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Doe v X.AI Corp

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Case Information
Case name Doe v. X.AI Corp[1]
Court U.S. District Court for the Northern District of California[1]
Docket 5:26-cv-02246-PCP[1]
Filed March 16, 2026[2]
Judge(s) P. Casey Pitts (PCP on the amended complaint)[1][3]
Plaintiffs Jane Does 1–5 (pseudonymous plaintiffs)[1]
Defendants X.AI Corp.; X.AI LLC; X.AI Holdings LLC; Stability AI U.S. Services Corp.; Stability AI, Inc.[1]
Case type Proposed civil class action[1]
Claims / issues Claims concerning AI-generated child sexual abuse material, exploitation and product liability[1]
Status July 7, 2026: first amended class complaint added Stability AI entities. Later developments have not been verified.[1]

Doe 1 v. X.AI Corp. (Case No. 5:26-cv-02246, N.D. Cal.) is a class action lawsuit filed on March 16, 2026, alleging that xAI's Grok AI model generated child sexual abuse material (CSAM) deepfakes using real photographs of minors.[4][5]

Parties

Plaintiffs

  • Jane Doe 1 — minor whose real image was used to generate CSAM via Grok
  • Jane Doe 2 — minor victim
  • Jane Doe 3 — minor victim
  • Putative class: All U.S. persons whose real minor images were altered by Grok into sexualized images or videos[4]

Defendants

  • X.AI Corp.[5]
  • X.AI LLC[5]
  • Stability AI — added as a defendant in the July 8, 2026 amended complaint.[6]

Counsel for plaintiffs: Lieff Cabraser Heimann & Bernstein.[4]

Court

  • Court: U.S. District Court for the Northern District of California (San Jose Division)[5]
  • Judge: Not yet assigned; plaintiffs filed motion to relate case to prior matter for potential same-judge assignment (Docket No. 3)[5]

Claims

  • Masha's Law (18 U.S.C. § 2255) — civil remedy for child sexual exploitation victims[4]
  • Trafficking Victims Protection Act[4]
  • California state law claims — negligence, products liability[5]

Relief sought: Damages, punitive damages, and injunctive relief.[4]

Factual Background

The complaint alleges that Grok's "Spicy Mode" — a feature restricted to paid subscribers — enabled users to upload real photographs of minors and generate photorealistic nude and sexually explicit images and videos.[4] Reports indicate Grok generated approximately 3 million sexualized images and 23,000 apparent child depictions in late 2025–early 2026 before xAI restricted the feature after public exposure.[4][7]

The California Attorney General launched an investigation into xAI/Grok on January 14, 2026, citing nonconsensual deepfake intimate images of women, girls, and children.[8]

One perpetrator who used Grok to generate CSAM was arrested; CSAM was reported to NCMEC.[4]

Procedural History

Date Docket No. Event
March 16, 2026 1 Complaint filed (44 pages; filing fee $405; nature of suit 360 P.I.: Other Personal Injury)[5]
March 16, 2026 3 Motion to relate case to prior matter filed[5]

No answer, motion to dismiss, or other responsive filing by xAI has been reported as of April 2026.[5]

Significance

This is one of the first class action lawsuits alleging that an AI model directly generated CSAM from real minors' images, raising novel questions about:

  • AI company liability for model outputs that violate federal child exploitation laws
  • Adequacy of safety guardrails in commercial AI products
  • Scope of civil remedies under Masha's Law and the TVPA for AI-generated CSAM
  • Product liability theories applied to generative AI
  • xAI v. Bonta — xAI's challenge to California AI Transparency Law (separate proceeding)


July 2026 amended complaint

On July 8, 2026, plaintiffs filed an amended complaint adding two new minor plaintiffs and naming Stability AI as a defendant.[6] The amended complaint alleges that xAI failed to provide user-identifying information in CyberTipline reports and that Stability AI models enabled downstream nudification applications used to generate CSAM.[6] Ars Technica reported that the amendment included allegations that one perpetrator used Grok to create roughly 7,000 sexually explicit images from a photograph of an 11-year-old child.[9]

References