Last May, we celebrated a phenomenal victory: the signing into law of the TAKE IT DOWN Act.
The TAKE IT DOWN Act finally made it a federal crime to publish or distribute sexual images of a person without their consent (i.e. image-based sexual abuse, or “IBSA”). Importantly, it also required tech companies to remove IBSA within 48 hours of receiving notice from a survivor.
NCOSE staff were honored to be personally invited to the signing of the TAKE IT DOWN Act at the Whitehouse, in recognition of our role advocating for its passage.
Now, as we know, a law is only as good as its enforcement. So, a year later, the question is: is the TAKE IT DOWN Act being enforced?
We are thrilled to say that the answer is: YES!
First Domain Seizures Under the TAKE IT DOWN Act
The TAKE IT DOWN Act’s requirements for tech platforms were set to go into effect one year after signing, on May 19, 2026. Leading up to this deadline, NCOSE delivered a briefing to the Federal Trade Commission (FTC) on the importance of enforcing the Act. This briefing was provided by NCOSE’s Public Policy Team and our Survivor Services Coordinator, Teresa J. Helm.
Now, we celebrate the first ever domain seizures under the TAKE IT DOWN Act! The domains CFAKE.com and SOCFAKE.com were seized by the Department of Justice and Department of Homeland Security, for disseminating AI-generated IBSA (commonly called “deepfake pornography).
This is an important milestone victory!
Not a Fantasy
FTC Sent Letters to Major Tech Companies & Nudifying Apps
We hope that these first two domain seizures only the beginning and that we will see strong, ongoing enforcement under which numerous tech companies are held accountable for their role in survivors’ abuse.
We are encouraged in this hope by the FTC having sent letters to numerous major tech companies, warning them of their duties to comply with the TAKE IT DOWN Act. These letters were sent to Meta, Apple, Alphabet (parent company of Google), Microsoft, X (formerly “Twitter), Reddit, Snapchat, TikTok, Discord, Reddit, Amazon, Pinterest, Automattic, Bumble, Match Group, and SmugMug.
Further, the FTC sent letters to 12 companies that offer “nudifying” technology—i.e. heinous abuse tools that digitally strip the clothing off images of people without their consent. Those letters warned the companies that they appeared to be in violation of the TAKE IT DOWN Act and would face consequences if they did not “immediately come into compliance with the law.”
The FTC also launched a new website, outlining how individuals can report platforms for non-compliance with the TAKE IT DOWN Act, and pointing survivors to resources.
These actions were taken by the FTC a few weeks after NCOSE’s briefing, shortly before the TAKE IT DOWN Acts’ requirements for platforms went into effect.
First Man Convicted for Violating the TAKE IT DOWN Act
In April, we also saw the first conviction of an individual for violating the TAKE IT DOWN Act’s criminal provisions. While the requirements for tech companies went into effect a year after the TAKE IT DOWN Act was signed into law, the Act’s criminal provisions went into effect immediately.
In April, a 37-year-old man named James Strahler pled guilty to the “publication of digital forgeries” — i.e. AI-generated IBSA, made a federal crime under the TAKE IT DOWN Act. Strahler had installed more than 24 AI platforms and more than 100 AI web-based models on his phone. He also engaged in harassment campaigns against his victims, via phone calls, voice mails, text messages, and online posts.
We are grateful that the TAKE IT DOWN Act allows perpetrators to be held accountable for the crime of IBSA, which causes so much harm to survivors.
What’s the Next Step?
The TAKE IT DOWN Act is law, and enforcement is moving forward. So, what’s next?
NCOSE is advocating for a bill that is complementary to the TAKE IT DOWN Act, addressing the problem of IBSA from another angle. This bill is the DEFIANCE Act.
THE DEFIANCE Act establishes a civil cause of action for survivors to hold perpetrators accountable for distributing or threatening to distribute AI-generated IBSA. In other words, while the TAKE IT DOWN Act establishes criminal provisions and requirements for tech companies, the DEFIANCE Act allows survivors to sue their perpetrators.
Contact your representatives today, urging them to support the DEFIANCE Act!
