Flora

I. BACKGROUND

1 Prisma’s app, Lensa, allows users to upload photos to edit and retouch. Compl. ¶ 1. 2 In late 2022, Lensa’s popularity skyrocketed with the launch of its “magic avatar” 3 feature—using AI to turn user’s photos into artistic or cartoonish depictions of their 4 likeness, applying different styles such as “cosmic,” “anime,” or “fairy princess.” 5 Id. ¶¶ 14, 17. Criticism from many corners soon followed: Artists contended that Lensa 6 employed AI trained on copyrighted images created by humans who received no 7 compensation for their contributions to the images generated by Lensa, id. ¶ 25; users 8 found that the app would create sexualized images from non-sexual, fully-clothed photos, 9 id. ¶ 26; and, the subject of this lawsuit, advocates concerned with Lensa users’ privacy 10 argued that Prisma was capturing and retaining “the facial geometry of the subjects of the 11 images” uploaded to Lensa, without their subjects’ consent. Id. ¶ 27. 12 When a user downloads the Lensa app, they are required to agree to Lensa’s Terms 13 of Use and Privacy Policy to use it. Compl. ¶ 19. Each of the Plaintiffs allege that they 14 “received disclosure” of Lensa’s Privacy…