PlaintiffNina Agdal (“‘Plaintiff’ or “Agdal”), by and through undersigned counsel,files this Verified Complaint and Demandfor Jury Trial against Defendant Dillon Danis (“Defendant” or “Danis”), in which she seeks to hold him accountable for unlawfully posting a nonconsensual, sexually explicit photograph of her on the internet without her consent, in violation of both federal and state law.

In one instance that givesrise to the claimsasserted in this Complaint, Danis obtained and posted on his X account, without authorization, a sexually explicit photograph of Plaintiff that was taken and shared, without her consent, during a romantic encounter with a non-party more than a decade ago.

Pursuant to 15 U.S.C. § 6851(b)(3)(A)(i), Plaintiff also is entitled to recover from Defendant the actual damagesshe has sustained as a result of Defendant’s conduct, in an amount to be determinedattrial, but not less than $150,000 per violation of the statute, in addition to her reasonable attorney’s fees and other litigation costs incurred in bringing this action.

Pursuant to 15 U.S.C. § 6851(b)(3)(A)Q), Plaintiff also is entitled to recover from Defendant the actual damagesshehassustained as a result of Defendant’s conduct, in an amount to be determinedattrial, but not less than $150,000 per violation of the statute, in addition to her reasonable attorney’s fees and otherlitigation costs incurred in bringing this action.

An award of reasonable attorney’s fees and costs; A temporary restraining order, preliminary injunction, and permanentinjunction pursuant to 15 U.S.C. § 6851(b)(3)(@i) and N.J. Stat. § 2A:58D-1(c)(4) enjoining Defendantandall personsin active concert or participation with him from continuing to disclose sexually explicit photographsof Plaintiff without her consent and from disclosing materials depicting or portraying Plaintiff that he knowsor has reason to believe were never meantto be shared publicly or were obtained without consent, through the hacking of any ofPlaintiff’s accounts or devices, or through any other illegal unauthorized means; and An award of such furtherrelief that this Court deemsjust and proper.