Attorney general sues company behind A2E app over AI tools that alter photos into sexual images

Florida Attorney General James Uthmeier’s office sued Rengstorff Consulting Ltd on Wednesday, Oct. 28, under the Florida Deceptive and Unfair Trade Practices Act.¹ The complaint was e-filed in Sarasota County circuit court, in the 12th Judicial Circuit, at 12:06 p.m. that day; the copy the office posted leaves the case number blank.² SignalData found no public statement from the company about the suit as of Oct. 29.

What the complaint alleges

The complaint describes Rengstorff as a Nevada corporation based in Las Vegas that runs the A2E website and a mobile app called Head Swap: Ultimate Face Swap, which it says is offered on the Apple App Store. It says A2E drew nearly 8.5 million visits in August 2026, without naming the source of that figure.²

According to the complaint, the products let users upload photos or videos of real people and generate images that show them nude or in sexual content, often without the subject’s consent. It alleges the tools can also make adults appear to be children, and that they can be used to produce child sexual abuse material.²

The complaint says A2E’s terms of use allow users to upload images of other people “only with their consent,” bar sexual deepfakes made without consent and sexual content depicting minors, and promise to end accounts used to make AI-generated child sexual abuse material and report them to law enforcement. It alleges the company does not verify consent and lacks content filters, moderation and enforcement mechanisms that block such content.² The complaint also points to two arrests in Florida as evidence that the company does not adequately monitor what its products generate; it does not name the people arrested.²

The complaint cites two Florida criminal statutes: section 827.072, which it says bars creating, possessing, viewing and transmitting child sexual abuse material generated by artificial intelligence, and section 847.0137, which it says bars transmitting such material, including images created or modified electronically to show an identifiable minor.²

The three counts

• Count I: unconscionable practices under the act
• Count II: unfair practices under the act
• Count III: deceptive practices, alleging the company’s terms lead users to believe that subjects consent, that sexual images of children are barred and that such material is monitored and reported

What the state is asking for

The complaint asks the court to permanently bar the company from offering tools that generate nude or sexualized images of minors and others without monitoring, reporting, consent verification and other safeguards. It also seeks consumer redress, disgorgement, civil penalties of up to $10,000 for each willful violation, attorney’s fees and costs, and a jury trial.²

In the office’s announcement, Uthmeier said companies “that design and profit from AI tools” that make such material easier to produce, while saying they prohibit it, “will be held accountable.”¹

What the records do not show

• These are the state’s allegations. No court has ruled on them, and Rengstorff Consulting has not been found liable.²
• No answer, court filing or public statement from the company was found. The Sarasota County docket was not checked, so the case number and any hearings are not reported.
• The complaint gives no total penalty figure; any amount would depend on how many violations a court found.²
• The complaint does not say how many Florida users A2E has or how many images it alleges were made of Floridians.²