Someone fed your photos into an image model and is selling the output. The copy is not your photo, pixel for pixel. It is close enough that your customers cannot tell, and close enough that the listing is taking your sales. The DMCA still has something to say about it, but the answer is narrower than most creators expect, and the part it does not cover is the part you have to handle differently.
Copyright protects original expression. A model output that reproduces your work in whole or in substantial part, without authorization, can be infringement, even if the pixels are not identical. The test is not pixel equality. It is whether the copy reproduces the heart of the work, the composition, the distinctive elements, the parts that make it yours. A model that was trained on your photos and produces images that are substantially similar to them is doing what a human copier does, faster and at scale. The DMCA notice process is the same: identify the work, identify the infringing material, and send the notice to the service provider's designated DMCA agent.
A DMCA notice can remove the listing, the image, or the page that hosts the copy, because the notice is a claim about a specific piece of infringing material on a specific service. What it cannot do is remove the model, or stop the model from producing more copies, because the model is not a listing. The Copyright Office's Section 512 resources make the distinction plainly: a takedown notice is a claim, not a court ruling that proves you own the work or that the other party infringed it, and the provider's action does not conclusively determine ownership or infringement. The notice is a tool for the copy in front of you, not for the system that made it.
The second limit is authorship. The DMCA Authority guide on AI-generated art notes that the question of whether AI-generated art can be protected under the DMCA hinges on the legal definition of authorship and originality, because copyright law attributes authorship to a human. An output generated entirely by a model, with no human authorship, may not itself be protected, which means the copier may have no copyright in the output either. That cuts both ways: it weakens the copier's claim to the output, and it complicates yours, if the output is the only thing you are trying to protect.
File the DMCA notice for the copy that reproduces your work. Identify your original, identify the infringing material with a specific URL, and send it to the designated agent, which you can find in the Copyright Office's DMCA Designated Agent database. You do not need a registration to send a notice, and you do not need a lawyer. The Copyright Office states plainly that a registration is not required before sending a takedown notice, though for US works, a registration is required before suing in court.
For the model itself, the route is different. If a platform is hosting a model trained on your work, the complaint is to the platform, under its own terms and its own copyright policy, not under the DMCA notice process alone. If the output is being sold as a product, the complaint is trademark or trade dress, if the output uses your brand, or unfair competition, if it misleads customers. The DMCA is the tool for the copy. The model needs a different tool, and the creator who files DMCA notices against a model is filing the right notice at the wrong target.
Preserve the evidence before you file: your original file with its creation timestamp, the published source URL predating the infringing content, and a screenshot of the copy with its URL and timestamp. The notice has to include the identification of the work you believe is infringed and the information that will help the provider locate the material. A vague description is not sufficient, and a notice without a specific URL will be rejected.
And read what you sign. The DMCA notice includes a statement, under penalty of perjury, that you are the owner or authorized to act for the owner, set out in 17 U.S.C. 512(c)(3). Section 512(f) makes knowing misrepresentation actionable in damages. A notice filed against a model output that does not reproduce your work is a misrepresentation, and it is the kind of mistake that costs more than the copy did.
Keep reading: the DMCA takedown notice checklist, when product descriptions are the theft, and what registration is actually worth cover the nearby cases in this series.
Yes, if the output reproduces your work in whole or in substantial part. The test is not pixel equality, it is whether the copy reproduces the heart of the work. Identify your original, identify the infringing material with a specific URL, and send the notice to the provider's designated DMCA agent.
No. The Copyright Office states that a registration is not required before sending a takedown notice. For US works, a registration is generally required before bringing an infringement lawsuit, but the notice itself does not need one.
No. A DMCA notice removes a specific piece of infringing material from a specific service. It cannot remove the model or stop it from producing more copies. For the model itself, the complaint goes to the platform under its own copyright policy, or to trademark or unfair competition law if the output uses your brand or misleads customers.
Your original file with its creation timestamp, the published source URL predating the infringing content, and a screenshot of the copy with its URL and timestamp. The notice must identify the work and give the provider enough information to locate the material.