San Francisco’s Nudify App Crackdown Runs on a Law Chiu Wrote

San Francisco’s city attorney has given Apple and Google 28 days to explain why they should not face civil penalties for hosting apps that turn ordinary photos into fake nude images. David Chiu’s office sent cease and desist letters naming 13 so called nudify apps, eight sold through Apple’s App Store and five through Google Play. Both letters lean on a California statute that Chiu’s own office helped write.

That last detail separates this action from a routine takedown notice. Assembly Bill 621 lets prosecutors sue not just the people who build nudify tools but anyone who “knowingly facilitates or recklessly aids or abets” them, language written with payment processors in mind. Apple and Google take a cut of every subscription these apps sell.

Eight Apps on iOS, Five on Android, One Shared Deadline

The 13 apps market themselves as ordinary face swap or photo editing tools. One, downloaded more than a million times according to the letters, advertises AI styles with names like “bikini queen curvy,” “calm busty” and “cinematic intimacy,” paired with sexualized images of women on its own promotional site.

Apple’s response accounts for most, but not all, of the eight apps named on its store. The company says it removed three and is terminating those developer accounts, and is separately pressing four more to fix policy violations. That leaves one of the eight unaddressed in Apple’s own public statement.

Google’s answer was cleaner. A spokesperson said all five Play Store apps named in Chiu’s letter have been suspended, part of what the company describes as a broader sweep of “hundreds of violating apps” and a block on search terms including “nudify.”

Neither company has said how much revenue passed through these apps or how many people downloaded them. Chiu told Wired the two firms had likely earned “millions of dollars in fees” from nudify subscriptions over the past year alone.

A Law Built to Catch the Payment Trail

California first created civil liability for nonconsensual sexual deepfakes back in 2019, through a bill known as AB 602. It let victims sue the people who made or knowingly shared the images. It said almost nothing about the companies that kept those operations running.

AB 621 closed that gap. Signed by the governor in October 2025 and in effect since the start of this year, it extends liability to anyone who knowingly facilitates or recklessly aids deepfake conduct, not just the creator. Legislative analysts working on the bill wrote plainly that going after the sites themselves does little good when they are “frequently operated by transient, fictitious entities located overseas,” so the statute instead reaches the businesses that keep them funded and running.

Official committee records show the bill is sponsored by San Francisco City Attorney David Chiu himself, alongside groups including the American Association of University Women of California. TechNet, the tech industry’s own trade group, opposed it.

The law’s penalties scale by who is doing the suing:

• $1,500 to $50,000 in statutory damages for an individual victim in a non-malicious case
• Up to $250,000 when the conduct is found malicious
• $25,000 to $50,000 per violation when a public prosecutor, such as Chiu, brings the case instead

The statute also builds in a 30 day cure window once a facilitator is put on notice, almost identical to the 28 days Chiu gave Apple and Google this month.

San Francisco Already Tested This Playbook Once

Chiu’s app store letters are not his first swing at this problem. In August 2024, his office sued the operators of 16 of the internet’s most visited AI “undressing” websites, sites his investigators said had drawn more than 200 million visits in just six months.

Those defendants were scattered across Estonia, the United Kingdom and elsewhere, which made them hard to pin down. By mid-2025, the office reported progress anyway. Ten of the 16 sites had gone offline or become inaccessible in California, with one operator, Briver LLC, reaching an initial settlement.

“While our lawsuit has so far led to an initial settlement as well as shut down 10 websites that exploit women and children, we won’t stop until all owners are held accountable and blocked from opening similar sites,” Chiu said at the time.

The website case left a lesson Chiu’s office carried into Sacramento: chasing anonymous offshore operators works slowly. Chasing the payment processors they depend on does not require finding them at all.

1. August 2024: Chiu sues 16 deepfake “undressing” websites tied to more than 200 million visits.
2. October 2025: Governor signs AB 621, extending civil liability to facilitators like payment processors.
3. January 2026: The Tech Transparency Project’s first report counts dozens of nudify apps on Apple and Google’s stores.
4. April 2026: A follow up TTP report finds the apps still there, some actively promoted through search and ads.
5. May 2026: A 54 group coalition presses state attorneys general to act; Minnesota signs the country’s first nudification ban.
6. July 2026: Chiu sends cease and desist letters to Apple and Google, citing both prior TTP reports as notice.

How Many Nudify Apps Are Still Out There?

Chiu’s letters name just 13 apps, a small slice of what watchdogs have already documented. The Tech Transparency Project, a research arm of the nonprofit Campaign for Accountability, published two reports this year finding dozens of nudify apps across both stores, with combined downloads reaching into the hundreds of millions.

• 483 million combined downloads TTP tied to nudify apps found across both app stores
• $122 million in estimated lifetime revenue those apps generated
• 31 apps rated suitable for “Everyone,” meaning children could download them freely
• 13 apps actually named in Chiu’s letters this month

TTP’s second report found the same apps still listed months after the companies’ own bans supposedly applied, and said search and autocomplete tools on both stores were steering users toward more of them.

We didn’t think after the first report that we would see this as a problem again.

Katie Paul, director of the Tech Transparency Project, said that in a statement, adding that the second review found conditions “just as bad, if not worse.” Apple and Google, she said, market their stores as trusted and safe in ways that are “not what is playing out in reality.”

A Coalition Already Asked State Regulators to Act

Two months before Chiu’s letters went out, a bipartisan coalition of 54 organizations led by the gender justice group UltraViolet pushed a different set of officials to move first. Their target was the National Association of Attorneys General, gathering for its spring consumer protection conference in May.

Deepfake abuse was not on that conference’s agenda. The coalition’s letter argued state attorneys general have more capacity to move quickly on this than federal regulators do, and urged them to hold app stores accountable for distributing nudification tools.

One state acted on its own that same month. Minnesota Governor Tim Walz signed the nation’s first outright ban on nudification technology on May 7, a criminal approach rather than California’s civil one. San Francisco’s letters, weeks later, came from a city law office rather than a state capitol.

Outside the App Stores, Little Changes

Chiu’s letters target distribution and payment processing inside two app stores. They say nothing about the underlying AI models that power nudify features, or the standalone websites offering the same service outside any app store’s reach, the exact targets of his 2024 lawsuit, which is still proceeding against the operators who have not settled.

Developers building photo editing tools with generative AI features on iOS or Android face a narrower path now. Apple’s guidelines already bar content that sexualizes real people without consent, and Google has blocked search terms tied to nudification across Play. Apps that generate edited images of identifiable people without safeguards sit at higher risk of removal on both platforms.

Users who paid for any of the affected apps may lose access once developer accounts are shut down, and neither company has published refund guidance. Anyone who spots a similar app can flag it directly, through Apple’s own tool for reporting abusive apps or Android’s “Flag as inappropriate” option under a listing’s developer contact section, citing the non-consensual imagery policy specifically.

Neither Apple nor Google has said whether it will review apps beyond the 13 Chiu named. The clock on those 13 runs out in mid-August.

Frequently Asked Questions

Can a nudify app victim in California sue Apple or Google directly?

Yes. Assembly Bill 621 gives any depicted individual, not just a city or state prosecutor, a private right of action against anyone who knowingly facilitates a deepfake pornography service. A victim does not have to wait for San Francisco or the state to bring a case first.

How does Minnesota’s nudify law compare to California’s approach?

Minnesota took a different route. Governor Tim Walz signed the nation’s first outright ban on nudification technology on May 7, 2026, making the tools themselves illegal to offer. California instead relies on civil liability, letting victims and prosecutors sue creators and facilitators for damages rather than banning the software outright.

What should I do if I already paid for a nudify app that gets removed?

Neither company has published refund guidance specific to these apps. Apple’s standard channel for disputing an App Store charge runs through its own reporting tool, while Google Play purchases can be disputed through the Play Store’s order history and existing refund process.

Has California targeted AI companies beyond app stores over deepfakes?

Yes. California’s attorney general separately sent a cease and desist notice to X over sexually explicit deepfakes generated by its Grok chatbot, part of a wider push that also includes the 54 group coalition pressing state attorneys general nationwide to treat nudification tools as an enforcement priority.

Disclaimer: This article is for general information only, does not constitute legal advice, and California civil code details may change; anyone considering legal action under these statutes should consult a licensed attorney.