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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 October 9, 2026: listed in proposed Grok MDL 3205 centralization request; JPML hearing set for December 3, with presentation/waiver notices due November 2. Transfer request pending.[4]

Doe 1 v. X.AI Corp. (Case No. 5:26-cv-02246, N.D. Cal.) is a proposed class action filed on March 16, 2026, alleging that xAI's Grok AI model generated child sexual abuse material (CSAM) deepfakes using real photographs of minors.[5][6]

Parties

Plaintiffs

The July 7, 2026 first amended complaint names Jane Does 1–5 as pseudonymous plaintiffs and proposes separate xAI and Stability AI classes, with Tennessee subclasses. The plaintiffs allege that real images of them as minors were altered to produce child sexual abuse material.[1]

Defendants

The amended complaint names X.AI Corp., X.AI LLC, X.AI Holdings LLC, Stability AI U.S. Services Corporation and Stability AI, Inc.[1]

Counsel for plaintiffs: Lieff Cabraser Heimann & Bernstein.[5]

Court

  • Court: U.S. District Court for the Northern District of California (San Jose Division)[6]
  • Judge: P. Casey Pitts (PCP designation on the July 7, 2026 amended complaint).[1][3]

Claims

  • Masha's Law (18 U.S.C. § 2255) — civil remedy for child sexual exploitation victims[5]
  • Trafficking Victims Protection Act[5]
  • California state law claims — negligence, products liability[6]

Relief sought: Damages, punitive damages, and injunctive relief.[5]

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.[5] 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.[5][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.[5]

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)[6]
March 16, 2026 3 Motion to relate case to prior matter filed[6]

No answer, motion to dismiss, or other responsive filing by xAI has been reported as of April 2026.[6]

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

The first amended complaint was filed July 7, 2026 as ECF 26. It names five pseudonymous plaintiffs and adds Stability AI U.S. Services Corporation and Stability AI, Inc. as defendants.[1] 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.[1] 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]

Proposed multidistrict proceedings

The JPML’s October 9, 2026 hearing-session order lists this action among thirteen cases in proposed MDL 3205, In re X.AI/Grok Artificial Intelligence Minor Sexual Exploitation Litigation. Plaintiffs request coordinated pretrial proceedings in the Western District of Arkansas; eight listed actions are in that district and five are in the Northern District of California. The panel designated the matter for oral argument at its December 3 session in New Orleans. Presentation or waiver notices are due November 2. The centralization request remains pending.[4]

References

  1. ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 1.12 First amended complaint, ECF 26, filed July 7, 2026 (68 pages); complete body reviewed October 10, 2026
  2. ↑ Court filing / case record, reviewed September 7, 2026
  3. ↑ 3.0 3.1 Case source, reviewed September 7, 2026
  4. ↑ 4.0 4.1 JPML, October 9, 2026 hearing-session order and schedule (13 pages), pp. 1–3 and 8–9; general order mirrored in the Retailer Tariff docket, listing proposed Grok MDL 3205. Complete body reviewed October 10, 2026.
  5. ↑ 5.0 5.1 5.2 5.3 5.4 5.5 5.6 5.7 Lieff Cabraser, "LCHB Files Class Action o/b/o Minor Victims Alleging xAI's Grok Generated and Profited from AI Sexual Exploitation Images and Videos," March 2026
  6. ↑ 6.0 6.1 6.2 6.3 6.4 6.5 Prokopiev Law, "Minors File Class Action Against xAI Over Grok CSAM Deepfakes in California," March 2026
  7. ↑ Cybernews, "Teens sue xAI: Grok AI-generated child porn," March 2026
  8. ↑ California AG Press Release, January 14, 2026
  9. ↑ Ars Technica, "Lawsuit: Man used Grok to make 7K sex images of stepdaughter, then shot himself" (July 8, 2026).
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