Attorneys representing the founder of the anti-masturbation group NoFap LLC 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.

The allegations were made by attorneys for the collected defendants, who claim that the first amended complaint presented by NoFap founder Alexander Rhodes' lawyers, David and Peter Kobylinski of the Pittsburgh-based law firm Kobylinski & Kobylinski LLC, is defective because it fails to provide adequate notice of the claims against each defendant.

Background on the Case

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. The lawsuit alleges that the defendants engaged in a civil conspiracy and racketeering scheme to defame the Rhodes-owned entity.

Accusations of Shotgun Pleadings

The attorneys for the collected defendants alleged that Rhodes' lawyers resorted to so-called "shotgun" pleadings in the first amended complaint. 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 that 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. Attorneys representing one of the scientists, Dr. David Ley, referred to the efforts by the plaintiffs as "fraud-based" and laced with "pleading deficiencies."

NoFap's History and Controversy

Alexander Rhodes founded NoFap in 2011 after claiming a lifelong addiction to porn beginning at age 11. The website is careful to claim that it’s just a website, not a movement, despite having an associated subreddit with 515,000 subscribers and a Twitter account with more than 19,000 followers.

NoFap is most commonly associated with #NoNutNovember, an online challenge in which men try not to masturbate or otherwise orgasm for a month. A 2018 study published in the peer-reviewed journal Sexualities found that members of NoFap online communities don’t see women in porn as “real women,” and that “real sex” is seen through the predominately male, heterosexual worldview of its members.

Key Facts

  • Alexander Rhodes sued Aylo, two scientists critical of NoFap, an academic publisher and the University of California system in late 2025.
  • The lawsuit alleges a civil conspiracy and racketeering scheme to defame the Rhodes-owned entity.
  • Attorneys for the collected defendants accused Rhodes' lawyers of using "shotgun" pleadings in the first amended complaint.
  • Alexander Neimroff, lead attorney representing the University of California system, defined "shotgun pleading" as multiple claims against multiple defendants without specifying which defendant is responsible for each act or omission.
  • NoFap was founded by Alexander Rhodes in 2011 after claiming a lifelong addiction to porn beginning at age 11.