On September 25, 2026, U.S. District Judge Cristina D. Silva of the District of Nevada denied in part OnlyFans' motion to dismiss a federal sex-trafficking lawsuit. Three claims under the Trafficking Victims Protection Reauthorization Act (TVPRA) can now proceed against Fenix International Ltd., the London-based company that operates OnlyFans. The ruling (D. Nev. No. 2:22-cv-01395) got little attention until October 9, when the National Center on Sexual Exploitation (NCOSE), whose law center co-represents the plaintiffs, publicised it. Afterglow refers to the plaintiffs only by the initials NCOSE uses. Everything below comes from the complaint's allegations, which the court has to accept as true at this stage. None of it has been proven.

Why It Matters

This is a motion-to-dismiss ruling, not a liability finding. Still, for creator platforms it is a significant step. It means a fan platform's revenue share on accounts it allegedly should have recognised as third-party-controlled can be the "benefit" a TVPRA beneficiary claim requires, and that Section 230 is no defence to those federal claims. That links directly to the "manager" problem that BBC and Guardian investigations described earlier this year (see *Middlemen, Mid-Cut*). A defendant can now point to two operational red flags the court treated as legally relevant: payout details shared across several creator accounts, and an abuse report the platform didn't act on. For operators, compliance is the lesson. Payout-account deduplication, re-verification when bank details change, and documented escalation of abuse reports are no longer just trust-and-safety best practice. They are litigation exhibits. The ruling also adds legal and reputational overhang at a sensitive time for OnlyFans' ownership, after majority owner Leonid Radvinsky's death in March and the minority-stake sale to Architect Capital in May (see *The King Is Dead*). Expect plaintiff firms to copy the pleading pattern. NCOSE is an anti-pornography advocacy group, and its framing of the platform should be read with that in mind, but the order itself is a public court document.

The two plaintiffs, identified by NCOSE as L.C. and P.H., say reality-TV and social-media personality Brittanya Razavi recruited them in 2020 to make OnlyFans content under her "management" for a promised 50% cut. They allege that Razavi set up accounts in their names using their IDs, locked them out of those accounts, and connected her own bank details so that all of the earnings went to her. They also allege she coerced them into commercial sex acts that were filmed and sold. Their case against the platform is that OnlyFans' terms ban third-party control of accounts, yet it let one creator's bank details be attached to several accounts. It had also received an earlier abuse complaint about Razavi, ran a referral programme that paid 5% of referred creators' earnings, and kept its standard 20% of revenue from the accounts. Razavi, her husband and two affiliated companies are also defendants.

The court's reasoning has three parts. Section 230 did not bar the claims. The judge held that because claims three to five arise under the federal trafficking statutes (18 U.S.C. §§ 1591(a)(2), 1594 and 1595), the platform immunity does not apply to them. The allegations were enough to state a beneficiary claim: OnlyFans allegedly received a specific financial benefit (its 20% share) from a venture it knew about or recklessly disregarded. The case stays in Nevada: the court refused to enforce OnlyFans' UK forum-selection clause, citing a genuine dispute over whether the plaintiffs ever agreed to it, their limited means, and what the order describes as the defendants' lack of presence in the UK. OnlyFans did win some ground. Its U.S. subsidiaries, Fenix Internet LLC and Fenix US Inc., were dismissed. The six state-law claims (fraud, conversion, unjust enrichment, contract and others) were also dismissed against all three Fenix entities, because the federal long-arm jurisdiction the court relied on reaches only the federal claims.

Sources

Update — 2026-10-10

Initial entry — story first created.