exposurePattern": "repeated_interactions", "reportedDate": "2026-01-02", "aiSystem": "Grok (image generation and editing on X and the standalone app)", "aiCompany": "SpaceXAI (formerly xAI)", "severity": "critical", "verificationStatus": "verified", "harmCategories": [ "minor_exploitation", "third_party_harm_facilitation", "barrier_erosion" ], "harmOutcomes": [ "psychological_distress", "reputational_harm" ], "harmOutcomeSummary": "Mass non-consensual sexualized imagery of real people — including apparent minors — generated at industrial scale and amplified when victims objected, with named women describing violation and dehumanization and regulators on three continents opening formal actions.", "frameworkFacets": [], "causationStatus": "established", "participantUsersAffectedMin": 0, "otherPeopleHarmedMin": 3, "affectedCountStatus": "partial", "affectedCountEvidence": "Three counted depicted persons: Ashley St. Clair (Guardian), Samantha Smith (BBC) and Dr Daisy Dixon (BBC), each named and speaking publicly. Further victims — including the minors in the IWF's apparent criminal imagery (girls 11-13) and the people in the analysis samples — are unquantified: hourly image rates, the 20,000-image sample and the CCDH estimate count images, not people, and are never converted.", "victimAgeRange": "minor", "jurisdiction": "XX", "platformType": "assistant", "outcomeType": "regulatory_action", "outcomeStatus": "ongoing", "primarySourceUrl": "https://www.bbc.com/news/articles/c98p1r4e6m8o", "primarySourceLabel": "BBC (2 Jan 2026) — Samantha Smith's account of being undressed by Grok and revictimized when she objected", "firstPublishedAt": "2026-01-11T12:19:47.670189+00:00", "scopeVersion": "facts-v3", "tags": [ "grok", "xai", "csam", "deepfakes", "minor", "sexual-images", "industrial-scale", "multi-country", "eu-dsa", "class-action", "35-state-ag", "depicted-or-impersonated" ] } ] }