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State of New York
Court of Appeals
Albany, New York
October 14, 2009
No. 178 Matter of Goldstein v New York State Urban Development Corporation

"This proceeding challenges the use of eminent domain by the Empire State Development Corporation (ESDC) to take property on the site of the proposed Atlan
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Class Action Over Deepfake Child Abuse Expands To SpaceXAI, Stability AI

An amended class action filed July 7, 2026, in the U.S. District Court for the Northern District of California added two Jane Doe plaintiffs and named SpaceXAI and Stability AI as defendants over alleged deepfake child sex abuse.[1]

The complaint says perpetrators used the companies' AI models to alter underage photos into explicit child sexual-abuse images and videos.[1] It says a stepfather used Grok to generate about 7,000 explicit images and videos from a single childhood photograph and traded them online.[1] Plaintiffs also accuse SpaceXAI of failing to include full information in legally required reports to the National Center for Missing and Exploited Children.[1]

On March 16, 2026, three Tennessee teenagers originally sued xAI in the same court, alleging Grok was used to make explicit deepfakes from real childhood photos.[1] That March complaint pressed claims under Masha's Law, the Trafficking Victims Protection Act and California law for a nationwide class of minors seeking damages and injunctions.[1]

An earlier January 2026 suit aimed at adults raised similar allegations about Grok's abilities.[1] Observers on social media urged tougher safeguards and flagged the expansion to Stability AI as evidence the problem is not limited to a single company.

The mainstream summary does not mention the alarming scale of the issue, as highlighted by the National Center for Missing & Exploited Children, which reported over 1.5 million CyberTipline reports related to generative AI and child sexual exploitation in 2025 alone. Among these, more than 182,000 reports specifically involved offenders generating or attempting to generate AI CSAM, indicating a significant and troubling trend that extends beyond the allegations against SpaceXAI and Stability AI. This context underscores the urgency of the legal actions being taken, as the summary frames the class action primarily around the allegations without addressing the broader implications of AI's role in facilitating such exploitation. Additionally, the summary does not explore the legal framework under which these companies operate, particularly the limitations of U.S. law regarding reporting requirements for electronic service providers, which do not mandate proactive scanning for CSAM. This gap suggests that while companies like SpaceXAI and Stability AI are being held accountable, the existing legal structures may not adequately support the prevention of such abuses in the first place.[2][3]

  1. NPR
  2. NCMEC
  3. Cornell Law School
AI Regulation and Liability Child Exploitation and Online Safety Courts and Legal Actions
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๐Ÿ“Š Relevant Data

In 2025, NCMEC received more than 1.5 million CyberTipline reports with a generative AI nexus to child sexual exploitation; excluding over 1.1 million Amazon reports of known CSAM in training datasets, more than 182,000 reports involved offenders possessing, generating, or attempting to generate AI CSAM, and since 2023 more than 158,000 images and videos have been categorized as GAI CSAM with over 275 victims identified.

CyberTipline Data โ€” National Center for Missing & Exploited Children

Under 18 U.S.C. ยง 2258A, U.S. electronic service providers must report apparent violations involving child pornography or CSAM to NCMEC's CyberTipline as soon as reasonably possible after obtaining actual knowledge, including provider contact information, but the statute does not require proactive scanning or mandate inclusion of specific images or IP addresses beyond facts known to the provider.

18 U.S. Code ยง 2258A - Reporting requirements of providers โ€” U.S. Code via Cornell Law School

๐Ÿ“Œ Key Facts

  • On Tuesday, July 7, 2026, an amended class action complaint added two new Jane Doe plaintiffs from Wyoming and Wisconsin to a suit originally filed by three Tennessee teenagers.
  • The amended complaint newly names Stability AI, maker of Stable Diffusion, as a defendant alongside Elon Musk's SpaceXAI (formerly xAI).
  • Plaintiffs allege perpetrators used the companies' AI models to alter underage photos into explicit deepfake child sexual abuse material and that SpaceXAI failed to provide full information in mandated reports to NCMEC.
  • For Jane Doe 4, the suit claims her stepfather used Grok to generate about 7,000 explicit images and videos based on a single childhood photograph and traded those images online.

๐Ÿ“ฐ Source Timeline (1)

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