Victims of sex trafficking can sue for damages in federal court. But who can they sue, and how can they recover? A lawsuit against Salesforce.com brings these provisions into focus. On January 7, the U.S. District Court for the Northern District of Illinois ruled that the lawsuit may proceed on a longstanding claim for relief against the now-defunct Backpage.
The Backstory: Backpage, Adult Classifieds, and Children in Danger
In the 2000s and 2010s, Backpage.com was a popular classified ad site. For several years, Backpage maintained a business relationship with Salesforce, a leading customer relationship management (CRM) company, for software support and other needs. But the popular Backpage adult classifieds also contained ads for commercial sex work. This included ads for the sexual exploitation of minors, posted by their traffickers.
In 2016, G.G. was a thirteen-year-old girl who had run away from home. According to allegations in court filings, traffickers kept G.G. and forced her into sex work, using Backpage to advertise for customers. G.G.’s mother, Deanna Rose, actually recognized her daughter in a Backpage ad.
Dozens of young people came forward with accounts of abuse, violence, and sex trafficking from clients who saw them in Backpage ads. Law enforcement seized the company in 2018 and indicted its executives. Although the Department of Justice did not bring charges of human trafficking against Salesforce, child sex trafficking victims from Backpage have sued them in civil court.
Civil Remedies for Sex Trafficking Victims: Can a Software Company Be Liable?
According to the Seventh Circuit, it is indeed possible for a CRM company like Salesforce to have civil liability to sex trafficking victims, even when the company did not directly participate in that trafficking.
The federal law against child sex trafficking, 18 USC § 1591, applies both to direct perpetrators and to those who benefit. Section 1595 allows individual victims to sue violators of Section 1591, including those who participated in such a “venture” if they “knew or should have known” about the crime.
G.G. filed a lawsuit in federal court in 2020, asserting a claim to damages from Salesforce under Section 1595. She alleged that Salesforce was “providing, assisting, supporting, and facilitating” Backpage’s ads with custom software, account planning, and other services — a “venture” for the purposes of anti-trafficking law.
The District Court for the Northern District of Illinois dismissed her complaint on Salesforce’s motion in May of 2022. Judge Andrea R. Wood held that Salesforce was an “interactive computer service,” and as such protected by the embattled 47 USC § 230 of the Communications Decency Act. This section largely shields internet service providers (ISPs) from liability for their users’ posts.
Congress has amended Section 230 to specify that it does not protect against sex trafficking charges. However, Judge Wood held that Salesforce had not committed any “conduct underlying” such a charge. The plaintiffs did not allege that Salesforce knew about the trafficking of G.G. herself. Without that allegation, the District Court did not believe that G.G. could sue Salesforce for her damages under Section 1595.
On appeal, the Seventh Circuit reversed and remanded this judgment. They found that the plaintiffs did allege that Salesforce participated in a sex-trafficking venture under Section 1595, as it had a “continuous business relationship” of close support. This section, according to the Court of Appeals, did not require Salesforce itself to conduct illegal activities in the business of sex trafficking. Nor did G.G. have to prove that Salesforce knew about her individual harm before she could sue for damages under Section 1595.
G.G.’s Case Comes Through (In Part)
Salesforce moved again to dismiss G.G.’s complaint. Her case was consolidated with other plaintiffs’ cases against Salesforce, but the District Court of the Northern District of Illinois ruled on Salesforce’s separate motion to dismiss on January 7, 2026.
The District Court denied Salesforce’s motion to dismiss G.G.’s claim of liability under Section 1595. Writing for the court, Chief Judge Virginia M. Kendall found that there was evidence to show that Salesforce also concerned itself with Backpage’s worries about criminal liability. Thus, the plaintiff plausibly alleged that Salesforce “knew or should have known” what was happening.
However, the District Court did dismiss G.G.’s claim for relief under Masha’s Law, which also provides a right to sue for victims of child sexual abuse and CSAM. This law would require Salesforce to have violated Section 1591. According to the court, a violation of Section 1591 does require knowledge of specific harm to the plaintiff, and G.G. did not allege that Salesforce knew of her personally.
Relief and Liability: How Wide a Net Does the Law Cast?
The Backpage cases helped drive Congress to amend Section 230 through the FOSTA-SESTA bill. Even so, free speech advocates and sex workers warned that the amendment could be counterproductive, leading service providers to censor or disable their sites in fear of prosecution and lawsuits.
This has indeed happened, partly due to uncertainty. Without more guidance on the breadth of the law, sites have been hesitant to host as much content as they once did. The Salesforce cases can potentially guide internet services and support companies to understand what courts expect of them, as well as providing survivors of trafficking with a roadmap toward relief.
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