2025 Dirty Dozen List Reveals 12 Survivors Prevented from Justice Due to Big Tech’s Liability Shield: Section 230

WASHINGTON, DC (April 3, 2025) – The National Center on Sexual Exploitation (NCOSE) has named Section 230 of the Communications Decency Act as the primary target of its 2025 Dirty Dozen List of mainstream contributors to sexual exploitation. This year, instead of naming 12 companies to the Dirty Dozen List, NCOSE is highlighting 12 survivors who were silenced by Section 230, Big Tech’s liability shield that has enabled their abuse.

“Online sexual abuse is rising exponentially but Section 230 of the Communications Decency Act is preventing survivors from receiving justice. Laws should protect those who have experienced horrific crimes, but instead, Section 230 gives online platforms broad immunity for crimes committed on their sites. This must end,” said Haley McNamara, Senior Vice President of Strategic Initiatives and Programs, National Center on Sexual Exploitation. “Section 230 is the greatest enabler of online sexual exploitation.” 

“Our 2025 Dirty Dozen List was re-imagined this year to highlight 12 survivors who have been prevented from receiving justice for the crimes perpetrated on them because Section 230 exists. Some of these survivors were contacted by predators over tech platforms; some were groomed and trafficked online; some had their child sexual abuse posted online. All of these survivors have sought justice without success because Section 230 is standing in the way,” McNamara said.

Dani Pinter, Senior Vice President and Director of the Law Center for the National Center on Sexual Exploitation, said, “Section 230 has become a legal loophole that has been interpreted to broadly grant online platforms immunity from liability, even when they knowingly, recklessly, or negligently enable child sexual abuse, sex trafficking, and other harms. The only solution is for Congress to repeal Section 230 to hold Big Tech accountable, to give survivors access to justice, and to prevent online sexual abuse and exploitation at mass-scale.”

The following are 12 condensed survivor stories and their lawsuits against tech platforms. Their full stories can be found at www.DirtyDozenList.com.

1. At just eleven years old, she was placed in a chatroom with a predator by Omegle. She was threatened, exploited and abused despite pleas for it to stop. M.H. v. Omegle.com, LLC, 122 F.4th 1266 (11th Cir. 2024).
2. John stared at the screen, his heart sinking as he saw the explicit images of himself as a 13-year-old circulating on Twitter, a platform that dismissed his reports for help with the chilling message, “We’ve reviewed the content, and didn’t find a violation of our policies, so no action will be taken at this time.” Doe #1 v. Twitter, Inc., No. 22-15103, No. 22-15104, 2023 WL 3220912, at *1 (9th Cir. May 3, 2023).
3. At sixteen, Jane Doe felt fear and betrayal when her ex-boyfriend repeatedly shared explicit images of her on Reddit without consent. It got worse when she reported the images to Reddit, only for them to resurface again and again on the platform. Does 1-6 v. Reddit, Inc., 51 F.4th 1137 (9th Cir. 2022).
4. As a child she joined Kik, an online chat service where she was pressured by adult men into sharing explicit images—a situation facilitated by Kik’s lack of protective policies and warnings. Doe v. Kik Interactive, 482 F. Supp. 3d 1242 (S.D. Fla. 2020).
5. She was sex trafficked by a stranger she met on Instagram over the course of one year. He was criminally convicted and sentenced to 40 years, but Instagram – the platform that connected them – evades liability. Doe (K.B.) v. Backpage.com, LLC, 2025 WL 719080, Case No. 23-cv-02387-RFL (N.D. Cal. Mar. 3, 2025).
6. She was sex trafficked as a child, and her abuses were recorded and uploaded to a pornography website. Despite the videos being reported as child sexual abuse material, the website kept it up and profited. Doe v. WebGroup Czech Republic, A.S., No. 2:21-cv-02428, 2024 WL 3533426, at *1 (C.D. Cal. July 24, 2024).
7. Jane Doe was sex trafficked as a minor and repeatedly raped over 1,000 times due to ads posted on Backpage’s “Escorts” section. She was turned away from the courts because of CDA 230.  Doe No. 1 v. Backpage.com, LLC, 817 F.3d 12 (1st Cir. 2016).
8. She was 12. A convicted predator used Snapchat to groom her into producing exploitive images (CSAM) through the app, and even traveled to her home. Snapchat failed to detect or remove the CSAM, which could have prevented her further abuse.  L.W. v. Snap Inc., 675 F. Supp. 3d 1087 (S.D. Cal. 2023).
9. J.B., who was sex trafficked as a minor, was repeatedly raped in hotel rooms arranged through Craigslist, where her trafficker advertised her. Craigslist knew there was sex trafficking on its site but let it fester. J.B. v. Craigslist, Inc., No. 22-15290, 2023 WL 3220913, at *1 (9th Cir. May 3, 2023).
10. He was 15 and downloaded what he thought was a safe dating app, only for it to become the connection point between predators who raped him.  Doe v. Grindr Inc., 128 F.4th 1148 (9th Cir. 2025).
11. He was an orphan who, at the age of fifteen, was groomed by his science teacher via Snapchat, which escalated into him being sexually assaulted and overdosing on drugs. Doe v. Snap, Inc., No. H-22-00590, 2022 WL 2528615, at *1 (S.D. Tex. July 7, 2022).
12. She was 15 and met a stranger with friends in common on Facebook—before long he used the messenger service to groom and exploit her, leading to her being trafficked, raped, and abused. Doe v. Facebook, Inc., 625 S.W. 3d 80 (Tex. 2021).  

The Dirty Dozen List is an annual campaign that historically called out twelve mainstream entities that facilitate, enable, and profit from sexual exploitation. Since 2013, it has driven major policy changes at Google, Netflix, TikTok, Hilton, Verizon, Walmart, the U.S. Department of Defense, and more. Learn more and take action at www.DirtyDozenList.com.

About National Center on Sexual Exploitation (NCOSE)
Founded in 1962, the National Center on Sexual Exploitation (NCOSE) is the leading national non-profit organization exposing the links between all forms of sexual exploitation such as child sexual abuse, prostitution, sex trafficking and the public health harms of pornography.