{ "meta": { "exportedAt": "2026-09-22T16:05:48.591Z", "formatVersion": 2, "selection": { "q": "yale-law", "system": "", "harm": "", "context": "", "country": "", "role": "", "relation": "core", "evidence": "", "year": "", "response": "lawsuit", "severity": "", "verification": "", "view": "incidents", "sort": "added" }, "totalIncidents": 1, "coverage": { "cases": 1, "countries": 1, "languages": 1, "unknownLocation": 0, "locationPending": 0, "unknownLanguage": 0, "unknownDate": 0, "lawsuits": 1, "regulatory": 0, "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-doe-v-clothoff-nj", "caseFacts": { "claims": [ { "id": "c1", "status": "documented", "evidence": [ { "locator": "Complaint caption and preliminary statement; ¶¶260-274, 338-340 (Telegram as nominal defendant).", "relation": "supports", "source_id": "s1" }, { "locator": "Docket D.E. 1 (filed 2025-10-16; assigned judges).", "relation": "supports", "source_id": "s2" } ], "assertion": "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." }, { "id": "c2", "status": "documented", "evidence": [ { "locator": "Complaint ¶¶33-40 (the discovery date, the Snapchat-group circulation, the age-14 source photo, the classmate uploader).", "relation": "supports", "source_id": "s1" }, { "locator": "TechCrunch's complaint-based account, including that local authorities declined prosecution.", "relation": "context", "source_id": "s6" } ], "assertion": "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." }, { "id": "c3", "status": "documented", "evidence": [ { "locator": "Complaint ¶¶1-6, 54-55 (visitors, image rate, watermark, three clicks), ¶¶220-255 (affiliated services), ¶¶695-697 (bots, API).", "relation": "supports", "source_id": "s1" } ], "assertion": "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." }, { "id": "c4", "status": "corroborated", "evidence": [ { "locator": "Guardian passages naming the operators, the fake CEO, Texture Oasis and GGSel/GG Technology; the Almendralejo and Westfield links; '>4m monthly visits'.", "relation": "supports", "source_id": "s4" }, { "locator": "Bellingcat's network map and payment-laundering account (G2A/Skinsback/Steam/PayPal/Stripe/Patreon), 23 Feb 2024.", "relation": "supports", "source_id": "s5" } ], "assertion": "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)." }, { "id": "c5", "status": "documented", "evidence": [ { "locator": "Docket entries D.E. 12-20 (24 Jun notice; 29 Jun vacatur; 8 Jul order; 9 Jul motion and exhibits; 3 Aug setting).", "relation": "supports", "source_id": "s2" } ], "assertion": "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." }, { "id": "c6", "status": "disputed", "evidence": [ { "locator": "Yale's account of the removal letters and platform responses (X, Discord, Google, YouTube).", "relation": "supports", "source_id": "s3" }, { "locator": "TechCrunch: the service was 'still available... through a Telegram bot' (12 Jan 2026).", "relation": "contradicts", "source_id": "s6" } ], "assertion": "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." } ], "effects": [ { "label": "AI-generated CSAM of a minor circulated in her school community; federal suit against the platform", "claim_id": "c2", "direction": "negative" } ], "sources": [ { "id": "s1", "url": "https://storage.courtlistener.com/recap/gov.uscourts.njd.585002/gov.uscourts.njd.585002.1.0.pdf", "kind": "court_filing", "access": "read", "language": "en", "translation_note": "Complaint PDF (45 pages) fetched and read via pdftotext on 2026-09-15. The filing establishes its own contents; its allegations remain allegations.", "independence_group": "court-record" }, { "id": "s2", "url": "https://www.courtlistener.com/docket/71665449/doe-v-airobotics-venture-strategy-3-ltd/", "kind": "court_docket", "access": "read", "language": "en", "translation_note": "Docket reviewed on 2026-09-15 through D.E. 20 (mirror ends 15 July 2026).", "independence_group": "court-record" }, { "id": "s3", "url": "https://law.yale.edu/yls-today/news/clinics-file-suit-against-website-generates-nonconsensual-nude-images", "kind": "party_announcement", "access": "read", "language": "en", "translation_note": "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.", "independence_group": "yale" }, { "id": "s4", "url": "https://www.theguardian.com/technology/2024/feb/29/clothoff-deepfake-ai-pornography-app-names-linked-revealed", "kind": "news_investigation", "access": "read", "language": "en", "translation_note": "Read in full on 2026-09-15 (29 Feb 2024, Black Box).", "independence_group": "guardian" }, { "id": "s5", "url": "https://bellingcat.com/news/2024/02/23/behind-a-secretive-global-network-of-non-consensual-deepfake-pornography/", "kind": "news_investigation", "access": "read", "language": "en", "translation_note": "Read in full on 2026-09-15 (23 Feb 2024).", "independence_group": "bellingcat" }, { "id": "s6", "url": "https://techcrunch.com/2026/01/12/a-new-jersey-lawsuit-shows-how-hard-it-is-to-fight-deepfake-porn/", "kind": "news_report", "access": "read", "language": "en", "translation_note": "Read in full on 2026-09-15 (12 Jan 2026); own interview with co-lead counsel.", "independence_group": "techcrunch" }, { "id": "s7", "url": "https://arstechnica.com/tech-policy/2025/10/teen-haunted-by-fake-nudes-sues-to-kill-nudify-app-block-telegram-bots/", "kind": "news_relaying_wsj", "access": "read", "language": "en", "translation_note": "Read on 2026-09-15 (17 Oct 2025). Relays the WSJ report; adds Telegram's ToS statement and the separate suit against the boy.", "independence_group": "wsj" }, { "id": "s8", "url": "https://www.wsj.com/tech/ai/teen-sues-maker-of-fake-nude-software-b88f316f", "kind": "news_report", "access": "unavailable", "language": null, "translation_note": "HTTP 401 paywall on 2026-09-15; not read; language not established.", "independence_group": "wsj" }, { "id": "s9", "url": "https://www.nj.com/news/2026/01/this-nj-girl-was-a-victim-of-deepfake-porn-shes-suing-the-app-that-generated-it.html", "kind": "news_report", "access": "unavailable", "language": null, "translation_note": "HTTP 403 on 2026-09-15; not read; language not established.", "independence_group": "nj-com" } ], "version": 1, "ai_roles": [ "others_use" ], "contexts": [ "education", "justice" ], "unknowns": [ "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." ], "geography": { "basis": "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.", "court_countries": [ "US" ], "event_countries": [ "US" ], "affected_person_countries": [ "US" ] }, "publication": { "basis": "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.", "reviewed_on": "2026-09-15" }, "ai_involvement": { "basis": "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.", "status": "supported" }, "person_relations": [ "depicted_or_impersonated" ] }, "name": "Doe v. ClothOff (D.N.J.): a New Jersey minor sues the AI 'undressing' platform over generated CSAM", "summary": "On 16 October 2025, Jane Doe, a New Jersey minor suing through her parents, filed a federal complaint in the U.S. District Court for the District of New Jersey (2:25-cv-16671-ES-JBC) against the operators of ClothOff, an AI 'undressing' service, after ClothOff-generated sexual images of her — created from an ordinary photo of her at 14 — circulated in a Snapchat group when she was 15. The complaint, brought by Yale Law School clinics, alleges the platform was purpose-built to produce hyper-realistic non-consensual intimate imagery and names AI/Robotics Venture Strategy 3 Ltd. (British Virgin Islands), Alaiksandr Babichau and Dasha Babicheva (Minsk), and Telegram as nominal defendant. As of mid-July 2026 the docket shows a continuing effort to serve the foreign defendants by email or publication.", "incidentDate": "2023-10-20", "incidentEndDate": "2025-10-16", "incidentKind": "bounded_series", "incidentDatePrecision": "range", "exposurePattern": "repeated_interactions", "reportedDate": "2025-10-16", "aiSystem": "ClothOff (AI undressing service)", "aiCompany": "AI/Robotics Venture Strategy 3 Ltd. d/b/a ClothOff (BVI); operators identified in reporting as based in Minsk, Belarus", "severity": "high", "verificationStatus": "verified", "harmCategories": [ "minor_exploitation", "third_party_harm_facilitation" ], "harmOutcomes": [ "psychological_distress", "reputational_harm" ], "harmOutcomeSummary": "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.", "frameworkFacets": [], "causationStatus": "established", "participantUsersAffectedMin": 0, "otherPeopleHarmedMin": 1, "affectedCountStatus": "partial", "affectedCountEvidence": "One counted depicted person: Jane Doe (complaint). The complaint's 'several other girls in her class' are depicted but unnamed and unquantified, so the total is counted-plus-unquantified (partial). Platform visitor and image-rate figures (27 million visitors, ~200,000 images/day) are not people and are never counted.", "victimAgeRange": "minor", "jurisdiction": "US-NJ", "platformType": "other", "outcomeType": "lawsuit_filed", "outcomeStatus": "ongoing", "primarySourceUrl": "https://storage.courtlistener.com/recap/gov.uscourts.njd.585002/gov.uscourts.njd.585002.1.0.pdf", "primarySourceLabel": "Federal complaint, D.N.J. 2:25-cv-16671-ES-JBC (45 pages, read via pdftotext)", "firstPublishedAt": "2026-05-10T10:35:08.921808+00:00", "scopeVersion": "facts-v3", "tags": [ "lawsuit", "federal", "minor", "new-jersey", "clothoff", "deepfake", "csam", "ncii", "yale-law", "ongoing" ] } ] }