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Are they fake? They are the faces of real children in sexual and pornograpic images.
I agree there should be more specific laws, but this still seems to fall under the current ones to me. These are not fully artifical CSAM, which is fucked up but has no living victim. These are sexual pictures of real children, that just have most of the sexual part generated. Thats much, much closer to full on CSAM then the above, and falls under the "spirit" of the law, which is to punish people that abuse children for sex. That is what these other children did to these 60 girls.
You have to admit there is a pretty fundamental difference between manipulating an otherwise legal image to look like a minor in a sexual act vs an actual photo of that same minor engaged in a sexual act. While both might be considered a crime, the damage to the victim is of a fundamentally different nature. I think there's a strong argument that the former bears a closer relationship to slander than it does to rape.
I agree the two are different, but not as different as you seem to think. None of these girls were raped, but this is still sexual abuse, especially because these images were shared.
Sexual abuse is complex, and far surpasses "slander," especially in ones formative years. This act of sexual abuse is going to change how 60 girls and soon to be woman respond to sex, likely for the rest of their lives. These images may follow them forever, causing heartache, job loss, on and on, and the damage will be done because this is a form of CSAM of them that is in the world.
That is not a light matter to be sidelined to a "hand slap" level of offense. I think the fact the perpetrators were also children should play heavily in their defense, but otherwise this needs to be treated as the sexually damaging event it is.
It does seem like there needs to be a new law specifically addressing this. In the past someone could have cut out the heads of a 17 year old and pasted it on top of a playboy model. That's an obvious fake, but I don't think it is the same as what's happened here. But to a degree there are similarities. Does the ability to detect a fake matter? I don't know. There are applications that can determine if a picture is AI generated with some level of confidence. Does that mean only human opinion matters? Again, I don't know. Certainly there was no abuse at the time the image was taken, so there is a difference with this and CP.