WESTFIELD —A Westfield High School student whose image was digitally altered and disseminated without her permission by one of her male peers last year is seeking punitive damages in federal court.

Earlier this month, the 15-yearold student, who was granted permission to use the anonymous moniker of Jane Doe in all legal documents to protect her identity, and her parents filed a verified complaint in United States District Court against one of her classmates, an underage boy identified in official records only as K.G.

“Jane Doe is one of many girls and women who have been and will continue to be exploited, abused, and victimized by nonconsensual pornography generated through artificial intelligence (AI),” the complaint, filed on February 2, states. “Specifically, Jane Doe and several other minor girls were exploited and violated when the Defendant used an AI application or website to create, obtain, possess, view, save, disclose and disseminate nonconsensual nude images of Jane Doe and other minor girls in violation of federal and state law.”

In October of last year, a number of local parents were notified by the school district that their daughters had been identified as victims of a potential AI “deepfake,” a term used to describe harmful, digitally-altered images. According to the “Jane Doe” complaint, the defendant stole clothed images of the girls, all of whom were underage at the time, from various social media sites and then manipulated those images to make it seem as though the girls had been posing naked. The doctored photos were then shared with other students at Westfield High School.

“The photos are lasting images depicting Jane Doe and the other girls, all identifiable minors, seemingly posing nude in a sexually explicit manner,” the complaint alleges. “Victims of nonconsensual and child pornography such as Jane Doe are left to cope with the psychological impacts of knowing that images such as the nude photos almost inevitably make their way onto the Internet where they are retransmitted to others, such as pedophiles and traffickers, resulting in a sense of hopelessness and perpetual fear.”

The complaint goes on to suggest that the student, K.G., likely used a certain type of photo editing software known as (an app that can be easily downloaded to Android and Apple devices which promises in its description to “undress any photo with AI for free” and proclaims that users can “strip your dream girl naked” with the simple tap of a button) to modify the images.

In January of this year, the federal complaint states, the affected students and their families learned that charges would not be filed against K.G. at the local level due to the fact that “information gathered by [Westfield High School] could not be used to support the investigation” and because “potential witnesses failed to cooperate with, speak to, or provide access to their electronic devices to law enforcement.”

“Jane Doe” and her family are seeking actual or liquidated damages in the amount of $150,000 for each time that the doctored images were shared as well as their attorney’s fees and any other costs incurred throughout the litigation proceedings.

Last week, a United States district judge ordered that “Jane Doe” be granted a temporary restraining order to prevent K.G. from “viewing, accessing, displaying, disclosing, sharing or transmitting” any nude images and forbid him from revealing her identity or those of her parents and immediate family members. K.G. also was ordered not to “delete, destroy, secrete or modify” any data on his smart phone, computer or other electronic device.

Last year, State Senator Jon Bramick agreed to co-sponsor legislation that would prohibit deepfake pornography and impose criminal and civil penalties for nonconsensual disclosure after speaking with several of the Westfield girls who had been impacted by the incident and their parents. Similar legislation was introduced at the federal level earlier this year by Congressman Tom Kean, Jr., who worked with Westfield High School student Francesca Mani to draft the bill.

“As a father, I am deeply disturbed by how effortlessly this kind of technology can be used in an explicit nature and minors can easily be the victims,” said Congressman Kean via a press release in January. “We live in a highly advanced technological world that is ever-changing and proper oversight is necessary.”