Doe 1 v. X.AI Corp.

The Complaint alleges that X.AI Corp. and X.AI LLC developed and deployed an artificial intelligence model called "Grok" that generates content based on user prompts. The Complaint contends that whilst industry-standard safeguards exist to prevent AI systems from creating child sexual abuse material, Defendants deliberately chose not to implement such protections. The Complaint notes that on 20 October 2025, xAI launched a feature called "Spicy Mode" for its Grok Imagine tool, marketed as a capability designed to push the boundaries of AI-generated visual content. A Grok spokesperson described the feature as being aimed at creators seeking more provocative visual narratives. The Plaintiffs allege that this feature enabled the generation of the harmful images at the centre of the case, and that xAI launched it without adequate safeguards to prevent the creation of non-consensual intimate imagery or child sexual abuse material.

The Complaint alleges that the Defendants introduced Grok to the market and specifically designed it to generate sexualised content that other AI systems would refuse to create. The Complaint also contends that the Defendants continue to profit from Grok's ability to produce such material through licensing arrangements and direct user subscriptions. It is further alleged that this business model depends upon Grok's capacity to generate content that violates both legal standards and industry norms.

The Complaint alleges that Jane Doe 1 (an adult now but at minor at the relevant time) discovered that someone known to her had used Grok to generate sexually explicit images depicting her without her knowledge or consent. Following a criminal investigation, the Complaint describes that similar AI generated imagery of Jane Does 2 and 3 were found on the phone of the perpetrator. The Plaintiffs argue that these AI-generated images constitute child sexual abuse material under federal law and have caused severe psychological harm.

The Complaint asserts thirteen causes of action: (1) production with intent to distribute child pornography under Masha's Law, 18 U.S.C. sections 2255(a) and 2252A(a)(7); (2) distribution of child pornography under 18 U.S.C. sections 2255(a) and 2252A(a)(2); (3) possession of child pornography under 18 U.S.C. sections 2255(a) and 2252A(a)(5)(B); (4) beneficiary liability under the Trafficking Victims Protection Act, 18 U.S.C. sections 1595, 1594, and 1591(a)(2); (5) violation of California's statutory right of publicity under California Civil Code section 3344; (6) unfair competition under California Business and Professions Code section 17200 et seq.; (7) strict liability for design defect; (8) negligent design defect; (9) negligent undertaking; (10) negligence per se; (11) negligent infliction of emotional distress; (12) intentional infliction of emotional distress; and (13) public nuisance. Plaintiffs seek monetary damages, injunctive relief requiring implementation of CSAM prevention measures, restitution of profits derived from the allegedly unlawful conduct, and attorney's fees.