Undefined Standing Creates Platform Liability Uncertainty

The provision allows "individuals affected by the publication" to claim disclosure of private facts without defining who qualifies as "affected," creating unpredictable liability for platforms hosting content. More concerning, the Division can initiate complaints "on behalf of aggrieved persons" without requiring those persons to come forward, enabling government-directed enforcement against platforms. The provision also allows estates of deceased persons to pursue claims indefinitely, creating perpetual liability for historical content, biographies, and archives—forcing platforms to monitor and potentially remove content about deceased individuals without temporal limits.