Victims of child sexual abuse accuse xAI of using their images to train grok's deepfake capabilities
A class action lawsuit has been filed by victims of child sexual abuse material (CSAM), accusing xAI of training Grok’s synthetic deepfake 'nudify' capabilities on real images and videos of child abuse. The lawsuit, filed in the U.S. District Court for the Northern District of California, names Jane Doe 1 and other anonymous individuals as plaintiffs, identifying Doe as a victim of child pornography tracked by the Federal Bureau of Investigation’s Child Exploitation Notification Program. Doe was a pre-school aged child when her perpetrator’s abuse began and continued for years, with media depicting her circulating online since at least the early 2000s, including hundreds of thousands of files submitted to the National Center for Missing & Exploited Children (NCMEC).
The lawsuit alleges that Doe’s material has 'well known hash-values' that have appeared in deepfakes created with Grok and spread on X. It states that CSAM depicting the plaintiff has been found on xAI as part of investigative reporting, takedown requests, and criminal investigations. The suit also claims that xAI, using Grok, has generated images depicting the plaintiff and the child pornography series in which she is the victim. The lawsuit cites 'Masha’s Law' as the basis for its allegations, a 2018 law that protects civil legal remedies for victims of child pornography and online exploitation.
According to an analysis by the Center for Countering Digital Hate, during an 11-day period between December 2, 2025, and January 2, 2026, Grok created more than 3 million sexualized images, at least 23,000 of which appeared to depict children. On January 14, after the period tracked by the center, Elon Musk wrote on X that he was 'not aware of any naked underage images of Grok. Literally zero.' Musk also implied that users, not his technology, were primarily responsible for images created using Grok, while simultaneously claiming the model 'will refuse to produce anything illegal' if asked.
The suit claims that while other competitors enacted guardrails to prevent their AI models from generating 'nudified' images of adults and children, xAI 'did the opposite,' embedding Grok and its deepfake capabilities directly into X, effectively creating an instantaneous CSAM generation and distribution system for the internet. The lawsuit notes that xAI said it built in guardrails to prevent Grok from creating deepfake sexualized images, but these are 'very weak,' diverge from standard industry best practice, and can be easily circumvented. The system rejects prompts where the chatbot detects 'clear intent by the user in the phrasing of their request,' but indirect or euphemistic prompts can easily slip past a text-based filter, so if the model retains the underlying capability to generate sexual or abusive content, some volume of CSAM becomes effectively inevitably generated by the system.
The lawsuit also notes that Grok’s terms of service treat anything posted on X as training material, meaning any CSAM material posted on the site over the past year was likely ingested by the model. The alleged victims are asking for monetary damages along with injunctions to prevent Grok from creating additional harm through future sexualized deepfakes or CSAM. The suit lists 'thousands' of members in the class, all with similar claims against xAI. A request for comment on the lawsuit sent to xAI was not returned.
Grok’s nudification capabilities, along with Elon Musk’s dismissive public attitude around the fallout, have led to international outrage, criminal investigations, and a wave of private lawsuits against the company. Another lawsuit against X filed earlier this year claims that a man used Grok to generate thousands of instances of deepfake CSAM material of his stepdaughter. That lawsuit also claims xAI withheld information from law enforcement authorities that would have helped them identify the stepfather as the perpetrator. Days after authorities traced and seized the material on the web, he committed suicide.
In July, Musk sued Minnesota Attorney General Keith Ellison over a new state law that bans nudification technology and imposes a $500,000 fine for each instance where an AI tool is used to generate or alter an image in a sexually explicit way. Musk’s lawsuit claims the ban violates the First Amendment.