(...) The Complaint details a scheme where the named defendants, acting on behalf of Passes, recruited young women, that they knew were minors, to create pornography before they reached the age of 18, and to distribute that child pornography on the Passes platform to paying subscribers, both before and after the subject became of age.
The Complaint further details how Passes and the individual defendants took to disguise their scheme and to cover their tracks once their sexual exploitation of minor women was revealed, including changing its public representations about the compliance policy just two days ago, and also about its relationship with Celestin.