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ARTICLE · 22 JUNE 2026

The TAKE IT DOWN Act Is Now In Full Effect: What Platforms Need To Know

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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Finnegan, Henderson, Farabow, Garrett & Dunner LLP

Finnegan, Henderson, Farabow, Garrett & Dunner LLP

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The TAKE IT DOWN Act establishes a comprehensive legal framework targeting nonconsensual intimate imagery, including AI-generated content, by creating criminal penalties for knowing publication and imposing strict compliance obligations...

United StatesGovernment, Public Sector
Lynn Parker Dupree
Lynn Parker Dupree
Lauren Hanlon
Lauren Hanlon
Matthew Laub
Matthew Laub
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The Highlights

  • The Act Establishes Criminal Liability for Knowing Publication of NCII, Including AI-Generated Content: The Act establishes criminal liability for the knowing publication of nonconsensual intimate images, including AI-generated or otherwise synthetic content.

  • Notice-and-Removal Framework Imposes 48-Hour Deadline for Platform Compliance: Covered platforms are required to implement and comply with a notice-and-removal framework, including a 48-hour timeline for responding to valid requests.

  • FTC Enforcement Commences, Creating Significant Civil Penalty Exposure for Noncompliance: The Federal Trade Commission commenced enforcement on May 19, 2026, with significant civil penalty exposure for noncompliance.

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