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Why is the DMCA even relevant here? Who's the copyright holder?

Not founders, so I can only provide my interpretation. Some states have revenge porn laws, some providers will remove content that is non consensual and of an adult nature if notified, so I presume they’re using DMCA as a proxy for all of the above. “Takedown requests” is probably better verbiage.

Depending on the circumstances, who the copyright holder is is immaterial.

Also, IANAL! Not legal advice!

They are considered unauthorized models.

Can you elaborate? I can't find anything in DMCA that says the subject of the image has copyright of the image.

If you are going to commercialize an image like put ads on your site or charge a paywall to see content all the models featured in the image must have signed model release forms. This isn’t us opining about how DMCA should work, this is just precedent.

Try to run a marketing campaign for any brand without getting model release forms for everyone depicted and you’ll see exact how legal responds.

I am still confused how this is related to DMCA. I tried googling and I couldnt' find any references to specific laws. My understanding of "revenge porn" is rarely commercialized by the user.

Your googling may have failed you. Revenue porn is deeply commercialized.

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