San Francisco City Attorney David Chiu sent cease-and-desist letters this week to Apple and Google, demanding the removal of 13 AI-powered "nudification" apps from their respective app stores1,2.
The letters warned that the app stores were violating California laws that prohibit supporting services used to create deepfake pornography. The City Attorney's Office said the tech companies were profiting from "face-swap" apps that are overwhelmingly used to target women and girls.
The 13 apps in question use AI to transform ordinary photos of real people into explicit images. The tools enable users to remove clothing from images, alter a person's features, place individuals in sexualized positions, and swap victims' faces onto other people's naked bodies.
ANALYSIS The cease-and-desist letters represent a municipal enforcement action that frames Apple and Google not as passive distributors but as active participants in enabling nonconsensual deepfake imagery — a legal theory that, if tested in court, would place platform liability squarely on app store operators rather than solely on app developers.
By targeting the distribution layer rather than individual app makers, the City Attorney's Office is pursuing a chokepoint strategy: removing these tools from the two dominant mobile app marketplaces would sharply limit their accessibility to casual users, even if the underlying models remain available through other channels.