OnlyFans tech clash: High Court refines interim relief in the world of adult content creation

Commercial litigation often ventures into interesting territory, and this case arises from one of the more risqué corners of the modern digital economy: the OnlyFans content-creator platform. In Infinni Innovations SA v OFMS Ltd & Ors [2026] EWHC 470 (Comm), Saini J considered whether to continue or refine an interim injunction previously granted without notice in relation to a competitor’s use of confidential data scraped from Infinni Innovations’ CRM platform. The application required the court to untangle allegations of covert data extraction, CRM competition and the commercial pressures surrounding the OnlyFans creator market. 

Background to OnlyFans business model

OnlyFans is a subscription-based social media platform (mostly known for adult content) where creators share paid-for content and use messaging tools to have conversations with their fans. Creators charge subscription prices for fans, and it is big business. In its 2024 accounts, OnlyFans reported gross payments from fans of approximately US$7.22 billion. 

Content creators aim to maintain personalised chats with fans through direct messaging. Successful content creators will often engage agencies to manage their accounts. The agencies will then employ members of staff who work as “chatters” to message the fans directly (as if they were the content creator). To help the chatters work effectively, agencies collect details on fan interactions from the chats, which include specific details about the fan involved (fan notes). Scripts are then developed by the agencies to enable their chatters to develop conversations which appear to the fan to be genuine, personalised chats with the content creator. 

Infinni Innovations (the Claimant) operates Infloww, a market-leading CRM platform used by agencies managing OnlyFans content creators. Its rival, run by the Defendants, OnlyMonster, competes aggressively for the same agencies, who depend on CRM tools to manage thousands of fan interactions in real time. 

The injunction

The Claimant alleged that the Defendants were responsible for a number of “cyber-attacks” which took the form of infiltration, and “data-scraping” of the Claimant’s servers. The Claimant contended that those servers held confidential information relating to data provided by content creators and their fans (which included fan notes and scripts), and analytic and reporting data generated by the Claimant. The Claimant argued that the infiltration and data-scraping was for the purpose of luring away the agency clients of Infloww and to make them the subscribers of OnlyMonster. 

Although the Defendants admitted taking certain fan notes and scripts, they argued that the agencies had authorised the data transfers. 

The Claimant applied without‑notice to obtain an interim injunction, restraining the Defendants from further accessing or infiltrating its servers, using or disclosing any fan notes or scripts taken, and using any confidential data allegedly extracted.

When the matter returned on notice, the court had to determine certain procedural issues including whether there had been a breach of the duty of fair presentation (when making a without notice application, the applicant has a duty to make a fair presentation of the material facts and relevant case law, including facts and arguments which the respondent would be likely to present, were they in attendance); whether the injunction should continue at all, and if so, in what form.

The court’s findings

Saini J found that the Claimant had not breached the duty of fair presentation.[1] The court did not agree with the Defendants that there had been a breach of that duty in relation to any issues of foreign law, or that the Claimant should have placed the Infinni terms of service before the court (since the Defendant was not a party to those terms of service). The court was also not persuaded by the Defendant’s submissions that the injunction had a significant impact on third parties. Saini J was of the view that the court had not been misled in any respect at the without notice hearing, and that “even if there had been a breach this is a case where the overall merits point towards interim relief of some form being re-granted.”[2]

Saini J found that the reporting and analytics data that had been extracted was generated by the Claimant itself (not the content creators or their agents) and therefore was confidential to the Claimant. Saini J also found that the fan notes and scripts were at least arguably confidential to the Claimant.

Ultimately, Saini J found that the Defendants had surreptitiously (and arguably by unlawful means[3]) exfiltrated data from the Claimant’s servers for the benefit of their competing business[4] and expressed concern about their continuing lack of candour[5] as to what was taken and how. That evidential picture justified continuation of interim relief until trial.

As to the scope of the injunction, the court recognised the commercial realities of the OnlyFans creator economy. Because agencies depend on uninterrupted CRM functionality and some agencies already had access to the extracted data on the OnlyMonster platform, the court considered that due to issues of practicality and fairness to those third party agencies, a narrower option for the injunction was appropriate, so as not to prevent those agencies from using the fan notes and script, but any other form of exploitation of the data by the Defendants would be prohibited.[6]

It is also worth mentioning the broad and sweeping order for disclosure that the Claimant sought. Saini J confirmed that the approach when considering such an order for disclosure alongside injunctive relief for breach of confidence should be “to ask whether a claimant has shown with clear and convincing evidence that, in the particular circumstances of the case, such an order is strictly necessary to police and give effect to an injunction, or to provide assistance in preventing future harm.”[7]

Applying this test, the court opted instead for a modified and more targeted form of disclosure affidavit and a digital image of the extracted data. A useful reminder that proportionality still rules, even where cyber‑intrusion is alleged. 

Key takeaways

Not only does this case uncover the fierce world of tech competition between two rival platforms in a fast-growing creator economy, it highlights the sensitivity of platform-users’ data and how subscriber interactions and creator communications are uniquely valuable. These elements, coupled with the adult‑content environment means allegations of data misuse carry enhanced scrutiny.

For businesses operating in digital markets, particularly those handling creator‑subscriber business models, user‑generated content, or high‑value customer messaging, this judgment underscores the importance of strong data‑security governance, clear internal audit trails, and plans to act swiftly where data is compromised. 

The case highlights the benefits of interim relief which will be robustly applied where evidence suggests unlawful behaviour, but proportionality remains central, especially in markets where third‑party stakeholders (here, creators and agencies) may be affected by restraints that are overly broad.

This judgment is a reminder that even in markets where the content may be risqué, the legal principles are anything but. As the matter heads to trial, the decision stands as helpful reading for any tech‑platform operator navigating competition, confidentiality, and the high‑stakes world of digital user engagement.