By: Emma Marck

Case/Decision/Legislation/Bill Commented On: Protecting Victims of Non-consensual Distribution of Intimate Images Act, SA 2017, c P-26.9

PDF Version: Intimate Image Abuse in the Age of Deepfakes: Reforming Alberta’s Civil Legislation: Part 2

The Canadian Centre for Child Protection reported that non-consensual distribution of intimate images (NCDII) involving Canadian youth increased by approximately 21% between 2024 and 2025, from 436 to 527. Despite the growing prevalence of intimate image abuse, Alberta does not provide a dedicated process for obtaining an expedited intimate image protection order or expressly authorize orders requiring online platforms to remove intimate images. Victims seeking protective relief must instead navigate ordinary civil proceedings or pursue voluntary removal through online platforms.

Voluntary platform reporting requires victims to manually report their own intimate images for removal without the benefit of a court order. Research shows that platforms frequently fail to respond to voluntary reports and often respond only after intimate images have been redistributed (Qiwei Li et al, “Platforms as Crime Scene, Judge, and Jury: How Victim-Survivors of Non-Consensual Intimate Imagery Report Abuse Online” (2025) 1392 Proceedings of the 2026 CHI Conference on Human Factors in Computing Systems 1 at 14). The delays permit further distribution, reduce the effectiveness of voluntary reporting, and compound the harms caused by NCDII (at 14).

The Protecting Victims of Non-consensual Distribution of Intimate Images Act, SA 2017, c P-26.9 (Alberta Act), establishes a civil cause of action for NCDII under section 3. In March 2026, the Alberta government announced plans to amend the legislation to address deepfake non-consensual intimate images (DNCII). However, expanding the definition of “intimate image” will not ensure access to effective remedies if victims cannot obtain timely protection or compel the removal of images circulating online. With no specialized procedures in the Alberta Act, the Alberta Rules of Court, Alta Reg 124/2010, will ordinarily apply. They require an applicant to comply with the procedures governing applications and responses (rr 6.3 and 6.6), service (Part 11), and evidence at application hearings (r 6.11). These procedures create delay, and the longer an intimate image remains online, the greater the likelihood of further circulation and exposure to additional forms of abuse (Antoinette Raffaela Huber & Zara Ward, “Non-consensual Intimate Image Distribution: Nature, Removal, and Implications for the Online Safety Act” (2025) 22:1 European J Criminology 30 at 32).

The Alberta Act does not explicitly authorize takedown orders or establish an expedited application for takedown orders. Other provinces that do so include British Columbia (Intimate Images Protection Act, SBC 2023, c 11, s 5 (BC IIPA)), New Brunswick (Intimate Images Unlawful Distribution Act, SNB 2022, c 1, s 5 (NB IIUDA)), and Nova Scotia (Intimate Images and Cyber-protection Act, SNS 2017, c 7, ss 5–6 (NS IICPA)).

This is the second post in a two-part series. In the first post, I discussed why the Legislature should:

1) Amend section 1 of the Alberta Act to define “intimate image” as a “personal intimate image” or a “fake intimate image” and include “nearly nude” images under each definition. Personal intimate images should require that the person is “depicted” instead of “identifiable.” Fake intimate images should maintain an identifiability requirement.

This post argues that the Alberta Legislature should:

2) Create a right to apply to the Court of King’s Bench for an expedited intimate image protection order. The Alberta Act should also introduce separate consent standards for expedited protection orders and damages claims.

3) Expressly authorize removal, search-engine de-indexing, information production, and direct intermediary orders (collectively referred to as “takedown” orders in this post). These reforms must be supported by an internet-intermediary definition and liability limit.

Alberta’s legislation could separately authorize an expedited application against a named respondent for orders prohibiting further distribution and requiring the respondent to destroy any copies within their possession or control. However, this post focuses on the procedural changes necessary to obtain immediate removal and de-indexing from online platforms without first identifying, naming, and serving the distributor. It also proposes related amendments to the existing cause of action and consent defence.

The Alberta Act Should Create an Expedited Application in the Court of King’s Bench to Best Address Online Distribution

Victims of NCDII can face increased risk when navigating multiple civil, criminal, and support pathways. In Nova Scotia, section 14 of the NS IICPA required the Minister to review the effectiveness and implementation of the legislation three years after it came into force. The resulting Review of the Intimate Images and Cyber-protection Act found that the complexity of multiple legal systems can cause victims to “fall through the cracks.” (at 28)

In 2021, the Uniform Law Conference of Canada (ULCC) developed the Uniform Non-consensual Disclosure of Intimate Images Act (Uniform Act) as a model statute to promote greater consistency across intimate image laws in Canada. The Alberta Act should follow the ULCC’s primary recommendation by creating a route for expedited applications seeking takedown relief (Hilary Young & Emily Laidlaw, Nonconsensual Disclosure of Intimate Images (NCDII) Tort (St. John’s: Uniform Law Conference of Canada, 2019) (ULCC Report) at paras 7–8; Uniform Act, General Comment).

By way of comparison, Manitoba’s Non-Consensual Distribution of Intimate Images Act, CCSM c N93 (Manitoba Act) authorizes designated agencies to assist individuals in removing intimate images from the internet takedown of intimate images in Manitoba (Manitoba Act, ss 3–4; Intimate Image Protection Regulation, Man Reg 3/2016, ss 2–3). The NS IICPA creates civil remedies to “deter, prevent and respond to the harms of [NCDII]” (s 2). The Nova Scotia Supreme Court’s Practice Memorandum No 13: Intimate Images and Cyber-Protection (NS Practice Memorandum) establishes court procedures for obtaining remedies without requiring an authorized agency to bring the application. The Nova Scotia model is preferable; Alberta’s legislation should create a direct right of application because the proposed relief includes binding orders against internet intermediaries.

The Court of King’s Bench should decide the expedited application because small claims courts have limited authority to grant injunctive relief (Uniform Act, comment to the definition of “court”; ULCC Report at para 93). Accordingly, the Alberta Act should provide that an individual depicted in an intimate image may apply to the Court of King’s Bench for relief.

The Alberta Act should also adopt section 12 of the Uniform Act, which provides that “[t]he rights and remedies under this Act are in addition to any other right or remedy that may be available to an applicant, a claimant or a respondent.” A cumulative remedies provision allows victims to seek protective relief through expedited takedown orders while also pursuing compensatory damages concurrently (Uniform Act, s 12, General Comment). This approach would allow an affected person to prevent further harm through expedited takedown relief while retaining the option of commencing a more costly action to determine liability and obtain damages.

Expedited Takedown Applications Should Not Require a Named Respondent

Requiring a named respondent in an expedited application undermines fast takedown relief. The applicant would first need to provide notice, serve the distributor of the image(s), and provide an opportunity to file evidence in response (Alberta Rules of Court, rr 6.3 and 6.6). Alberta should permit an expedited takedown application to proceed without notice or a named respondent to avoid the risk of continued circulation due to waiting periods.

British Columbia’s Civil Resolution Tribunal (CRT) issued Intimate Image Protection Order Rules intended to further access to justice for victims of NCDII (r 1.3(1)). According to Rule 1.3(2)(c), the Intimate Image Protection Order Rules must be applied in a manner that “recognizes the importance of making timely decisions to reduce further harm to people who [are victims of NCDII].” The BC IIPA authorizes the CRT to determine that an intimate image was distributed without consent and to issue removal, deletion, and de-indexing orders where the distributor is not a named respondent (s 5(2)). The application may proceed without notice, and any person affected by the resulting determination or order may later seek cancellation (ss 5(6)–(8)). This procedure reflects the ULCC’s recognition that “time is of the essence to arrest further distribution of an image to the extent possible.” (ULCC Report at para 52) Alberta should adopt this combination of expedited relief without notice and a subsequent right for affected persons to seek cancellation.

Express statutory authority would remove uncertainty about whether an applicant must first obtain relief against the distributor. In Google Inc v Equustek Solutions Inc, 2017 SCC 34 (CanLII), the Supreme Court of Canada upheld an injunction against Google because its assistance was necessary to prevent the defendants from defying court orders and causing irreparable harm (at paras 34–35, 42). Because the common-law route turns on necessity, the Alberta Act should expressly authorize orders against intermediaries without requiring prior relief against the distributor. Accordingly, the amended Alberta Act should provide that an application may be made without notice and without a named respondent.

The Applicant Should Prove Non-Consent in an Expedited Takedown Application Without a Named Respondent

The amended Alberta Act should authorize the Court to determine an expedited takedown application without an oral hearing, based on affidavit and other written evidence. This procedure would avoid the delay and expense of scheduling a personal appearance and reflect the ULCC’s proposed minimal evidentiary burden (ULCC Report at para 7). Express statutory authority is necessary because the procedure for deciding applications without a personal appearance under Rule 6.9 does not automatically apply to originating applications (Alberta Rules of Court, rr 6.1(b), 6.9).

On the issue of consent, the Alberta Act should require the applicant to satisfy the Court that the image is an intimate image depicting the applicant and that a person other than the applicant and who is not a respondent distributed the intimate image without the applicant’s consent. This approach departs from the Uniform Act, which places the burden of proving consent on a named respondent (Uniform Act, ss 4(1)–(2), 9). Because no respondent participates in the initial proceeding, the applicant should establish through affidavit evidence that the image depicts the applicant and that another person distributed it without the applicant’s consent. The Alberta Act should also provide that the Court may determine an application based on affidavit and other written evidence. The amended Alberta Act should further provide that a party or other person affected by a determination or order made under this section may ask the Court to cancel the determination or order.

Despite this higher initial burden, an expedited takedown application without a named respondent would provide faster relief because the Court would not be required to wait for the applicant to identify the distributor, provide notice, and wait for the distributor to respond. The Court should be able to issue takedown orders without declaring that the distributor acted unlawfully. Any affected person could later seek cancellation by proving actual consent (BC IIPA, ss 5(7)–(8), 10).

The Court of King’s Bench Should Clarify the Procedure for Expedited Applications Through Civil Practice Note 1

Alberta should accompany these legislative amendments by adding a procedure for intimate-image protection orders to the Court of King’s Bench Civil Practice Note 1: Justice and Applications Judges’ Chambers and Special Applications (AB Civil Practice Note 1). The amended Practice Note should permit applications without a named respondent to proceed without a personal appearance by the applicant. It should also require the clerk to place each complete application promptly before a Justice (AB Civil Practice Note 1, Part A). The Practice Note should specify the required filing package including a tailored originating-application form, a supporting affidavit identifying the image and the available evidence of non-consensual distribution, the relevant URLs or accounts, and a proposed form of order. It should also explain that the Justice may determine the application, give directions for further preparation and set a hearing date, arrange an expedited hearing in an emergency, or grant interim relief where supported by the evidence (see NS Practice Memorandum at para 15). A Justice would be required to determine the application because the requested relief includes injunctions, which Applications Judges cannot grant (Court of King’s Bench Act, RSA 2000, c C-31, s 9).

The Court should also publish forms for expedited takedown applications without a named respondent and for applications seeking information production, takedown, or cancellation. The Court should model these forms on those appended to the NS Practice Memorandum. The forms would help self-represented parties navigate otherwise complicated and expensive processes (see NS Practice Memorandum at para 16, Appendix).

Only Actual Consent Should Be a Defence to Expedited Relief

NCDII legislation takes several approaches regarding the evidentiary burden for obtaining expedited takedown relief. The NB IIUDA requires the Court to find that the applicant had a reasonable expectation of privacy before granting relief (ss 4(1), 5(1)). The NS IICPA requires the Court to find that the respondent distributed the intimate image without consent before granting declaratory or injunctive relief (ss 3(d), 6(1)). The Uniform Act, by contrast, does not require the applicant to separately prove a reasonable expectation of privacy or non-consent as an element of the expedited application (4(1)–(2), 6 and 9). The Uniform Act creates the right to apply with a minimal evidentiary burden to ensure that victims can obtain takedown quickly and inexpensively (Uniform Act, General Comment; ULCC Report at para 7).

In my view, Alberta’s legislation should create separate defences for expedited applications and traditional tort actions. Requiring actual consent to defeat expedited relief allows an applicant to obtain protective orders even where the distributor honestly but mistakenly believed that consent existed (Uniform Act, comment to s 9). An actual-consent standard avoids a fault-based inquiry that could complicate and delay a process designed to provide quick and inexpensive protective relief (ULCC Report at paras 5, 7; Uniform Act, comment to s 9). It also ensures that protective relief addresses the image’s continued availability online rather than the distributor’s blameworthiness or subjective belief in consent (ULCC Report at paras 7, 75; Uniform Act, comment to s 9).

Accordingly, the amended Alberta Act should provide that, on a request for cancellation, the Court must cancel the determination or order if the respondent proves that the applicant consented to the distribution of the intimate image at the time when and to the extent that it was distributed. It should also provide that a person requesting cancellation is considered a respondent for the purposes of that defence.

The Alberta Act Should Amend the Cause of Action and Consent Defence for Compensatory Damages

The Alberta Act must apply different consent standards for expedited applications and tort liability. Only actual consent should defeat expedited relief because it addresses an intimate image’s continued availability. In an action for damages, however, an honest and reasonable belief in consent should be a defence to tort liability. Implementing this distinction requires amendments to the existing cause of action, which currently requires the plaintiff to prove that the defendant knew that the plaintiff did not consent or was reckless as to whether the plaintiff consented (Alberta Act, s 3).

The Cause of Action Should Not Require Knowledge or Recklessness as to Non-Consent

The Alberta Act’s statutory cause of action currently requires a plaintiff to prove that the distributor knew the depicted person did not consent or was reckless as to whether the depicted person consented. This creates a barrier to relief by requiring the plaintiff to prove the distributor’s state of mind, even where the plaintiff did not consent. The ULCC Report rejects the knowledge or recklessness approach because it imports the criminal mens rea concept into civil law (ULCC Report at paras 66–67). The Alberta Act should amend section 3 so that distributing an intimate image constitutes a tort without requiring the plaintiff to prove that the distributor knew of, or was reckless about, non-consent, subject to the defence discussed next (see Uniform Act, s 3, comment to s 10).

The Defence Should Include an Honest and Reasonable Belief in Consent

Section 6 of the Alberta Act currently provides only a public-interest defence. The Uniform Act permits the defendant to prove actual consent or an honest and reasonable belief in consent in addition to the public-interest defence (Uniform Act, s 10(1)(b)–(c), comment to s 10). The reasonableness of a defendant’s belief in consent is assessed objectively by asking whether a reasonable person would understand that an agreement to distribute existed (ULCC Report at paras 64–67, 72–73). The Alberta Act should follow the NB IIUDA, BC IIPA, and Uniform Act by providing a defence where the defendant “had, or honestly and reasonably believed that [they] had” consent “at the time when and to the extent that” the image was distributed (NB IIUDA, s 8(1)(b); BC IIPA, s 11(1)(a); Uniform Act, s 10(1)(b)).

This approach is justified because tort law is less concerned with the defendant’s blameworthiness and imposes less stigma than criminal law (ULCC Report at paras 64–67). Shifting the onus to the defendant also avoids placing the effort and expense on the plaintiff to prove non-consent (ULCC Report at paras 74–80).

The Alberta Act Should Expressly Authorize Removal, De-Indexing, Information Production, and Intermediary Orders

Although voluntary platform reporting is generally cheaper and faster than litigation, internet intermediaries are “ill-equipped” to make legal determinations about consent (ULCC Report at paras 9, 11). An internet intermediary may also refuse removal where the posting of an intimate image complies with its terms of service (ULCC Report at para 10). Voluntary platform reporting also offers limited transparency, procedural fairness, and rights of appeal (ULCC Report at para 10).

A declaration that a named respondent’s distribution was unlawful can provide intermediaries with compelling evidence that their terms of service were breached (Uniform Act, s 4(2)(c); ULCC Report at para 28). However, as discussed above, obtaining a declaration against a named respondent would ordinarily require the applicant to serve the application and provide the respondent with an opportunity to respond (Alberta Rules of Court, rr 6.3, 6.6). A declaration that a named respondent acted unlawfully is unnecessary where the Court is authorized to order an intermediary directly to remove or de-index the image (see e.g. BC IIPA, ss 5(2)(a), (c), 5(3)(a)). The Court would establish a factual and legal basis for the takedown order by determining that the image was distributed without the applicant’s consent.

The Alberta Act should authorize the Court to determine that an intimate image was distributed without consent and to order internet intermediaries to delete, remove, and de-index intimate images online (Uniform Act, ss 4(1)–(3), 5(1)–(3)). As noted above, this relief should be available on an expedited basis. Deletion orders would require copies of the image to be destroyed, removal orders would require the image to be removed from an online platform, and de-indexing orders would require search engines to stop displaying links to the image (Uniform Act, ss 4(2)(d)–(e), 5(2)(d)–(e); see also National Security Law Firm).

Currently, section 7(1) of the Alberta Act authorizes damages, an accounting of profits, an injunction, and any other just and reasonable order against a defendant but does not expressly authorize orders against internet intermediaries. A plaintiff relying on section 7(1) must argue that the Court’s injunction power and authority to make “any other just and reasonable order” permits platform removal, search-engine de-indexing, or intermediary relief.

S.B. v D.H., 2022 SKKB 216 (CanLII) (S.B.) demonstrates why a broad remedial power may not provide adequate relief for NCDII under the Alberta Act as currently framed. The claim in S.B. arose before Saskatchewan amended The Privacy Act, RSS 1978, c P-24 (SK Privacy Act) in 2022 to expressly authorize orders for deletion, removal, and de-indexing (s 7.7(1)(b.1)). The Court declined to issue takedown orders under its broad remedial powers, even though it acknowledged that a victim of NCDII could reasonably be reluctant to disclose her identity and images to a private takedown service (S.B. at para 137).

The Manitoba Act provides the closest drafting model for Alberta. Following its amendment in 2026, it explicitly permits the Court to order the defendant to delete or destroy copies, order platform removal, and order search-engine de-indexing (Manitoba Act, s 14(1)(b.1); The Non-Consensual Distribution of Intimate Images Amendment Act, SM 2026, c 2, s 8 (Manitoba Amendment Act). The Manitoba Act also allows the Court to order an internet intermediary to remove and, where applicable, de-index the image within a specified period (Manitoba Act, s 14(1)(b.2); Manitoba Amendment Act, s 8).

The Alberta Act should authorize three forms of relief, which could be made either through the proposed expedited application or the existing action for compensatory damages. The Court should be able to:

i. Determine that the intimate image was distributed without consent (BC IIPA, s 5(2)(a); Uniform Act, s 4(2)(c)).

ii. Order an internet intermediary to remove, delete, destroy, or de-index the image (Uniform Act, ss 4(2)(e), 5(2)(e); BC IIPA, s 5(2)(c); Manitoba Act, s 14(1)(b.2)).

iii. Order a person to produce any information the Court considers necessary to further removal, deletion, destruction, or de-indexing (BC IIPA, s 5(2)(d)).

These forms of relief would provide effective takedown under the Alberta Act.

The Alberta Act Should Define “Internet Intermediary” Under Section 1

The Alberta Act should define “internet intermediary” as “an organization that hosts or indexes third-party content through an online platform.” (se e.g. Uniform Act, s 1; BC IIPA, s 1) Although the proposed wording is narrower than the Manitoba Act’s inclusion of a “person or organization” in s 1(1), the proposed definition is consistent with the Uniform Act and the remedial purpose of the proposed amendments (Uniform Act, comment to s 1).

The Alberta Act Should Limit Intermediary Liability to Support Direct Takedown Orders

Internet intermediaries should generally be protected from liability for damages arising from third-party distribution (Uniform Act, s 8, comment to s 8). However, the limit on internet intermediary liability should not prevent the Court from making direct takedown or information production orders against them. Currently, the Alberta Act only includes a liability limit for parents of child defendants who did not “directly participate” in distributing an intimate image (Alberta Act, s 8). A broad definition of “distribution” may capture internet intermediaries and implicate freedom of expression issues (Uniform Act, comment to s 8). Internet intermediaries should not generally be named as parties or required to defend expedited applications or actions for compensatory damages under the Alberta Act (Uniform Act, comment to s 8).

The Alberta Act should provide that an internet intermediary is not liable if the internet intermediary has taken reasonable steps to address, through its services, the distribution of intimate images without the consent of the person depicted. This would follow the approach in section 12 of the BC IIPA (see also Uniform Act, s 8(1)). The Alberta Act should also provide that nothing limits the Court’s authority to make an order against an internet intermediary (Uniform Act, s 8(2); Manitoba Act, s 15.1(2)). This provision would clarify that the liability limit does not exempt internet intermediaries from complying with orders under the Alberta Act (Uniform Act, s 8(2), comment to s 8; Manitoba Act, s 15.1(2)).

Conclusion

As I have argued in this post, Alberta’s NCDII legislation should create an expedited application for protective relief. Affected persons need a direct way to seek removal and de-indexing orders when continued circulation can compound their harm. A dedicated application in the Court of King’s Bench, supported by tailored forms and faster hearings, would reduce procedural barriers for applicants acting without counsel. Separate consent standards would also ensure that a respondent’s mistaken belief in consent does not prevent protective relief where the affected person did not actually consent to distribution.

The Alberta Act should also give the Court express authority to issue removal, de-indexing, and information-production orders. A determination that the image was distributed without consent would provide the factual and statutory basis for a direct takedown order. The proposed remedies would reduce the burden on affected persons to locate images, retain private takedown services, or repeatedly report the same content. Together, these amendments would give Alberta courts the ability to address online circulation in a more comprehensive way than the current legislation allows. Based on the foregoing analysis, I propose the following amendments to the Alberta Act. For clarity, the new provisions are underlined below:

Definitions

“internet intermediary” means an organization that hosts or indexes third-party content through an online platform.

Distribution of Intimate Images

3 A person who distributes an intimate image of another person, knowing that the person depicted in the image did not consent to the distribution, or is reckless as to whether or not that person consented to the distribution, commits a tort against that other person.

Application for Expedited Intimate-Image Protection Order

3.1(1) An individual who is depicted in an intimate image that has been distributed by another person without the individual’s consent may apply to the Court of King’s Bench for relief under this section.

(2) In an application under subsection (1), if the applicant satisfies the Court that the image is an intimate image depicting the applicant and that a person other than the applicant and who is not a respondent distributed the intimate image without the applicant’s consent, the Court, after considering any prescribed factors, may do any or all of the following:

(a) determine that the intimate image was distributed without the applicant’s consent;

(b) order an internet intermediary to

(i) remove the intimate image from any platform operated by the internet intermediary and from any other electronic form of application, software, database or communication method,

(ii) delete or destroy the intimate image, and

(iii) de-index the intimate image from any search engine;

(c) order a person to provide any information the Court considers necessary to further the objectives of removal, deletion, destruction or de-indexing of the intimate image;

(d) make any other order the Court considers just and reasonable in the circumstances.

(3) An application under subsection (1) may be made without notice and without a named respondent.

(4) The Court may determine an application under subsection (1) based on affidavit and other written evidence.

(5) A party or other person affected by a determination or order made under this section may ask the Court to cancel the determination or order.

(6) A party or other person who makes a request under subsection (5) is to be considered a respondent for the purposes of section 6.1.

Defences

6 A defendant is not liable in an action under section 3 if the defendant proves that

(a) the defendant had, or honestly and reasonably believed that the defendant had, the consent of the person depicted in the intimate image to distribute the intimate image at the time when and to the extent that the defendant distributed it; or

(b) the distribution was in the public interest and did not extend beyond what was in the public interest.

6.1 On a request under section 3.1(5), the Court must cancel the determination or order if the respondent proves that the applicant consented to the distribution of the intimate image at the time when and to the extent that it was distributed.

Remedies

7(1) In an action under section 3, the Court may

(a) award damages to the plaintiff, including general, special, aggravated and punitive damages,

(b) order the defendant to account to the plaintiff for any profits that have accrued to the defendant as a result of the distribution of the intimate image,

(b.1) determine that the intimate image was distributed without the plaintiff’s consent,

(b.2) order an internet intermediary to

(i) remove the intimate image from any platform, electronic application, software, database or method of communication,

(ii) delete or destroy the intimate image, and

(iii) de-index the intimate image from any search engine,

(b.3) order a person to provide any information that the Court considers necessary to further the removal, deletion, destruction or de-indexing of the intimate image,

(c) issue an injunction on any terms and conditions that the Court determines appropriate in the circumstances, and

(d) make any other order that the Court considers just and reasonable in the circumstances.

Liability of internet intermediaries limited

8.1(1) An internet intermediary is not liable under this Act if the internet intermediary has taken reasonable steps to address, through its services, the distribution of intimate images without the consent of the person depicted.

(2) Nothing in this section limits the Court’s authority under section 3.1 or section 7 to make an order against an internet intermediary.

Rights and remedies not limited

9 The rights and remedies under this Act are in addition to any other right or remedy that may be available to an applicant, plaintiff, respondent or defendant.

This post may be cited as: Emma Marck, “Intimate Image Abuse in the Age of Deepfakes: Reforming Alberta’s Civil Legislation: Part 2” (31 August 2026), online: ABlawg, http://ablawg.ca/wp-content/uploads/2026/08/Blog_EM_Intimate_Images_Part2.pdf

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