A class action lawsuit filed by victims of child sexual abuse material (CSAM) accuses xAI of training Grok’s synthetic deepfake “nudify” capabilities on real images and videos of child abuse.
The lawsuit, filed Wednesday in the U.S. District Court for the Northern District of California, names Jane Doe 1 and other anonymous individuals as plaintiffs, calling Doe “an identified 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, for the explicit purpose of making CSAM material to distribute online. Media depicting the victim has circulated online since at least the early 2000’s, with, according to the lawsuit “hundreds of thousands of files” being included in law enforcement submissions to the National Center for Missing & Exploited Children (NCMEC).
As part of the FBI’s program, she still receives updates when images related to her abuse surface online, and the suit alleges her material has “well known hash-values” that have shown up in deepfakes created with Grok and spread on X.
“CSAM depicting Plaintiff has been found on xAI as part of investigative reporting, takedown request efforts, and criminal investigations, arrests, and convictions for violations of state and federal laws,” the lawsuit states. It also claims “xAI, using Grok, has generated images depicting Plaintiff and the child pornography series in which she is the victim.”
The lawsuit cites “Masha’s Law” as the basis for its allegations. That law, passed in 2018, protects civil legal remedies to victims of child pornography and online exploitation.
According to an analysis by the Center for Countering Digital Hate, during an 11-day period between Dec. 2025 and Jan. 2026, Grok created more than 3 million sexualized images, at least 23,000 of which appeared to depict children.
On Jan. 14, after the period tracked by the center, Musk wrote on X that he was “not aware of any naked underage images of Grok. Literally zero.” Must 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 it’s deepfake capabilities directly into X, effectively creating an instantaneous CSAM generation and distribution system for the internet.