LOS ANGELES—Attorneys representing the founder of the anti-masturbation group NoFap LLC, Alexander Rhodes, are accused of using so-called "shotgun" pleadings in their case against Pornhub's parent company Aylo and a class of defendants implicated in an alleged civil conspiracy and racketeering scheme to defame the Rhodes-owned entity.
In the initial filing in late 2025, Rhodes sued Aylo, two scientists critical of NoFap, an academic publisher and the University of California system claiming a campaign targeting NoFap and meant to grow Pornhub's market share.
In recent filings, attorneys for the collected defendants alleged that Rhodes' lawyers, the brothers David and Peter Kobylinski of the Pittsburgh-based Kobylinski & Kobylinski LLC law firm, resorted to so-calles "shotgun" pleadings in the first amended complaint that presented the potentially baseless conspiracy.
Alexander Neimroff, the lead attorney representing the University of California system, notes that the "first amended complaint constitutes an impermissible 'shotgun pleading.'" Neimroff defines the term as “multiple claims against multiple defendants without specifying which of the defendants are responsible for which acts or omissions, or which of the defendants the claim is brought against."
Neimroff further explains, "Such complaints are defective because they fail to provide the defendants 'adequate notice of the claims against them and the grounds on which each claim rests,'" via a citation of case law.
Additionally, attorneys representing one of the scientists, Dr. David Ley, referred to the efforts by the plaintiffs as "fraud-based" and laced with "pleading deficiencies." Both of these instances from Dr. Ley and the University of California system are sourced from a new round of reply briefs filed by the defendants to further bolster arguments made in their collective motions to dismiss.
Rhodes' attorneys have maintained that the defendants engaged in a RICO scheme to further cause harm to his company and personal image, while also further diluting the registered trademarks and intellectual property of NoFap. For example, the other scientist who was sued, Dr. Nicole Prause, is painted by the plaintiffs as an incredible liar in multiple instances despite examples of the disputing evidence filed by her attorneys.
Similarly, Rhodes sued academic publisher Taylor & Francis, the entity that owns some of the academic peer-review journals that have published Ley and Prause and their work critical of NoFap's overall mythos.
NoFap teaches concepts of "rebooting" the human brain from problematic pornography use by abstaining from not only porn viewing but also masturbation. The teachings have even developed into orgasm denial as a means to harness some sort of imagined set of health benefits. Ley and Prause wrote critical materials challenging this claim, further offering a scientific basis to characterize NoFap's theories as pseudoscience.
Rhodes has also been central in circulating the claim that pornography consumption is as addictive as consuming hardcore drugs.
As AVN has noted time and again, the vast majority of the major medical and health societies in the United States and abroad do not recognize pornography addiction as a mental health diagnosis. Rather, problematic pornography use falls under compulsive behavior disorders that cannot be treated through an addiction treatment model.
This has long been core to the work of Ley and Prause, including their research into the wider NoFap movement that has grown beyond the Rhodes-owned NoFap LLC.
Aylo was sued by Rhodes because he maintains that the company bankrolled the effort to discredit NoFap and other opponents of the online porn business, including activists and extremists like Laila Mickelwait and the staff of the far-right National Center on Sexual Exploitation.
Rhodes, who is known for being litigious and even sued his biological mother Althea Azeff for defamation, filed suit in a local court initially. The case was removed by the defendants to federal court in Pennsylvania.
