Jane Doe and three other women sued defendant xAI alleging that the company’s Grok chatbot generated non-consensual nude and sexually explicit images of them. Plaintiffs claimed the deepfakes caused severe emotional distress and posed risks to their reputations and employment.

All four plaintiffs jointly sought to proceed in the lawsuit under pseudonyms to avoid retaliatory harassment. Defendant opposed the request generally, arguing the case did not involve a compelling privacy interest, that pseudonymity would prejudice it by complicating witness interviews and increasing costs, and that the public had an interest in knowing who the plaintiffs were. Defendant also filed a separate motion specifically targeting South Carolina Roe, one of the four plaintiffs, seeking to compel her to use her real name.

The court granted plaintiffs’ motion to proceed pseudonymously and denied defendant’s opposition and its targeted motion to compel South Carolina Roe’s identity.

Necessary to protect against retaliation

The court found pseudonymity necessary to protect plaintiffs against retaliation. The threatened harm was severe: the deepfakes could cause emotional distress and damage to reputation and employment. Plaintiffs’ fears of retaliation were reasonable, as public critics of Grok’s deepfake capability had commonly been subjected to harassment campaigns. Plaintiffs were particularly vulnerable because defendant’s technology could generate additional deepfakes if their identities became known.

Defendant failed to demonstrate sufficient prejudice from pseudonymity. Defendant could still identify plaintiffs during discovery and at trial, since pseudonymity applied only to public filings. Defendant did not establish that pseudonymity would materially increase litigation costs. The court also indicated it could mitigate any jury bias through jury instructions and trial procedures, or by requiring plaintiffs to use their full names at trial.

Sensitive and personal nature of the images

The court also granted pseudonymity based on the sensitive and highly personal nature of the claims. Disclosure of plaintiffs’ identities could lead third parties to locate and view the very images at the heart of plaintiffs’ claims, substantially compounding the harm.

Jane Doe v. X.AI Corp., 2026 WL 2199524 (N.D. Cal., July 30, 2026)