Without Her Knowledge: Enabling the Rape of an Unconscious Woman
Abstract:
None of the men who raped Gisèle Pelicot forcibly entered the home she shared with her husband, Dominique. Not one was required to use force to overtake her, she was not bound and gagged; there is no evidence of the application of physical force. That is not what this case is. Gisèle was unconscious due to the cocktail of medications Dominique secretly administered to her. Unbeknownst to Gisèle, her husband had invited these men into their home to rape her.
The discussion in this Article is intentionally detailed; admittedly, the material can be painful to read. We recognize the inevitable discomfort but are of the opinion the consequences of enabler behavior must be presented from the victim’s perspective. There is no intention to be disrespectful or to engage in prurient discussion. That said, the events are disturbing and demand honest engagement.
There is an abundance of criminal actors responsible for this virtually incomprehensible crime. Similarly, there are several legal issues germane to what transpired in the Pelicot household. Notwithstanding the range of actors and issues we could examine, we have made the deliberate decision to focus on Dominique and the website essential to his criminal conduct.
Dominique’s rapes, and that of 70 other men, were dependent on the website, Coco; the former are the perpetrators, the latter, the enabler. There is a direct connection between the two. In focusing on the rapes committed by those Dominique brought into the home, we analyze the rape he committed while not himself engaging with Gisèle intimately.
This issue is a critical component of our undertaking. We have chosen to term this “rape by proxy.” Admittedly the “through line” in this Article whereby we connect the issue of enablers with the question of categorizing rape may not, at first blush, be necessarily self-evident. We recognize that.
To fully understand the repeated violations of Gisèle’s body demands identifying the enablers. While the website Coco did not assault Gisèle, absent their actions, Dominique would not have had the necessary infrastructure. The carefully planned crime, involving scores of men over many years, was dependent on the enablers. It is, then, under that “umbrella” the issue of enabler culpability will be examined in detail. In doing so, we will recommend mechanisms for holding enablers accountable for their actions and direct contributions to a crime.
To understand the necessity of expanding our conceptualization of rape to include “rape by proxy,” we must examine the current state of rape law and rape culture in various jurisdictions. Rape culture is pervasive across multiple societies and despite progress in the field of victims’ rights, victims of rape still experience being dismissed, disbelieved, and blamed.
Key Words: Rape by Proxy, Website Accountability, Criminalizing Enablers, Rape Culture, Architecture of Enabling, Websites as Enabling Crimes, Rape Law, Victim Autonomy, Content Moderation, Rape Law Reform
I. Introduction
Sitting in his parked car, located far enough away so as to not attract attention, he waited for almost an hour for the drugs to take effect on the other man’s wife.[1]
He walks up to the house and is greeted by the man, whom he notes as being significantly large in stature. He is impressed by the vastness of the man’s house, and its near clinical cleanliness.[2]
The man leads him into the kitchen.[3] There, he is instructed to undress and warm his hands with either hot water or on a radiator, so his cold hands would not wake or disturb the man’s wife.[4] He is then assessed by the other man, who continues the inspection for conditions that might awake the man’s wife, such as the presence of tobacco or perfume scents.[5]
He is assured by the man that a condom is not required.[6]
No money changes hands.[7]
From the kitchen, he is led to a bedroom where he first sees the other man’s wife – unconscious and laying naked on the bed.[8]
The other man remains in the room and instructs him to begin penetrating the man’s wife. While he rapes the man’s wife, he feels bewildered as the man barks orders at him while standing in the room, naked and masturbating.[9]
This is the experience of dozens of men who were solicited by Dominique Pelicot to rape his wife, Gisèle Pelicot.[10]
At its core, a husband directed the rape of his wife over the course of ten years by dozens of men who he, through a website, solicited to act as his conduit. Full stop.
More than watching his wife be raped, over the course of several years Dominique Pelicot raped by proxy his wife, Gisèle Pelicot, in concert with dozens of other men. In a nutshell, Gisèle was raped while unconscious by men who Dominique had interacted with using the social media platform, Coco.
The discussion in this Article is intentionally detailed; admittedly, the material can be painful to read. We recognize the inevitable discomfort but are of the opinion the consequences of enabler behavior must be presented from the victim’s perspective. There is no intention to be disrespectful or to engage in prurient discussion. That said, the events are disturbing and demand honest engagement.
There is an abundance of criminal actors responsible for this virtually incomprehensible crime. Similarly, there are several legal issues germane to what transpired in the Pelicot household. Notwithstanding the range of actors and issues we could examine, we have made the deliberate decision to focus on Dominique and the website essential to his criminal conduct.
The rapes committed by Dominique and 70 other men, were dependent on the website; the former are the perpetrators, the latter, the enabler. There is a direct connection between the two. In focusing on the rapes committed by those Dominique brought into the home, we analyze the rape he committed while not engaging with Gisèle intimately.
This issue is a critical component of our undertaking. We have chosen to term this “rape by proxy.” Admittedly the “through line” in this Article whereby we connect the issue of enablers with the question of categorizing rape may not, at first blush, be necessarily self-evident. We recognize that.
However, the rapes of Gisèle were only possible because of the conduct of two distinct enablers, the website and the medical profession, physicians and pharmacists alike.[11] For a variety of reasons, primarily due to significant barriers to accessing necessary information, we chose to focus on the website exclusively.
That is not intended to excuse the important role of those entrusted with Gisèle’s medical attention but rather reflects a conscious decision on our part to leave that particular issue to others. We acknowledge this decision is open to criticism.
In drawing a direct connection between enabling and the rapes we make the argument the latter was dependent on the former. The website availed Dominique the means and opportunity to create the infrastructure whereby Gisèle was raped over the course of many years. We are not suggesting that absent Coco, the terrible crime at hand would not have occurred. That is an unknown. We are asserting that Coco, as an enabler, was essential to Dominique in the crime he orchestrated. Coco is essential to understanding how he was able to bring men to the house.[12]
The title captures the essence of our undertaking; to fully appreciate the sordid reality of this unimaginable years-long crime requires understanding the significant role of Dominique in the rapes and the website that enabled his criminal behavior. In addition to our focus on enablers, we address two other, related, issues tragically relevant to this case: rape culture and rape by proxy.
None of the men who raped Gisèle forcibly entered the home she shared with her husband, not one was required to use force to overtake her, she was not bound and gagged; there is no documentation of the application of physical force. That is not what this case is. Gisèle was unconscious due to the cocktail of medications Dominique secretly administered to her.
While the men exclusively committed sexual acts upon her, Dominique was solely responsible for the orchestration of each act. Gisèle never consented or gave any indication of understanding what was taking place in the bed she believed to be safe. After all, it was the bed she shared with her husband and to the best of her knowledge, only with Dominique. However, such was not the case. Far from it.
While Dominique will serve a 20-year sentence for his actions, to fully understand the repeated violations on Gisèle’s body demands identifying the enablers. While the Coco website did not assault Gisèle, without it Dominique would not have had the necessary infrastructure. That is not, under any circumstances, to minimize his culpability, for that speaks for itself.
Nevertheless, the carefully planned crime, involving scores of men over many years, was dependent on the enablers. It is, then, under that “umbrella” the issue of enabler culpability will be examined in detail. In doing so, we will recommend mechanisms for holding enablers accountable for their actions and direct contributions to a crime.
The fact that dozens of men raped Gisèle is undisputed. The issue demanding our attention is whether by orchestrating the rape of his wife, Dominique committed rape by proxy, notwithstanding the accepted fact he did not engage in concurrent sexual relations. How we answer this question contributes to our understanding of the harm caused by enablers.
To understand the necessity of expanding our conceptualization of rape to include “rape by proxy,” we must examine the current state of rape law and rape culture in various jurisdictions. While the facts of the Pelicot case are disturbing, there are still some who do not think that Dominique is culpable.[13] Rape culture is pervasive across multiple societies and despite progress in the field of victims’ rights, victims of rape still experience being dismissed, disbelieved, and blamed. What follows is a comparative analysis of how rape is viewed and defined across the world.
To address these issues this Article shall proceed in the following manner: I: Introduction; II: Rape Culture; III: What is Enabling/Who are Enablers; IV: Rape by Proxy; V: The Enabler: Coco; VI: Dominique Pelicot and Rape; VII: Recommendations for Enabler Accountability; VIII: Final Word.
II. Rape Culture
In analyzing the harm caused by enablers in the Pelicot case, it is necessary to examine how rape culture lays the foundation for sexual abuse. Rape culture is a disease that has infected nearly every nation across the globe. Rape culture, simply defined, is a society wherein sexual violence and sexual abuse are normalized and excused. This culture is pervasive and impacts all facets of society: media, popular culture, politics, the judicial system. It is also part of the reason why sexual violence is so widespread.
Rape culture is at the heart of not only the case of Dominique Pelicot, but also every instance of sexual assault. It fosters an environment in which such crimes are justified, and at times are even refused to be acknowledged as a crime at all.
Within rape culture, women in particular are conditioned to believe it is their responsibility to avoid being sexually assaulted or subjected to forms of sexual abuse.[14]
However, rape culture does not solely impact women. It also perpetuates the incorrect belief that men cannot be victims of sexual violence and leads to harsh stigmas on men who come forward with their experiences of assault.
This can be seen in how the criminal justice system struggles to bring perpetrators of sexual violence and abuse to justice compared to other types of crime. Society is often quick to make excuses for perpetrators, or to find a way to shift the blame to the victim of the abuse.[15]
Though the number of sexual assault occurrences is high, the rates of convictions and prosecutions of perpetrators are low.[16] In the United Kingdom, only 1 in 100 rapes that are reported to police result in a criminal charge, let alone a conviction.[17] In 2024, 71,227 rapes were recorded by U.K. police, yet charges were brought in just 2.7% of those cases.[18]
Within a culture that normalizes and justifies rape, the immediate reaction to an individual’s disclosure of being sexually victimized is skepticism, shame, and blame. This response is particularly problematic when juxtaposed with the typical response to other crimes such as robbery, where the automatic reaction is to believe the victim outright and be outraged at the perpetrator.[19]
These reactions to disclosures of sexual abuse significantly contribute to the issue of underreporting in sexual assault cases.[20] When survivors were asked why they did not report to police, 39% responded that they did not think police could help, 35% stated they thought it would be ‘embarrassing’; 25% though the police would not do anything about it, and 24% thought the police simply would not believe them.[21]
Rape culture is also characterized by misconceptions commonly referred to as “rape myths.” These may include misguided beliefs that a woman’s dress or appearance necessarily invites sexual advances (“she was asking for it”) or that a wife is obligated to engage in sexual intercourse whenever he wants to, regardless of her own consent or desire.
It is essential to understand the prevalent rape culture in France in order to fully grasp the gravity of this case. During the trial of Dominique and his co-defendants, many of the girlfriends and wives of the defendants were asked questions by the jury such as “Did [your husband] have fantasies? If so, was he able to ask you to fulfill them?” and “How do you explain that he looked for a sexual relationship outside of your own?”[22]
Even when faced with such a horrific story of what Gisèle Pelicot had suffered at the hands of these men, “women were still made to explain themselves, and made to bear the implication that, if you give your husband the right kind of sex, something like this simply will not happen.”[23] One resident of the town, Mazan, where this occurred stated, “Honestly, no-one here gives a damn.”[24]
The Mazan mayor himself, Louis Bonnet, minimized the severity of Gisèle’s suffering and told BBC that “No one was killed…it could have been worse.”[25] Bonnet then compared Gisèle’s experiences to another case in a nearby town where the woman was raped while conscious. In contrasting the two, Bonnet suggested “[Gisèle’s] rapes were less troubling” and stated because the other victim had been conscious when she was raped, her case was “even more serious” than Gisèle’s.[26]
When the reporter “suggested that [Bonnet] was seeking to play down the gravity of the Pelicot case,” Bonnet responded “Yes, I am.”[27] Bonnet went on to say, “I’m not going to say the village has to bear the memory of a crime which goes beyond the limits of what can be considered acceptable.”[28]
This reaction is not exclusive to the Mazan rape trial, but rather is characteristic of the culture in France.[29] In 2024, more than 140 French public figures signed a petition which claimed France is “abysmally” lagging behind in societal and legal responses to the pervasive problem of sexism and sexual abuse.[30] The petition stated “It’s unacceptable that the rate of dismissals of complaints of sexual violence reached the delirious rate of 94% in 2022.”[31]
Additionally, although France recognized marital rape in 1992, it took until 2006 for marital rape to be considered an aggravating circumstance – though it remains an underreported and under-prosecuted crime.[32]
The Pelicot case sheds light on an aspect of French society, and global society, that many wish to be kept in the shadows: rape culture is deeply rooted in its foundation.
To comprehensively evaluate the enablers in the Pelicot case, it is necessary to first define what and who an “enabler” is.
III. What is Enabling/Who are Enablers
A. Introduction
An enabler is defined as: An individual who knows, or should know, that another individual has been harmed and makes the decision to not act to either minimize harm to that individual and/or to other potential victims. The enabler is not present when the harm is caused but fails to act when information regarding harm is brought to their attention.
B. Categorizing Enablers
Our particular focus is on three distinct forms of enablers: the willfully ignorant, the organizational, and the environmental.
Perhaps for the survivor there is no difference as the consequence is the same; however, in establishing methods and mechanisms of, and for, accountability, importance is attached to distinct categories of enabling behavior. That is particularly important when recognizing the extent to which the perpetrator benefits from the decision-action of the enabler.
The three proposed categories reflect distinct political-social cultures and individual motivations. Willful ignorance would be more suggestive of the latter, whereas organizational and environmental are more reflective of the former, suggesting a more institutionalized interaction between enablers and perpetrators.
Organizational enablers are those within a structure who have authority to ignore or look past the actions of individual(s) and permit their actions to persist. By deciding which individual(s) are more important for a cause or goal, organizations use their power to enable the choices perpetrators make. By doing so, they “protect” the organization and its present and future goals.
Environmental enablers understand the dangers found within a situation or environment and allow them to continue, disregarding the damage which has taken place, and creating the circumstances whereby future harm can occur unabated. Environmental enablers understand, whether implicitly or explicitly, the environment the perpetrator wishes to create and sustain.
Willful ignorance is defined as follows:
1. Willful blindness, or willful ignorance, describes “deliberate avoidance of knowledge of a crime, especially by failing to make a reasonable inquiry about suspected wrongdoing despite being aware that it is highly probable.”2
2. “A person [who] intentionally shields themselves from acknowledging information that might make them liable in a civil or criminal case, even denying these facts to themselves.”
Organizational behavior and organization have been defined as:
1. “Organizational behavior are the actions and attitudes of individuals, groups and structures within an organization that can affect its function and performance.”
2. “A group of people, structured in a specific way to achieve a series of shared goals. Relationships within an organization are determined by its structure and are typically based upon role and function.”
Environmental is defined as:
1. “The conditions affecting the development, growth, or performance of a person or thing.”
2. “All the circumstances, people, things, and events around them that influence their life.”
Categorizing the enablers is not to be misunderstood as excusing one type more than another; they are equally culpable and should be held accountable, regardless which category most accurately defines them. Because of the complexity of the ecosystem’s composition, it is possible a survivor will confront a combination of the three categories. It is incorrect to suggest one category is more harmful or nefarious than another.
With the foundation of enablers laid, we now turn to defining the novel concept of “rape by proxy.”
IV. Rape by Proxy
Rape by proxy is a form of sexual violence characterized by the active participation of an actor who gains sexual gratification from the rape of a person, despite not being the individual who is physically performing the rape. In such cases, the actor is using the individual performing the rape as a conduit for his own sexual gratification. The actor observes, records, and controls the sexual exploitation of the victim by others. Circumstances such as the actor directing the individual what to do and masturbation while observing the rape can serve as evidence of these elements.
An actor is an “active participant” if he is present and in control, which can manifest as directing, orchestrating, or manipulating the situation. There is nothing passive in rape by proxy; the actor is not just letting the individual rape the victim, he is directing them while they do so.
A distinguishing aspect of rape by proxy, as opposed to other multi-participant crimes such as gang rape, is that the actor is gaining sexual gratification despite not engaging in sexual intercourse. In a case of rape by proxy, the actor’s purpose is primarily to obtain sexual gratification, not financial benefits. This is fundamentally different from “pimping,” in which the “pimp” is primarily motivated by money and receives payment in exchange for setting up a sexual encounter between the “john” and the sex worker.
To recognize the need for a recognized crime of “rape by proxy,” we look to the current legal and criminal frameworks in various jurisdictions to identify potential gaps in the law.
A. Legal Frameworks
1. France
Under Article 222-23 of France’s Criminal Code, rape is defined as “[a]ny act of sexual penetration, of any nature whatsoever, committed against another person by violence, constraint, threat or surprise” and is punishably by fifteen years imprisonment.[33] France also recognizes a separate crime of “sexual assault”, which is defined as “any act of a sexual nature committed with violence, coercion, threat or surprise.”[34]
Though French legal provisions on rape and other forms of sexual violence do not reference consent, a draft reform to the legislation was submitted in January 2025 to the French National Assembly.[35] The draft included that “consent must ‘be given freely’, ‘is specific and can be withdrawn before or during the sexual act’, is to be ‘assessed in light of the surrounding circumstances’ and ‘cannot be inferred from the silence or absence of resistance of the person.’”[36]
Dominique Pelicot was found guilty of aggravated rape under Article 222-23 due to his marital relationship with the victim of the crime and received the maximum sentence of 20 years.[37] Forty-eight of Dominique’s co-defendants were also found guilty of aggravated rape, and two men were found guilty of sexual assault.[38]
2. The European Union
The Council of Europe Conventions on preventing combating violence against women, also known as The Istanbul Convention, was ratified in 2014.[39] While the Istanbul Convention gives some discretion to its state parties, “GREVIO has insisted that only a positive consent model (‘yes means yes’) fully satisfied the requirements of the Istanbul Convention.”[40]
The above figure depicts the results of a 2024 Eurostate survey, reporting the percentage of respondents who totally agree or tend to agree with various rape stereotypes.[42] According to this survey, some EU citizens believe that a husband can have sex with his wife without her consent and a significant minority of citizens believe that women often fabricate or exaggerate claims of abuse or rape.[43]
Some of the highest rates of respondents who subscribe to these rape myths are in countries that have not ratified the Istanbul Convention and have not reformed their legislation, indicating that legal reform can have an impact on individuals’ perspectives on rape and attitudes towards victims of sexual abuse.
3. United States Federal Law
Under 10 U.S. Code § 920 – Article 12, a person is guilty of rape when they commit a sexual act upon another person by “first rendering that person unconscious” or administering to that person “without the knowledge or consent of that person, a drug, intoxicant, or other similar substance and thereby substantially impairing the ability of that other person to appraise or control conduct”.[44]
The United States also criminalizes conduct similar to the actions of Dominique Pelicot. According to Subsection (c) of Article 120, a person who “commits or causes sexual contact upon or by another person, if to do so would violate subsection (a) (rape) had the sexual contact been a sexual act, is guilty of aggravated sexual contact.”[45] The term “sexual contact” means:
“touching, or causing another person to touch, either directly or through the clothing, the vulva, penis, scrotum, anus, groin, breast, inner thigh, or buttocks of any person, with an intent to abuse, humiliate, harass, or degrade any person or to arouse or gratify the sexual desire of any person. Touching may be accomplished by any part of the body or an object.”[46]
By including when a person causes sexual contact by another person, not just commits it upon another person, the statute seems to recognize, at least in part, the culpability of an individual who orchestrates the rape or sexual assault of another.
Under United States Federal law, Dominique would likely be charged with “aggravated sexual contact,” rather than “rape,” because while he “cause[d] sexual contact upon or by another person” and that contact amounted to rape, Dominique himself did not “commit” the act on Gisèle.[47]
4. Utah State Law
A person is guilty of rape in Utah if the person “has sexual intercourse with another individual without the individual’s consent.”[48] Utah law recognizes marital rape, and states that this section “applies whether or not the actor is married to the individual.”[49] The default punishment for rape, a first degree felony, is a minimum of five years imprisonment, which may be for life.[50]
However, the mandatory sentence may rise up to a minimum of 10 years if the rape was “committed against an incapacitated individual,” which includes an individual with an intellectual disease or defect, physical disease or defect, neurological disease or defect, or cognitive disease or defect.[51] The mandatory sentence further increases to a minimum of 15 years if during the commission of the rape the defendant caused serious bodily injury to the victim.[52]
Under Utah Code § 76-2-202, a person who acts “with the mental state required for the commission of an offense” and “intentionally aids another person to engage in conduct which constitutes an offense shall be criminally liable as a party for such conduct.”[53]
Utah also recognizes that a sexual act is without the consent of the victim when the actor “intentionally impaired the power of the victim to appraise or control his or her conduct by administering any substance without the victim’s knowledge.”[54]
In Utah, Dominique would likely be charged with rape as a party to the conduct under the theory that he “intentionally aid[ed]” each of the men that he recruited to rape his wife.[55] If convicted, this crime would carry a mandatory minimum sentence of 5 years imprisonment, though that minimum sentence could raise to 10 years if the prosecution were to successfully argue that Gisèle was an “incapacitated individual.”[56]
While the party liability statute provides an avenue for Dominique to be charged with “rape,” it still does not reflect Dominique’s full culpability or his active and domineering role in the crime.
Dominique's role goes beyond the typical accomplice liability. Within a single instance of rape, Dominique was the primary instigator, active participant, and beneficiary of the systematic sexual violence.
Upon establishing the framework for rape by proxy, we may now focus on the enabler, Coco.
V. The Enabler: Coco
A. Introduction
In this Article, we define the website Coco as an enabler. Coco’s importance, perhaps centrality is a more accurate term, to the rape by proxy cannot be over-stated. While the theme of enablers-enabling has been previously addressed by one of us,[57] the role of a website enabling rape by proxy demands special attention. For Pelicot to have committed the crimes required two critical, separate actors: the men who raped Gisèle and the website.
There was an integral, and intrinsic, co-dependence between the two; the connection between the men and Dominique was dependent on Coco. That is the essence of enabling; given the horrors visited upon Gisèle there is, perhaps, no stronger case for criminalizing the act of enabling than what transpired in Mazan, France.
In advocating holding Coco liable for the crime of enabling, our lens is the consequence from the perspective of the one victim, Gisèle. To fully appreciate enabling, it is incumbent to understand the extraordinary harm caused to the vulnerable individual, without the means or resources to protect themselves. That is particularly accentuated when the victim is unconscious.
Founded in 2003 by Isaac Steidl, Coco was created to serve as a “romantic meetings” website.[58] From a seemingly harmlessbeginning,[59] the website with anonymous chatrooms quicklydeveloped into a unique opportunity for online predators.[60] Coco marketed itself as an unregulated, anonymous website; a “website without registration.” As online websites became increasingly regulated after the early 2000’s,[61] Coco offered online users the opportunity of coordinating and committing crimes anonymously.[62]
Coco’s interface functioned similarly to other discussion-based websites like Reddit. There are various threads on different topics that each user could choose to enter. Once clicking on a chatroom’s thread, users could see other comments and posts related to the topic. Additionally, you could message users individually while remaining anonymous.
As discussed below, Steidl’s alleged knowledge is important to our understanding of the website’s role as enabler.
Pictured above is a screenshot of the now-defunct Coco website. The website’s tag line “le chat sans inscription” translates in English to “the chat without registration.”
B. Content Moderation
Content moderation is defined as the structure practice of filtering online content posted by users.[64] The purpose of moderation online is to, “to protect the company’s brand (by enforcing user adherence to site guidelines or rules),ensure compliance with the laws and statutes governing their operations, and contribute positively to maintaining an audience of users willing to upload and view content on their sites.”[65] Content moderation is the first line of defense to protect online users from harmful content by promoting internet safety. It has become a standard practice for online platforms.[66]
C. Registration
Beyond a lack of moderation, Coco required little information from users to open an account.[67] To “register” forCoco, a prospective user had to provide their age (minimum 18) and a username to create an account.[68] However, the user could immediately change their age and username after initially gaining access to the website.[69]
Websites such as Facebook require a name, email or phone number, password, date of birth, and gender to originally register a new account.[70] Additionally, you are often required to confirm your email or phone number to prove your credentials are valid.[71]
D. Criminal Activity
There has been evidence tying online users and their posts to crimes including murder, harassment, drug trafficking, sex trafficking, and child pornography, all of which were easily accessible to anyone with an account.[72]
A 2018 murder in France was planned on Coco. Michel Sollossi, a fifty-five year old, was beaten to death after planning to meet up with a twenty-two year old man. During the trial, the court held the murder was motivated by homophobic ideology and the defendant was sentenced to twenty years in prison.[73]
This is not an isolated case of violent attacks on gay individuals created and planned on Coco.[74] Additionally, there were instances of child rape videos being shared on the same thread Dominique Pelicot created.[75] Pelicot, along with other online users, relied on the website’s lack of moderation to commit their crimes.[76] Isaac Steidl is currently on trial for having knowledge of criminal activity occurring on Coco, and yet continuing to allow users to engage unmoderated online activity anonymously.[77]
He has been formally charged with the administration of an online platform to facilitate illegal transaction by an organized gang, complicity in drug trafficking, complicity in possession and distribution of child pornography images, complicity in corruption of minors via electronic communication, aggravated procuring, participation in a criminal association, and aggravated money laundering.[78]
The offenses Steidl is charged with carry up to ten years in prison each and complicity in drug trafficking can carry a fine up to 7.5 million dollars.[79] Several of Steidl’s bank accounts were frozen, and up to 5 million euros were seized in total.[80] Additionally, three of his relatives are being questioned for playing an active role in the administration of Coco or benefitting from the criminal activity occurring on it.[81]
France passed a law in January 2023, aiming to hold website administrators accountable; Steidl’s case is the first time it is being employed:
The new law allows the authorities to prosecute people who run the platforms and knowingly permit illegal content, goods or services to be exchanged while also requiring users to remain anonymous or while failing to keep certain user data.[82]
According to Maître Nathalie Bucquet, a French lawyer, “the mere knowledge of the illicit nature of the content justifies criminal liability on the part of the administrator.”[83]
Dominique utilized an existing chatroom thread called “à son insu,” which translates in English to “without her knowledge.”[84]
On this chatroom thread, he would post photos of Gisèle, in order to solicit other men. Hewrote on the threadthat the two of them had a fetish for other men having sexual intercourse with Gisèle while she was asleep.[85]
That being said, there is little proof that these men truly believed this was consensual.[86] Messages sent to Pelicot by other users on Coco included things like “I dream of doing the same to my wife and sharing her with accomplices like you.”[87] Additionally, when Pelicot would reach out to these men on Coco, he would state, “I’m looking for a pervert accomplice to abuse my wife who’s been put to sleep” or “You’re just like me, you like rape mode.”[88] All of this suggests that these men were fully aware of the non-consensual nature of their sexual relations with Gisèle.
Once he found a user interested in meeting, Dominique would often use Skype to continue coordinating.[89] There was never a monetary exchange between Dominique and the men he would recruit. He was doing this simply for his own satisfaction. From Caroline Darian’s book, I’ll Never Call Him Dad Again, we learn that Dominique was severely in debt and could have benefitted from receiving money in exchange for offering up his wife, but he never did.[90]
The chatroom existed for at least ten years,[91] enabling Dominique’s rape by proxy to continue.[92] Coco, in rare cases, banned accounts when there were either “complaints or legal threats” made against users. Coco allowed users to re-gain full access to after paying a small fee.[93] The fact Isaac Steidl created a system in which an individual could pay a small fee to reinstate their banned accounts is evidence Steidl knew of criminal activity taking place on his platform and intentionally created the means for such activity to persist even after preventative action.
According to French authorities:
In the unlikely event that a user did get kicked off Coco due to complaints or legal threats, researchers and authorities say the site would charge a small fee of about €10 to reinstate banned accounts.[94]
Isaac Steidl’s arrest was made in January 2025;[95] his trial is currently ongoing.[96] French authorities seized Coco in 2023, almost three years after Dominique’s initial arrest revealed his criminal activity on this website. In addition to the Pelicot case, French authorities stated the website has been implicated in 23,051 criminal cases prior to being shut down.[97]
The question remains: why did it take so long to shut it down?
E. Legislation
EU and domestic legislation has been enacted placing greater responsibility on websites to moderate all posted content.[98] In writing this Article, we engaged with the Irish law firm, McCann Fitzgerald, who have published content regarding the Harassment, Harmful Communications and Related Offenses Act of 2020,[99] or more commonly known as, “Coco’s Law.”[100] This law was passed after a tragic suicide resulting from harassment on online platforms.[101]
From this interview, we gained insight on how legislation is shared and enforced across European Union countries. Domestic laws regulating online content vary by country, making it difficult to moderate online activity that goes beyond borders. Therefore, The Digital Services Act was passed to address these gaps.[102]
The 2022 Digital Services Act (DSA)[103] was passed by the European Union to create a more uniform standard of responsibility for online platforms transnationally:
New rules introduced in the DSA is creating a fairer and safer online world.
Currently, there is no consistent flagging system for when you see illegal content, goods or services online. The DSA makes it easier for you to report illegal content, such as hate speech, and goods such as counterfeit products by introducing mandatory user-friendly flagging systems.
Platforms need to process alerts in a timely and diligent manner and keep you updated. You should also have clear information about whom you’re buying goods or services from online.
Cyber bullying and cyber violence are an increasing problem for children and adults alike. The DSA introduced stronger protections for people targeted by online harassment and bullying. This includes making sure any non-consensual private images and other abusive, illegal content that are shared can be quickly flagged by users.[104]
Each member state of the European Union must transpose the DSA into their domestic legal code individually within a certain period of time.[105] These examples of legislation confirm the criminal culpability of website platforms failing to protect their users, despite having the knowledge of criminal activity.[106] Although this progress is important, there is still work to be done. There have been “copycat” websites that have been battling to stay online, despite several legal threats.[107]
Dominique Pelicot would never have been as successful in raping his wife by proxy for so long without the lack of website content regulation on Coco enabling the seemingly endless perpetuation of his crimes to continue. Additionally, without any legislation that criminalized Dominique’s sexual abuse of his wife, there is little justice to be given.
VI. Dominique Pelicot and the 50+ Other Rapists: Perpetrator Analysis
A. Systematic Elimination of Victim Autonomy: The Architecture of Control
The Pelicot case represents a paradigmatic example of how domestic abusers systematically dismantle their victims' autonomy through multiple, reinforcing mechanisms of control. The evidence reveals that Dominique Pelicot's decade-long campaign of sexual violence was facilitated by his methodical elimination of every avenue through which Gisèle might have detected, resisted, or escaped the abuse. This systematic approach to victim subjugation demonstrates the intersection of traditional domestic violence tactics with unprecedented technological and chemical methods of control.
1. Isolation as a Foundational Control Strategy
Isolation emerges as the cornerstone of Dominique Pelicot's control strategy, representing what domestic violence scholars recognize as "a powerful tool used by abusers to control and manipulate their victims, making it difficult for them to seek help or escape."[108] The systematic nature of this isolation was revealed through family testimony, particularly that of son-in-law Pierre Peyronnet, who described the family's mounting concern about Gisèle's rapidly deteriorating health and "the difficulty in reaching out to her."[109] The family found it "very difficult to get her on the phone, and most of the time it was [Dominique] who answered, explaining that Gisèle was asleep, even in the middle of the day."[110]
This pattern of controlled communication represents what French jurisprudence under Article 222-14-3 of the Penal Code recognizes as psychological violence within couples, specifically the systematic restriction of social contact.[111] The European Court of Human Rights, in its landmark decision Opuz v. Turkey (2009), established that states have positive obligations to prevent and punish such isolation tactics as core components of domestic violence.[112] The Istanbul Convention, ratified by France in 2014, further mandates recognition of psychological violence, including isolation, under Article 33.[113]
The isolation acquired deeper significance when considered through the framework of victim-vulnerability theory. Building on Benjamin Mendelsohn’s foundational notion of “latent victims,” Gisèle’s situation illustrates how structural conditions generate inherent exposure to victimization.[114] Henri Ellenberger further developed this idea by identifying women as belonging to categories predisposed to victimization, rendering them especially susceptible to predatory behaviors within conjugal relationships.[115]
Likewise, Hans von Hentig’s pioneering work underscored that certain individuals are more vulnerable to victimization owing to biological, sociological, and psychological factors-with women, children, and the elderly singled out as particularly at risk.[116] The legal framework surrounding isolation as abuse has evolved significantly across European jurisdictions. The UK's Domestic Abuse Act 2021 provides comprehensive recognition of controlling or coercive behavior, specifically including the isolation of victims from support networks.[117] Germany's Protection Against Violence Act (Gewaltschutzgesetz) similarly recognizes isolation tactics as grounds for protection orders.[118]
The European Union's 2022 proposal for a directive on combating violence against women explicitly includes "isolating the victim" as a form of psychological violence requiring criminalization.[119] Research moreover demonstrates that systematic isolation serves multiple functions within abusive relationships. The Family Violence Appellate Project identifies that isolation prevents detection by removing witnesses, eliminates support networks that could provide assistance or intervention, and creates psychological dependency that makes escape seem impossible.[120] The U.S. Department of Justice defines isolation comprehensively as including "psychological manipulation, cutting off social ties, restricting communication, and financial control."[121]
The Pelicot case reveals an additional dimension to isolation tactics - the role of age in creating invisibility. Gisèle's mature age may have contributed to the invisibility of her situation, as noted in criminal victimization literature: "If the doctors she consulted didn't make the connection between her symptoms and rape, it's perhaps because we tend to believe that victims of sexual assault and rape are younger women."[122] This represents what scholars identify as an unthought-of criminal reality - the victimization of older women remains largely invisible in both medical and legal contexts, representing a significant gap in understanding victimization patterns.[123]
French medical professionals are legally required under Article L. 2212-2 of the Public Health Code to screen for domestic violence, yet the case demonstrates systematic failures in recognizing victimization patterns among mature women.[124] This failure reflects broader societal assumptions about who constitutes a "typical" rape victim, assumptions that the Pelicot case has fundamentally challenged. The case has prompted discussions within the French medical community about improving training for recognizing signs of abuse among older patients, particularly those presenting with unexplained fatigue, memory loss, and other symptoms consistent with chemical submission.[125]
2. Financial Control and Economic Dependency as Instruments of Subjugation
Economic abuse represents one of the most pervasive yet underrecognized forms of domestic violence. The National Network to End Domestic Violence establishes that financial abuse occurs in 99% of domestic violence cases and that concerns over their ability to provide financially for themselves and their children was one of the top reasons for staying in or returning to an abusive partner.[126]
While the Pelicot case record does not explicitly detail financial abuse, the systematic nature of Dominique's control over his wife's life, particularly her chemically induced unconsciousness that left her unable to maintain awareness of her circumstances, effectively eliminated her financial agency and decision-making capacity. Both were retired elders and not anymore involved in professional activities, Dominique Pelicot having taken charge of the management of the revenues from their pensions, the financial intendance of the household.
The legal definition of economic abuse has expanded significantly in recent years. The UK's Domestic Abuse Act 2021 provides the most comprehensive legal framework, describing economic abuse as any behaviour that has a substantial adverse effect on a victim's ability to acquire, use or maintain money or other property, or obtain goods or services.[127] This definition encompasses both direct financial control and indirect methods that impair economic autonomy.
French law has similarly evolved to recognize economic violence. Article 222-14-3 of the Penal Code, strengthened by the 2019 Grenelle contre les violences conjugales, now explicitly includes economic control as a form of psychological violence.[128] The law recognizes that economic abuse "involves the control of a partner or ex-partner's money and finances, as well as the things that money can buy" and "can include exerting control over income, spending, bank accounts, bills and borrowing."[129]
The European framework has also advanced significantly. The Istanbul Convention requires states to recognize economic violence, with Article 3(b) defining domestic violence to include economic harm.[130] The European Union's 2022 proposal for a directive on combating violence against women specifically mandates criminalization of controlling financial resources or preventing economic independence.[131]
California's legal framework exemplifies recent advances in recognizing financial control, with Family Code provisions defining coercive control as controlling, regulating, or monitoring the other party's movements, communications, daily behavior, finances, economic resources, or access to services.[132]
Research utilizing the Legal Abuse Scale (LAS) demonstrates that financial control represents a distinct factor in legal abuse patterns, with perpetrators systematically using court processes and financial manipulation to maintain control.[133] The conjugal context indeed creates particular vulnerabilities for economic abuse. Legal scholars note that by denying the victim access to money, such as forbidding the victim from maintaining a bank account, he or she is totally financially dependent upon the abuser for shelter, food, clothing and other necessities.[134]
The Office on Violence Against Women identifies that a large majority of cases of domestic abuse involve economic abuse and that this type of abuse is designed to create economic instability and/or make one partner economically dependent, which evidently limits their freedom.[135] In the Pelicot case, the chemical submission created a unique form of economic incapacitation. While traditional economic abuse involves overt control of financial resources, Dominique's systematic drugging rendered Gisèle incapable of monitoring, accessing, or controlling any financial resources.
This represents an extreme form of what the French Council of State defines as economic dependency, which is legally recognized as an aggravating circumstance under Article 222-8 of the Penal Code when violence occurs within couples.[136] The inability to maintain consciousness during daylight hours, as testified by family members, would have made any independent financial activity impossible.
B. Dominique as Rapist and Orchestrator
1. Rape by Proxy and the Technology of Sexual Exploitation
Dominique Pelicot occupied a dual role as both direct perpetrator and orchestrator of systematic sexual violence, creating what can be characterized as rape by proxy - a form of sexual violence where the primary perpetrator derives gratification not only from direct participation but from observing, recording, and controlling the sexual exploitation of the victim by others. This represents an evolution in criminal behavior that leverages technology to create new forms of sexual violence and exploitation.
The systematic nature of Dominique's orchestration was revealed through digital evidence that demonstrated meticulous planning and documentation. Police discovered more than 20,000 photos and videos on his computer drives, in folders titled 'abuse,' and 'her rapes'.[137] This vast archive was meticulously documented, labeling each by name and date and tucked into a master folder titled 'Abuse.'[138] The prosecution established that this trove of images allowed them to uncover a widening circle of abusers, demonstrating how the documentation served both as personal gratification and as evidence facilitating the prosecution.[139]
The recruitment process revealed sophisticated use of technology to facilitate sexual crimes. Dominique would select his co-perpetrators by communicating with them first on Coco's private messaging system, then on Skype where he detailed how they would proceed.[140] Investigators found Skype messages in which he boasted of drugging his wife, demonstrating how digital platforms enabled both the coordination of crimes and the perpetrator's psychological gratification through sharing details of his victims' subjugation.[141]
During his trial testimony, Dominique acknowledged that he had raped his wife two or three times a week, either alone or with someone else.[142]
This admission reveals the systematic and ongoing nature of the sexual violence, with the orchestrated assaults by others supplementing rather than replacing his direct participation. The frequency and regularity of these assaults, combined with their documentation, created what criminal law scholars recognize as an ongoing criminal enterprise.[143]
The analysis of this behavior through criminal theory reveals several critical dimensions. First, it represents what can be understood as what we could name a crime of ownership, where the accused behaved like the owner of property that he made available to other individuals so they could enjoy it. This resonates with historical legal frameworks that treated women's bodies as male property in sexual assault cases, concepts that modern criminal law has explicitly rejected.[144] This conceptualization reflects deeply embedded patriarchal notions of marital ownership, where the husband views his wife's body as his possession to be controlled, distributed, and exploited.
Second, Dominique Pelicot's method represents an externalization of criminal acts through accomplice recruitment. This externalization created a commodification of sexual violence, where the victim's body became a resource distributed within a network of predators – despite the fact that no money was exchanged. The systematic nature of this exploitation was so comprehensive that, had monetary exchange been involved, it could have qualified for additional charges under Articles 225-5 and 225-7 of the French Penal Code.[145]
The European legal framework provides additional context for understanding this behavior. The European Court of Human Rights has established in cases like Siliadin v. France (2005) that states have positive obligations to criminalize and prosecute forms of sexual exploitation that involve systematic control over victims.[146] The Council of Europe Convention against Trafficking in Human Beings defines exploitation to include sexual exploitation, which could encompass the systematic distribution of a victim for sexual purposes even without monetary exchange.[147]
This configuration pushes the concept of polyvictimization beyond its usual empirical and doctrinal contours. In criminological and victimological literature, polyvictimization designates exposure to multiple forms of victimization over time, often dispersed across perpetrators, settings, and institutional failures. In the Pelicot case, however, the multiplicity of offenses is neither episodic nor situationally fragmented. It is structurally unified, temporally extended, and centrally coordinated.⁴³ The victim is not merely subjected to repeated harms, but enclosed within a deliberately engineered system of victimization, in which repetition itself becomes the mode of domination.
This systematic character challenges the traditional legal framing of plurality of offenses as either a series of independent crimes or a cumulative aggravating factor. Here, plurality operates as a constitutive element of the wrongdoing. The husband’s role is not exhausted by participation or facilitation; it is one of orchestration, converting multiple third-party assaults into a single, continuous criminal enterprise directed at one person. The legal harm thus exceeds the additive logic of multiple counts. It concerns the destruction of the victim’s autonomy, security, and bodily integrity through sustained exposure to interchangeable perpetrators within a closed environment she could not escape.
From a criminal law perspective, this raises acute questions about authorship, unity of offense, and aggravated liability. The organizing agent exercises a form of control analogous to that found in organized crime or joint criminal enterprise doctrines, yet the object of that enterprise is not illicit profit or collective violence, but the instrumentalization of one individual’s body. This suggests that existing categories—such as complicity, co-perpetration, or habitual offending—may be insufficient to capture the normative gravity of orchestrated polyvictimization. What is at stake is not only repetition, but the transformation of the victim into a stable site of exploitation.
More broadly, the case invites a reconceptualization of polyvictimization as a legal category rather than merely a descriptive or epidemiological one. When polyvictimization is systematically produced by a controlling agent, within a single relational and spatial framework, it implicates duties of heightened protection, evidentiary reclassification, and potentially new forms of aggravation grounded in domination rather than multiplicity alone. The Pelicot case thus exposes a blind spot in criminal law: its difficulty in naming and sanctioning forms of violence that are neither singular nor serial in the usual sense, but structurally totalizing.
As Dominique testified in court: "'I am a rapist, like the others in this room.'"[148]
This explicit acknowledgment of his role as both direct perpetrator and orchestrator establishes clear criminal liability under French law. However, the spectator element provided him with ongoing gratification through both live observation and subsequent review of recorded material, creating a continuous cycle of sexual violence that extended far beyond the physical acts themselves.
French criminal law recognizes various forms of participation in sexual crimes. Article 121-6 of the Penal Code establishes that "the accomplice to the offense, in the meaning of Article 121-7, is punishable as a perpetrator.[149]
However, Dominique's role transcends traditional categories of accomplice liability, as he was simultaneously the primary instigator, active participant, and beneficiary of the systematic sexual violence. This has prompted examination into whether existing frameworks adequately capture the complexity of technologically-mediated sexual exploitation.
C. Legal Parallels and Reform
The Pelicot case therefore prompted immediate legal reform in France. Parliament passed a bill to expand the legal definition of rape centered around one, vital word that has previously been absent from sexual assault legislation: consent.[150] As one legislator noted, "We would not be here without the Pelicot trial. It revealed how big rape culture is in France and, because of that, it became politically unacceptable to not change something in the law."[151]
This legal evolution reflects broader international trends toward consent-based definitions of sexual assault, moving away from traditional force-based models that failed to address cases involving unconsciousness, intoxication, or other forms of incapacitation.[152]
Further legal and social reform are required to prevent future instances of sexual violence and abuse akin to the Pelicot case. What follows are our recommendations for holding accountable the enablers of these crimes.
VII. Recommendations for Enabler Accountability
A. Introduction
To understand the essence of this case requires stepping back from the actual attacks on Gisèle which we have addressed at length elsewhere. The power of the theory regarding “rape by proxy” speaks for itself. It is a unique contribution of this Article, reflecting the unimaginable reality the most vulnerable of victims faced.
Not only was Gisèle drugged by her husband, but she was raped by men who took full advantage of her under the strict and exacting guidelines loudly demanded by Dominique, while he was gratifying himself.[153] This has been carefully and thoroughly documented in the proceeding sections.
While those actions are criminally and morally beyond egregious, for which incarceration is the appropriate result, in this section we circle back to what we addressed in Section III. The uniqueness of this case is the powerful combination of rape, rape by proxy and the act of enabling. Given the consequences of enabling, failure to criminalize the act all but guarantees the success of the next Dominique Pelicot.
While there is no question regarding the criminal behavior of Dominique and those who raped Gisèle, demanding accountability for enabling is a necessary condition for protecting the vulnerable. The duty to protect Gisèle, and future victims, would be significantly enhanced were the enabler held criminally accountable.
Notwithstanding the traditional focus on those who are perceived as having caused the greatest harm, whether physical, emotional, or mental, the accountability we recommend be exacted from the enabler suggests a re-framing of the criminal law paradigm. In making this recommendation we recognize the challenges, and perhaps discomfort, in recommending the failure to act on behalf of the vulnerable be framed as a crime, and therefore subject to criminal sanction.
However, framing this action - for failure to act is an action - as limited to moral failure does an injustice to the individual in need of protection. The proverbial “slap on the wrist”, not only fails to protect the specific vulnerable individual and thereby prevent a known, identifiable harm, but it directly contributes to future injury, whether to the same individual or another, thereby freeing the enabler from additional crimes as well.
B. Criminal Law: The Principle of Deterrence
A principal tenet of criminal law is deterrence, defined as:
There are two categories of deterrence, specific (or simple) and general. Both involve the idea that the threat of punishment will influence individuals not to commit crimes. Specific deterrence focuses on the individual and rests on the assumption that if the punishment imposed on a specific offender is severe enough for a crime, the offender will not commit crimes in the future. General deterrence focuses on society and is based on the idea that potential offenders will be deterred by the fear of being punished. Both categories of deterrence are based on the assumptions that potential offenders are rational and will perceive the possible punishment for crime as painful.[154]
Notwithstanding legitimate debate regarding the effectiveness of deterrence,[155] relying on moral reprobation[156] exclusively when viewing harm from the victim’s perspective falls far short in considering means of holding the wrongdoer accountable. While the effectiveness argument has been the subject of much discussion,[157] our exclusive focus is on two victims: the immediate and the potential, future subject of an attack.
From the victim - present and particularly future - perspective, the important discussion regarding deterrence effectiveness is less pertinent than the immediate need to protect and the requirement to develop measures facilitating such an undertaking. Saving just one victim through deterrence is significant. Whether this is akin to “the ends justify the means” is a legitimate query, if not concern, in the context of an unnecessary and unwarranted expansion of the criminal law.[158]
According to the Talmud, “Whoever saves a single life is considered by scripture to have saved the whole world.”[159] While not ignoring voices of hesitation regarding expansion of the existing criminal code,[160] the harm caused Gisèle by the twin forces of perpetrator and enabler justifies expanding what we recommend be framed a criminal act.
Focusing on protecting two categories of vulnerable victims - present and future - exclusively relying on a moral code falls short.[161] The concept, while perhaps reflecting self-comfort, if not self-indulgence, encapsulated as “we are good people”[162] who “know what to do”[163] fails the individual being attacked, both in the moment and the subsequent failure to hold those responsible accountable. Albeit different standards of accountability,[164] reflecting distinct cultural, religious, institutional, and personal norms and values, the critical inquiry must focus on victim expectation-protection.[165]
Absent accountability and enforcement, mere words are useless.
C. Coco: The Crime of Enabling
At its most basic level, the way Dominique orchestrated the rape of his wife required the conjoining of forces directly benefitting from the crime of enabling. As we discussed in Section V, the website Coco provided the tools by which the crime could be initially planned, subsequently executed. While there is no suggestion any individual directly associated with the website benefitted from sexual engagement with Gisèle, this must not be equated with freeing them of responsibility for the enabled crimes. Failure to hold those responsible for the website accountable before a court of law fails the two categories of victims.
Reliance on the harsh glare of the court of public opinion, while doubtlessly unpleasant for some, is insufficient from the three perspectives of accountability, victim expectation, and deterrence.
To understand the significance of victim expectation, and therefore the need for actual accountability in a court of law, requires recognizing the consequences from the perspective of the harmed individual. To carry weight, accountability be tangible and concrete, extending well beyond “spin masters” and forced apologies. That was repeatedly articulated by Larry Nassar survivors,[166] who were disdainful of public statements by enablers (USAG), articulating concern years after the harm, “ensuring” their commitment to the health, safety and welfare of present-day competitors.
Bullshit.
Those empty words are just that, empty.
To think otherwise is to misunderstand the harm from the victim’s perspective, providing the enabler a convenient “out”, reflecting nothing more than public positioning, devoid of any tangible consequences. The recommendation to hold enablers accountable before a court of law would directly address what is, too date, a systemic failure to demand consequences from those without whom their action, injury could not have occurred.
To limit accountability to the public arena for the enablers failure to protect innocent victims, is commensurate to a meaningless “slap on the wrist” and an insignificant look of disapproval. It all but guarantees future harm while callously dismissing the injury to the present victim.
In the same manner Coco ensured Dominique could orchestrate what transpired in the Pelicot home, USAG officials guaranteed Nassar unlimited access to Mattie Larson’s body. Mattie’s words, “who the fuck sends a 14-year-old alone to a man’s hotel room at night,”[167] powerfully captures the need not for public castigation but rather criminal accountable. The second part of her previously referenced comment, “what do they think is going to happen”[168] is the bellwether in highlighting the utter vapidness of the court of public opinion.
Were USAG, or any other enabler, truly concerned about the consequences of their actions, then an adult would have accompanied Mattie to Nassar’s hotel room with the singular purpose of protecting her. The reader is reminded, Mattie was a child, for whom USAG had direct responsibility for her health, safety, and welfare. The failure to protect when the duty is absolute reflects a consequence free paradigm from the enablers perspective when accountability is non-existent.
Had USAG officials been subject to criminal prosecution for the crime of enabling, the assumption is their actions would have been significantly different with a distinct focus, not only regarding Mattie but also those who competed subsequently. That is the essence of deterrence, notwithstanding the previously referenced lack of consensus regarding its effectiveness.
The prioritization of the public’s perception - glare notwithstanding - is largely performative, devoid of any meaning or significance. Victim expectation of consequences for those without whom the harm could not have occurred demands our attention; Tiffany Thomas’s “they (the enablers) are fucking choking me”[169] is a powerful and painful j’accuse compellingly highlighting the need for actual, consequential accountability.
There is a direct relationship between the three, particularly when viewed from the perspective of failing to prevent predictable future harm. There is no indication Dominique considered stopping his criminal conduct; rather, all evidence suggests his intent was to continue unabated, without remorse or second thought.[170]
In that context, viewing the actions of the culpable individuals through the lens of morality fails Gisèle and enhances the vulnerability of future victims given the lack of actual accountability. To expect criminals such as Dominique, and actors such as those responsible for enabling his conduct, to be deterred by public castigation is to fundamentally misunderstand the essence of what Gisèle faced the nights she was drugged and raped.
It is through the narrow lens of what transpired in her bedroom, within what should be the safety of her own home, this critical issue must be considered. The forces Gisèle faced were relentless, focused, and determined. She never stood a chance. The partnership-whether solidified by agreement or virtual and unspoken-that brought dozens of men to her bed over the course of years had one goal: to rape an unconscious woman.
The fact she happened to be the orchestrator’s wife is nearly unfathomable and only accentuates the rape culture[171] aspect of this case. What is critical when examining the tension between legality and morality is inquiring both accountability and consequences. That is relevant to three distinct crimes committed by the three actors that were present - tangible and intangible -when she was violated: rape, rape by proxy, and enabling.
The interlocking relationship between the three[172] ensured the crime could be committed literally in perpetuity, if not for Dominique’s arrest unrelated to this crime.[173] Re-stated: if not for the unrelated act of “upskirting” in a supermarket, the rapes of Gisèle would have continued owing to the tripartite joining of three forces. Whether this can be defined as an alliance is, in all probability, an exaggeration.
What is not an overstatement is the requirement on society to recognize absolute immorality cannot be held accountable exclusively through the comfortable (even if the facts are uncomfortable) lens of morality. The sentences imposed on Dominique and the 50+ rapists he solicitedthrough the website Coco is more in line with a criminal enterprise or conspiracy.
Understandably proving such a case would be a “stretch.” However, this must not be construed as not acknowledging the reality of this case: organized rape over years of a drugged, unconscious woman. The fact her husband was the mastermind does not minimize the criminal actions of what, if the law were so structured, could be framed as co-conspirators. The act of enabling, presently not subject to the criminal code, was critical to the rapes. The relationship between Dominique and Coco (even if never by formal agreement) was as critical to the crime as were the interactions between Dominique and dozens of men.
The failure to view the two interconnected relationships exclusively as criminal is disingenuous, minimizing the deliberate actions, profoundly disrespectful to Gisèle, and a recipe for future harm to future victims. Efforts to frame this as a moral failure is to fundamentally misunderstand the reality of how at least 50 men raped Gisèle. There must be no tolerance for attempts to frame the ecosystem as anything but criminal; any other articulation of must be met with a vehement and loud: NO!
This is not to suggest an extremist perspective on our part;[174] quite the opposite. Our exclusive focus in this Article is to demand accountability for all responsible actors as we eschew attempts to frame this as a question of morality and the consequent, “moral failing,” Beyond profoundly disrespectful to Gisèle, it perpetuates rape myths,[175] facilitates “copy cats,”[176] and casts the victim as subject to a paradigm akin to “boys will be boys.”[177]
Accordingly, as we have argued in this Article, what transpired in the Pelicot home was criminal for which all involved - perpetrators and enablers - must be held criminally accountable. There cannot be tolerance of any other framing of systemic rape of an unconscious woman, possible only because of a well-organized ecosystem.
Dominique’s violation, while beyond reprehensible, must be understood in the larger context to fully appreciate the requirement to hold enablers criminally accountable. While the severity of the actual rapes is unquestioned, the significance of this case extends beyond the physical acts of Dominique and those who physically penetrated Gisèle. Their punishments are fully in accordance with the rule of law, reflecting the severity of their actions, efforts to explain notwithstanding.[178] However, to focus - without minimizing the harm - exclusively on what transpired in the bedroom is to miss the larger, more significant aspect of this case.
A constant refrain articulated by sexual assault survivors when recognizing the harm was preventable had enablers acted to protect them rather than the perpetrator is deep anger at the former.[179] That anger is fully justified, largely in the “but for” context; “but for” the enabler, the perpetrator would not have had access to their body.
Without the website, Dominique would not have been able to establish - much less conduct - without fear of being “outed,” the criminal enterprise at the root of this case. The safety Coco provided Dominique ensured the continuation violation of the drugged and unconscious Gisèle; the name of the chatroom, “without her knowledge,” is the most honest and telling raison d’être of its owners.
Their actions are a direct reflection of the clearly stated phrasing. To suggest otherwise is duplicitous and to ignore what Dominique clearly understood when he found a platform aligned with his carefully planned attacks on Gisèle. In the spirit of “leaving nothing to chance”, the platform with its phrasing provided Dominique the structure to violate Gisèle. It was a perfect, “too good to be true,” alignment, enabling over 50 men to rape an unconscious, drugged woman who never suspected her husband would deliberately orchestrate strangers violating his wife.
Without minimizing the severity of Dominique’s criminal conduct, the facts in this case raise issues extending beyond the physical. To truly understand its unique importance requires recognizing the extraordinary infrastructure Gisèle confronted, without having any awareness of its existence.
The act of enabling was the mechanism whereby an extraordinary ecosystem was created, fostered, honed, fine-tuned, and ultimately implemented. A careful reading of available material[180] highlights the careful, thorough, and deliberate planning required to ensure the rapes would be undetected.
The ecosystem, with Dominique at its epicenter, incorporated multiple moving pieces, whose purpose was specific, deliberate, and clear. There was an unconscious woman in bed. She was the sole focus of those who came to rape her. That interaction was dependent on the enablers who committed the act of enabling.
When considered from Gisèle’s perspective - or any other sexual assault survivor - to fail to criminally prosecute those who are integral to the ecosystem is to disparage the harms they have suffered. While the media focus on Dominique[181] is understandable, it falls short for it misses the more compelling, albeit subtle criminal act committed by those who never met, much less touched Gisèle Pelicot. The word “compelling” is intended to signify the gravity with which enabling must be understood.
As we have carefully documented in this Article, it was essential to the crimes of rape by proxy and rape; the inter-dependence between the distinct acts is absolute. To fully appreciate what transpired in the Pelicot home requires recognizing the direct connection between the three separate crimes. From Gisèle’s perspective, the crime of enabling cannot be dismissed as a minor piece. The graph below depicts the interconnectivity of the three crimes at the heart of this case.[182]
D. A Call to Legislators
While criminalizing poses challenges to legislators, particularly the perception that enablers are committing an act of omission, this case highlights the consequences of enabling. Coco cannot be framed in the lens of omission, quite the opposite. Their actions, whether establishing the platform and allowing the existence of forums titled “without her knowledge,” are an act of commission.[183]
To frame it otherwise is to give the enabler the benefit of the doubt, facilitating the avoidance of accountability and subsequent punishment. That must not be tolerated if the primary focus is protecting vulnerable individuals. It is irrelevant whether the individual knows they are at risk, subject to egregious criminal violations.
What must serve as the determining factor are the actions of the individual identified as the enabler, regardless of the victim’s knowledge. In the matter before us, the harm imposed on Gisèle - without her knowledge - is the most compelling evidence of the consequences of the act of enabling. The three distinct actors, committing three separate crimes, over the course of at least ten years, were not engaged in a criminal conspiracy as defined by the law;[184] however, the rapes were dependent on the website in its capacity as enabler.
Any other construction of the events is to gainsay what directly contributed to the violations of Gisèle’s body. That is not to minimize the actions of Dominique and the rapists; rather, it is to demand accountability for an additional category of actors whose actions were instrumental to the rapes.
Legislators, confronted with the challenge of omission/commission delineation must approach the question regarding criminalizing enabling from the particular focus of preventing harm to the vulnerable. That approach will lend itself to a recognition of the harm caused by enablers and the requirement to hold them accountable.
A victim-centric focus[185] compellingly highlights the harm caused by enablers, regardless of the fact they did not come in physical contact with the individual. In recommending the criminalization of enabling, the intent is not to unnecessarily expand the criminal code; rather the sole purpose is to more effectively deter, while simultaneously enhancing protection of a vulnerable individual.
Gisèle Pelicot, repeatedly violated in her bed by her husband and dozens of men, was unaware of the harm imposed on her unconscious body. That was only possible because of the platform provided by Coco, fully utilized by Dominique. Whether Coco intended for Dominique to commit the crimes he did is irrelevant in applying the enabler test. What is critical in holding the enabler liable before a court of law is determining the consequence of their actions and the subsequent need for accountability.
At its core, the platform’s name clearly signaled intent and capability, offering Dominique the means for the crimes he committed. Absent the website, which clearly advertised its purpose and capability, Dominique would not have had reason to engage with Coco. However, as the evidence makes clear, engage he did.
Accordingly, we recommend legislators recognize the harm enablers cause to vulnerable individuals and accordingly criminalize the act of enabling thereby ensuring accountability. Survivors repeatedly emphasize financial compensation does not address harm caused nor does it prevent future injury.[186] Perhaps, quite the opposite.
As has been repeatedly documented, in many instances the financial compensation is not paid by the relevant institution, rather by an insurance company.[187] While perhaps reflecting the relationship between the two parties, a monetary award does not address the harm beyond an immediate case and a specific victim. That is a critical distinction between the consequences of criminalization, and a financial settlement predicated on a civil suit.
Legislators owe vulnerable individuals the duty of care and protection. That obligation is not met when acts of enabling are erroneously - perhaps deliberately - framed as a moral failure. Such framing not only fails to address the crime committed but minimizes the deep injury to the victim. From the victim’s perspective, the harm caused was not only a moral failure by the perpetrator but a criminal act demanding punishment.[188]
The critical question, which this case dramatically and painfully highlights, is the requirement to incorporate in the category of criminal actors those who never directly engaged with the victim. While those responsible for Coco may have been aware of Dominique’s criminal behavior, it goes without saying Gisèle had no knowledge of the website. Whether Coco did, or did not, have knowledge of the crime Dominique was committing, the platform the website provided is sufficient in assessing their culpability and the consequent requirement to demand their accountability.
A potential claim of ignorance by the website owners regarding how the platform was used by Dominique would be easily refuted. The terminology made clear the forum’s purpose: “without her knowledge.” In the context of enabling, this is a clear example of a crime of commission; to suggest otherwise is to protect the actor, while enhancing the vulnerability of individuals such as Gisèle. The crime of enabling is, undoubtedly, one step removed from the actual physical interaction between the perpetrator (Dominique) and victim (Gisèle); there is no intention to equate the two.
However, from the perspective of understanding the manner in which Dominique was able to commit the crime of “rape by proxy”, his dependence on the website was absolute. Dominique’s ability to recruit men to his home to rape his drugged wife was dependent on the platform, “without her knowledge.” That is the essence of the crime of enabling for which Coco must be held accountable.
A failure to act on behalf of future victims - whose vulnerability is significantly enhanced by the acts of enablers - will have inevitable consequences. The intent is not to suggest criminalizing enablers will prevent any future acts of rape and “rape by proxy”; such a claim would be irresponsible.
It is, however, intended to create the mechanism whereby those whose “contribution” to crimes such as in this case have been, from their perspective, “cost free”, both with respect to a crime committed (Gisèle) and future victims. Criminalizing enablers, then, would make a significant contribution to holding accountable those from whom the perpetrator of the crime directly benefitted, thereby enhancing victim vulnerability.
VIII. Final Word
This Article highlights the consequences of the combustible merging of disparate factors and circumstances resulting in the decades long rape of an unconscious and drugged woman. Not of any woman, but the wife of the man who orchestrated what under normal circumstances would be defined as “unimaginable.”
Except not only was it “imaginable” but it actually occurred in a small town in France. The fact the rapes were minimized by the mayor is but a piece of a much larger, sordid, and terrible crime carefully planned, flawlessly executed, that came to a crashing end only because of an unrelated crime committed by Dominique Pelicot.
Notwithstanding the heinousness crimes committed by Dominique and those who raped his unconscious wife, our focus is on two issues without which this tragedy cannot be understood. As we explain in great detail, to understand this crime requires recognizing the extraordinary harm caused by “rape by proxy” particularly when it is enhanced by the critical role played by enablers and hence our call to recognize “enabling” as a crime. The primary enabler in this case is the website, Coco; the ease with which Dominique was able to interact with the men who would rape his wife is a direct result of the website. That is the essence of enabling.
To fully appreciate its significance and requisite need to criminalize “rape by proxy” the most painful and obvious rationale is Gisele Pelicot who is its most obvious and direct victim. Regrettably we are unable to address the role of physicians and pharmacies whose roles were crucial to the crime. However, we have shone a very bright light - a j’accuse - on two crimes demanding the immediate and forceful attention of the public, media, jurists, and legislators: enabling and “rape by proxy.
We do so with the intent not only of drawing light to how it was possible for Dominique to commit this crime but no less importantly to make a determined and concerted effort to protect potential future victims. In blunt terms, failure to act with forcefulness and commitment is akin to abandonment of a vulnerable individual to whom a duty is owed.
What happened to Gisele Pelicot must serve as a rallying call before it is too late for the next victim.
[1] Hugh Schofield, Woman describes horror of learning husband drugged her so others could rape her, BBC News (Sep. 5, 2024), https://www.bbc.com/news/articles/cd9dwxexp77o.
[2] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[3] Hugh Schofield, Woman describes horror of learning husband drugged her so others could rape her, BBC News (Sep. 5, 2024), https://www.bbc.com/news/articles/cd9dwxexp77o.
[4]Id.
[5]Id.
[6]Id.
[7]Id.
[8]Id.
[9] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[10]Id.
[11] For the purposes of this Article, due to barriers to accessing necessary information related to the involvement of the medical professionals in this case, we will be focusing solely on the website as an enabler.
[12] In addition to the sexual violations to which Gisèle was unknowingly subjected, Dominique’s daughter has written a book. While there are no criminal charges filed against Dominique alleging that he committed rape by proxy against his daughter, Caroline Darian cited evidence shown to her by police regarding significant violations of her privacy and dignity. Additional evidence indicates privacy violations by Dominique of his two daughters-in-law.
[13]Andrew Harding, French village torn apart by horror of mass rape trial, BBC News (Sep. 10, 2024), https://www.bbc.com/news/articles/cyvpd7zyprdo.
[14]Rape Culture, Rape Prevention Education (Jan. 2026), https://rpe.co.nz/what-is-rape-culture/.
[15]What is rape culture?, Rape Crisis England & Wales (Jan. 2026), https://rapecrisis.org.uk/get-informed/about-sexual-violence/what-is-rape-culture/.
[16]Rape Culture, Rape Prevention Education (Jan. 2026), https://rpe.co.nz/what-is-rape-culture/.
[17]What is rape culture?, Rape Crisis England & Wales (Jan. 2026), https://rapecrisis.org.uk/get-informed/about-sexual-violence/what-is-rape-culture/.
[18]Id.
[19]Rape Culture, Rape Prevention Education (Jan. 2026), https://rpe.co.nz/what-is-rape-culture/; Nina Bahadur, If Reporting A Robbery Was Like Reporting A Rape, The Huffington Post (Feb. 25, 2015, 12:18 PM EST), https://www.huffpost.com/entry/rape-report-robbery-victim-blaming_n_6751560.
[20]SeeRape Culture, Rape Prevention Education (Jan. 2026), https://rpe.co.nz/what-is-rape-culture/.
[21]What is rape culture? Rape Crisis England & Wales (Jan. 2026), https://rapecrisis.org.uk/get-informed/about-sexual-violence/what-is-rape-culture/.
[22] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[23]Id.
[24] Andrew Harding, French village torn apart by horror of mass rape trial, BBC News (Sep. 10, 2024), https://www.bbc.com/news/articles/cyvpd7zyprdo.
[25]Le Monde with AFP, French mayor sorry for ‘no one died’ comment over mass rape trial, Le Monde (Sep. 21, 2024, 4:58 PM CEST), https://www.lemonde.fr/en/france/article/2024/09/21/french-mayor-sorry-for-no-one-died-comment-over-mass-rape-trial_6726828_7.html; Andrew Harding, French village torn apart by horror of mass rape trial, BBC News (Sep. 10, 2024), https://www.bbc.com/news/articles/cyvpd7zyprdo.
[26] Andrew Harding, French village torn apart by horror of mass rape trial, BBC News (Sep. 10, 2024), https://www.bbc.com/news/articles/cyvpd7zyprdo.
[27]Id.
[28]Id.
[29]Id.
[30] Angelique Chrisafis, ‘Impunity is growing’: French celebrities call for law to crack down on sexism and sexual violence, The Guardian (May 14, 2024, 10:27 EDT), https://www.theguardian.com/world/article/2024/may/14/french-celebrities-law-crackdown-sexism-sexual-violence.
[31]Id.
[32] Paul Bensussan,Marital rape according to French law: Desire, need and consent. Sexologies. 18. 182-185. 10.1016/j.sexol.2009.04.001.; Clea Caulcutt, France launches campaign against marital rape, Radio France Internationale (Jun. 15, 2011, 2:40 PM CEST), https://www.rfi.fr/en/france/20110615-france-launching-its-first-campaign-against-marital-rape.
[33] France - Rape, European Institute for Gender Equality (Jan. 2026), https://eige.europa.eu/gender-based-violence/regulatory-and-legal-framework/legal-definitions-in-the-eu/france-rape?language_content_entity=en; Code Pénal [C. pén.] [Penal Code] art. 222-23 (Fr.)
[34] European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 13 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf; Code Pénal [C. pén.] [Penal Code] art. 222-22 (Fr.)
[35] European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 14 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf.
[36]Id.
[37] Marie-Gabrielle Campana-Doublet, National Analysis: France, European Women’s Lobby (2013), https://womenlobby.org/wp-content/uploads/2013/10/2714_france_lr.pdf; Catherine Porter and Ségolène Le Stradic, With Guilty Verdicts, Rape Victim’s Ordeal in France Becomes a Message of Hope, The New York Times (Dec. 19, 2024), https://www.nytimes.com/2024/12/19/world/europe/pelicot-rape-trial-guilty-verdict.html.
[38] Angelique Chrisafis, Who are the men convicted over rape and assault of Gisèle Pelicot?, The Guardian (Dec. 19, 2024, 11:02 AM EST), https://www.theguardian.com/world/2024/dec/19/who-are-the-men-convicted-over-rape-and-assault-of-gisele-pelicot-.
[39] European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at I (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf; Council of Europe Convention on preventing and combating violence against women and domestic violence, Council of Europe Treaty Series No. 210 (2011), https://rm.coe.int/168008482e.
[40]European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 9 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf (bold in original).
[41] Id.
[42] European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 4 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf.
[43] Id.
[44] 10 U.S.C. § 920 (2017).
[45]Id. (emphasis added).
[46]Id.
[47]Id.
[48] Utah Code § 76-5-402(2) (2025).
[49] Utah Code § 76-5-402(2)(c) (2025).
[50] Utah Code § 76-5-402(3)(a) (2025).
[51] Utah Code § 76-5-402(1) and (3)(b) (2025).
[52] Utah Code § 76-5-402(3)(c)(i) (2025).
[53] Utah Code § 76-2-202 (1973).
[54] Utah Code § 76-5-405(2)(e) and (h) (2022).
[55]See Utah Code § 76-2-202 (1973); Utah Code § 76-5-402(2) (2025).
[56] Utah Code § 76-5-402(3)(a) (2025); Utah Code § 76-5-402(1) and (3)(b) (2025).
[57] See, e.g. Amos N. Guiora, Armies of Enablers: Survivor Stories of Complicity and Betrayal in Sexual Assaults (American Bar Association 2020).
[58] Kim Willsher and agencies, France charges founder of website used by Dominique Pelicot, The Guardian (Jan. 9, 2025, 11:11 AM EST), https://www.theguardian.com/world/2025/jan/09/france-charges-isaac-steidl-founder-of-website-used-by-dominque-pelicot.
[59]Id.
[60] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[61] Jeff Meyer, Key moments in content moderation (Apr. 16, 2024), https://www.webpurify.com/blog/key-moments-in-content-moderation/.
[62]Le Monde with AFP, France charges founder of adult website linked to mass rape trial, Le Monde (Jan. 10, 2025, 5:09 PM CET), https://www.lemonde.fr/en/france/article/2025/01/10/france-charges-founder-of-adult-website-linked-to-mass-rape-trial_6736899_7.html.
[63] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[64] Romain Badouard & Anne Bellon, Introduction to the Special Issue on Content Moderation on Digital Platforms, 14 Internet Policy Rev. (1) (2025), https://doi.org/10.14763/2025.1.2005.
[65]Sarah T. Roberts, Behind the Screen: Content Moderation in the Shadows of Social Media (Yale University Press 2019).
[66]Id.
[67] Daryna Antoniuk, French police shut down chat website reviled as ‘den of predators’, The Record (Jun. 25, 2024), https://therecord.media/coco-website-takedown-cybercrime-france?utm_source=chatgpt.com.
[68] Kim Willsher and agencies, France charges founder of website used by Dominique Pelicot, The Guardian (Jan. 9, 2025, 11:11 AM EST), https://www.theguardian.com/world/2025/jan/09/france-charges-isaac-steidl-founder-of-website-used-by-dominque-pelicot.
[69]Id.
[70]Facebook Help Center - How to Create a Facebook Account, Facebook (last visited Jan. 24, 2026), https://www.facebook.com/help/188157731232424.
[71]Id.
[72] Catherine Porter and Ségolène Le Stradic, France Indicts Founder of Notorious Website Used in Pelicot Rape Case, The New York Times (Jan. 9, 2025), https://www.nytimes.com/2025/01/09/world/europe/france-pelicot-rape-trial-coco-indictment.html.
[73] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[74]Id.
[75]Id.
[76] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[77] Aurelien Breeden, Catherine Porter and Ségolène Le Stradic, His Chat Site Was Tied to the Pelicot Rapes. Now, France Wants to Prosecute Him, Too., The New York Times (Jan. 17, 2025), https://www.nytimes.com/2025/01/17/world/europe/pelicot-rape-trial-coco-isaac-steidl.html.
[78] Le Monde with AFP, Aggressions sexuelles et guet-apens homophobes: le fondateur et gérant due site Coco.fr mis en examen, Le Monde (Jan. 9, 2025, 6:54 PM CET), https://www.lemonde.fr/societe/article/2025/01/09/agressions-sexuelles-et-guet-apens-homophobes-le-fondateur-et-gerant-du-site-coco-fr-mis-en-examen_6490086_3224.html; Kim Willsher and agencies, France charges founder of website used by Dominique Pelicot, The Guardian (Jan. 9, 2025, 11:11 AM EST), https://www.theguardian.com/world/2025/jan/09/france-charges-isaac-steidl-founder-of-website-used-by-dominque-pelicot.
[79] Le Monde with AFP, Aggressions sexuelles et guet-apens homophobes: le fondateur et gérant due site Coco.fr mis en examen, Le Monde (Jan. 9, 2025, 6:54 PM CET), https://www.lemonde.fr/societe/article/2025/01/09/agressions-sexuelles-et-guet-apens-homophobes-le-fondateur-et-gerant-du-site-coco-fr-mis-en-examen_6490086_3224.html.
[80] Kim Willsher and agencies, France charges founder of website used by Dominique Pelicot, The Guardian (Jan. 9, 2025, 11:11 AM EST), https://www.theguardian.com/world/2025/jan/09/france-charges-isaac-steidl-founder-of-website-used-by-dominque-pelicot.
[81] Le Monde with AFP, Aggressions sexuelles et guet-apens homophobes: le fondateur et gérant due site Coco.fr mis en examen, Le Monde (Jan. 9, 2025, 6:54 PM CET), https://www.lemonde.fr/societe/article/2025/01/09/agressions-sexuelles-et-guet-apens-homophobes-le-fondateur-et-gerant-du-site-coco-fr-mis-en-examen_6490086_3224.html.
[82] Code Pénal [C. pén.] [Penal Code] art. 323-3-2 (Fr.); Aurelien Breeden, Catherine Porter and Ségolène Le Stradic, His Chat Site Was Tied to the Pelicot Rapes. Now, France Wants to Prosecute Him, Too., The New York Times (Jan. 17, 2025), https://www.nytimes.com/2025/01/17/world/europe/pelicot-rape-trial-coco-isaac-steidl.html.
[83] Aurelien Breeden, Catherine Porter and Ségolène Le Stradic, His Chat Site Was Tied to the Pelicot Rapes. Now, France Wants to Prosecute Him, Too., The New York Times (Jan. 17, 2025), https://www.nytimes.com/2025/01/17/world/europe/pelicot-rape-trial-coco-isaac-steidl.html.
[84] Le Monde with AFP, Franche charges founder of adult website linked to mass rape trial, Le Monde (Jan. 10, 2025, 12:44 PM CST), https://www.lemonde.fr/en/france/article/2025/01/10/france-charges-founder-of-adult-website-linked-to-mass-rape-trial_6736899_7.html.
[85] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[86] Saskya Vandoorne, Niamh Kennedy, Caroline Baum, Kara Fox, Carlotta Dotto, Eleanor Stubbs, Yukari Schrickel and Byron Manley, CNN (Dec. 19, 2024), https://www.cnn.com/interactive/2024/12/europe/Gisèle-pelicot-france-case-messages/
[87]Id.
[88]Angelique Chrisafis, ‘A rapist can be in the family’: how Dominique Pelicot became one of the worst sexual predators in history, The Guardian (Dec. 11, 2024, 6:59 PM EST), https://www.theguardian.com/world/2024/dec/11/a-rapist-can-be-in-the-family-how-dominique-pelicot-became-one-of-the-worst-sexual-predators-in-history.
[89] Saskya Vandoorne, Niamh Kennedy, Caroline Baum, Kara Fox, Carlotta Dotto, Eleanor Stubbs, Yukari Schrickel and Byron Manley, CNN (Dec. 19, 2024), https://www.cnn.com/interactive/2024/12/europe/Gisèle-pelicot-france-case-messages/.
[90] Caroline Darian, I’ll Never Call Him Dad Again: Turning Our Family Trauma of Sexual Assault and Chemical Submission into a Collective Fight, (Sourcebooks 2025).
[91] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[92] Francesca Gillett and Laura Gozzi, Gisèle Pelicot’s ex-husband jailed for 20 years in mass rape trial, BBC News (Dec. 19, 2024), https://www.bbc.com/news/articles/c89xde5qzvgo.
[93] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[94]Id.
[95] Kim Willsher, French police arrest founder of website used by Dominique Pelicot, The Guardian (Jan. 8, 2025, 3:04 EST), https://www.theguardian.com/world/2025/jan/08/french-police-arrest-founder-of-website-used-by-dominique-pelicot.
[96] Founder of adult website linked to mass rape trial in France faces charges, CBS News (Jan. 10, 2025, 6:28 AM EST), https://www.cbsnews.com/news/founder-adult-website-linked-mass-rape-trial-france-charges/.
[97] Kim Willsher and agencies, France charges founder of website used by Dominique Pelicot, The Guardian (Jan. 9, 2025, 11:11 AM EST), https://www.theguardian.com/world/2025/jan/09/france-charges-isaac-steidl-founder-of-website-used-by-dominque-pelicot.
[98] Aurelien Breeden, Catherine Porter and Ségolène Le Stradic, His Chat Site Was Tied to the Pelicot Rapes. Now, France Wants to Prosecute Him, Too., The New York Times (Jan. 17, 2025), https://www.nytimes.com/2025/01/17/world/europe/pelicot-rape-trial-coco-isaac-steidl.html.
[99] Three Years of Coco’s Law: Impact and Analysis of the Harassment and Harmful Communications Act 2020, McCann Fitzgerald (Jan. 2, 2025), https://www.mccannfitzgerald.com/knowledge/disputes/three-years-of-cocos-law-impact-and-analysis-of-the-harassment-and-harmful-communications-act-2020.
[100] Correspondence in our records
[101] Neil Fetherstonhaugh, Mother who fought for Coco’s Law after bullied daughter’s suicide recognized with top award, Crime World (Apr. 1, 2022, 12:49 PM), https://www.sundayworld.com/news/irish-news/mother-who-fought-for-cocos-law-after-bullied-daughters-suicide-recognised-with-top-award/41207537.html. This “Coco” legislation is unrelated to the website, albeit carrying the same name
[102] Aurelien Breeden, Catherine Porter and Ségolène Le Stradic, His Chat Site Was Tied to the Pelicot Rapes. Now, France Wants to Prosecute Him, Too., The New York Times (Jan. 17, 2025), https://www.nytimes.com/2025/01/17/world/europe/pelicot-rape-trial-coco-isaac-steidl.html.
[103] The Digital Services Act, European Commission (Dec. 15, 2025), https://digital-strategy.ec.europa.eu/en/policies/digital-services-act-package.
[104] DSA: Making the online world safer, European Commission (Dec. 12, 2025), https://digital-strategy.ec.europa.eu/en/policies/safer-online.
[105]Transposition, European Commission (last visited Jan. 24, 2026), https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=LEGISSUM:transposition
[106] Nick Robins-Early, The anonymous, anything-goes forum at the heart of the Pelicot rape case, The Guardian (Oct. 12, 2024, 12:00 PM EDT), https://www.theguardian.com/world/2024/oct/12/coco-website-pelicot-rape-trial.
[107] Le Monde with AFP, France probes online platform suspected of spreading child pornography, Le Monde (Aug. 30, 2025, 5:29 PM CEST), https://www.lemonde.fr/en/france/article/2025/08/30/france-probes-online-platform-suspected-of-spreading-child-pornography_6744876_7.html.
[108] Office on Violence Against Women, U.S. Dep't of Justice, Domestic Violence (2025). 2-3. Trial testimony, Procès Pelicot, Cour d'Assises du Vaucluse (2024).
[109] Code pénal, art. 222-14-3 (Fr.).
[110]Opuz v. Turkey, App. No. 33401/02, Eur. Ct. H.R. (2009).
[111] Council of Europe Convention on Preventing and Combating Violence Against Women and Domestic Violence, May 11, 2011, C.E.T.S. 210, art. 33.
[112] Benjamin Mendelsohn, La Victimologie, 90 Revue Française de Psychanalyse 95 (1956).
[113] Ezzat A. Fattah, Victimology: Past, Present and Future, 33 Criminologie 17 (2000).
[114] Hans von Hentig, The Criminal and His Victim (1948).
[115] Domestic Abuse Act 2021, c. 17 (U.K.).
[116] Gewaltschutzgesetz [GewSchG] [Protection Against Violence Act], June 1, 2002, BGBl. I at 1818 (Ger.); Hans von Hentig, The Criminal and His Victim (1948).
[117] European Commission, Proposal for a Directive on Combating Violence Against Women, COM(2022) 105 final.
[118] Family Violence Appellate Project, Economic Abuse and Legal System Response (2023).
[119] Office on Violence Against Women, supra note 112. 15-16. See generally Rape Crisis England & Wales, Older Women and Sexual Violence (2019).
[120] Code de la santé publique, art. L. 2212-2 (Fr.).
[121]See Société Française de Médecine Légale, Recommandations pour la détection de la soumission chimique (2025).
[122] National Network to End Domestic Violence, Economic Abuse Fact Sheet (2025).
[123] Domestic Abuse Act 2021, supra note 10, § 1(4).
[124] Grenelle contre les violences conjugales, Dossier de presse (Nov. 25, 2019).
[125] Office on Violence Against Women, supra note 1.
[126] Istanbul Convention, supra note 6, art. 3(b).
[127] European Commission, supra note 12.
[128] Sarah F. Cage & Thomas Miles, Legal Abuse and Intimate Partner Violence, 12 J. Legal Analysis 157 (2023).
[129] Emily Gutowski et al., The Legal Abuse Scale: A New Measure of Intimate Partner Abuse, 37 Violence Against Women 123 (2022).
[130] Various domestic violence legal precedents compiled in Legal Aid Foundation, Economic Abuse Compendium (2024).
[131] Office on Violence Against Women, supra note 1.
[132] Code pénal, art. 222-8 (Fr.). 30-35. Procès Pelicot, trial evidence and testimony (2024).
[133]See generally European Criminal Law, Framework Decision 2008/841/JHA on organized crime. 37-39. Victimological analysis compiled from French academic sources on conjugal violence.
[134] Code pénal, arts. 225-5, 225-7 (Fr.).
[135]Siliadin v. France, App. No. 73316/01, Eur. Ct. H.R. (2005).
[136] Council of Europe Convention on Action against Trafficking in Human Beings, May 16, 2005, C.E.T.S. 197. 43-44. See generally research on polyvictimization in criminological literature. 45-46. Trial proceedings and psychological analysis, Procès Pelicot (2024).
[137] Luc Leroux, Mazan rape case: the dignity of Gisèle Pelicot, a “field of ruins” that is “still standing”, Le Monde (Sep. 12, 2024, 4:02 PM CEST), https://www.lemonde.fr/societe/article/2024/09/05/affaire-des-viols-de-mazan-la-dignite-de-gisele-pelicot-un-champ-de-ruines-qui-est-encore-debout_6305062_3224.html?search-type=classic&ise_click_rank=23.
[138]Id.
[139]Id.
[140] Loi n° 2021-478 du 21 avril 2021 visant à protéger les mineurs des crimes et délits sexuels. 51-53. M.C. v. Bulgaria, App. No. 39272/98, Eur. Ct. H.R. (2003).
[141] Luc Leroux, Mazan rape case: the dignity of Gisèle Pelicot, a “field of ruins” that is “still standing”, Le Monde (Sep. 12, 2024, 4:02 PM CEST), https://www.lemonde.fr/societe/article/2024/09/05/affaire-des-viols-de-mazan-la-dignite-de-gisele-pelicot-un-champ-de-ruines-qui-est-encore-debout_6305062_3224.html?search-type=classic&ise_click_rank=23.
[142] Angelique Chrisafis, Dominique Pelicot tells French trial: ‘I am a rapist,’ as he returns to dock, The Guardian (Sep. 17, 2024, 1:10 PM EDT), https://www.theguardian.com/world/2024/sep/17/dominique-pelicot-france-rape-trial-testimony.
[143]See Henry, N., Flynn, A., & Powell, A. (2020). Technology-facilitated domestic and sexual violence: A review. Violence against women, 26(15-16), 1828-1854.
[144] Carol E. Tracy, Terry L. Fromson, and Jennifer Gentile Long, Rape and Sexual Assault in the Legal System, Women’s Law Project (Jun. 5, 2012).
[145] Code Pénal [C. pén.] [Penal Code] art. 225-5 and 225-7 (Fr.)
[146]Siliadin v. France, App. No. 73316/01, (2005) ECHR 545, 43 Eur. H.R. Rep. 16.
[147] Council of Europe Convention on Action against Trafficking in Human Beings, art. 4(a), May 17, 2005, C.E.T.S. No. 197.
[148] Angelique Chrisafis, Dominique Pelicot tells French trial: ‘I am a rapist,’ as he returns to dock, The Guardian (Sep. 17, 2024, 1:10 PM EDT), https://www.theguardian.com/world/2024/sep/17/dominique-pelicot-france-rape-trial-testimony.
[149] Code Pénal [C. pén.] [Penal Code] art. 121-6 and 121-7 (Fr.).
[150]European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 14 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf.
[151] Catherine Porter and Ségolène Le Stradic, France Moves Closer to Adding a Missing Word to Its Rape Law: Consent, The New York Times (Apr. 1, 2025), https://www.nytimes.com/2025/04/01/france-parliament-consent-rape-law.html.
[152]European Parliamentary Research Service, Definitions of Rape in the Legislation of EU Member States, European Parliamentary Research Service, PE 757.618 at 14 (May 2025), https://www.europarl.europa.eu/RegData/etudes/IDAN/2024/757618/EPRS_IDA(2024)757618_EN.pdf.
[153] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[154] Robert R. Wiggins, Deterrence, EBSCO (2024), https://www.ebsco.com/research-starters/military-history-and-science/deterrence.
[155]Five Things About Deterrence, National Institute of Justice (Jun. 5, 2016), https://nij.ojp.gov/topics/articles/five-things-about-deterrence.
[156] Richard Blaylock, The Doctrine of Reprobation, The Gospel Coalition (2025), https://www.thegospelcoalition.org/essay/doctrine-of-reprobation/.
[157] Paul H. Robinson and John M. Darley, The Role of Deterrence and the Formulation of Criminal Law rules: At Its Worst When Doing Its Best, 91 Geo L.J., 949 (2003); Five Things About Deterrence, National Institute of Justice (Jun. 5, 2016), https://nij.ojp.gov/topics/articles/five-things-about-deterrence; Daniel P. Mears and Mark C. Stafford, A theoretical critique of deterrence-based policy, J. Crim. L., Volume 95, November–December 2024, 102305.
[158] Eric Luna, Overextending the Criminal Law, Cato Policy Report,Vol. XXV no. 6; Terry Skolnik, Criminal Justice and the Erosion of Constitutional Rights,B.C. L. Rev., Vol. 66:1679.
[159] Religious Action Center, Save One Life, Save the Entire World (Including Yourself), May 24, 2019Rabbi Dan M
[160] Paul H. Robinson and Michael T. Cahill, The Accelerating Degration of American Criminal Codes, 56 Hastings L.J., 633(2005).
[161] Mark Greenberg, The Moral Impact Theory of Law, 123 Yale L.J., 1288, xx (2024); Carl Herstein, Forgetting the Connection Between Law and Morality, Public Square Magazine, (Oct. 9, 2019), https://publicsquaremag.org/sexuality-family/forgetting-the-connection-between-law-and-morality/.
[162]See Amos N. Guiora and Jessie E. Dyer, Bystander Legislation: He Ain’t Heavy He’s My Brother, 29 Kan. J.L. & Pub. Pol’y 291, xx (2020).
[163]Id.
[164] Michele J. Gelfand, Beng-Chong Lim, & Jana L. Raver, Culture and Accountability in Organizations: Variations in Forms of Social Control Across Cultures, 14 Human Resource Management Review, 1, xx (2004).
[165] Amos N. Guiora, Armies of Enablers: Survivors Stories of Complicity and Betrayal in Sexual Assaults (American Bar Association 2020). See interactions with Mattie Larson
[166]Id.
[167]Id.
[168]Id.
[169]Id.
[170]Inside the depraved mind of ‘career criminal’ Dominque Pelicot, Sky News (Dec. 19, 2024, 10:47 PM GMT), https://news.sky.com/story/inside-the-depraved-mind-of-career-criminal-dominique-pelicot-13276676.
[171]See Section II
[172]See Chart, Section IV.
[173]As France’s largest rape trial comes to an end, is the punishment enough, TRT. World (Dec. 20, 2024), https://www.trtworld.com/video/18245613.
[174] Amos N. Guiora, Tolerating Intolerance: The Price of Protecting Extremism (Oxford University Press2014).
[175] San Francisco State University, Office for Civil Rights and Title IX, Common Myths and Facts about the Causes of Sexual Violence.
[176] Natalie Stechyson, Copycat in Dominque Pelicot rape trial admits to drugging and raping his own wife—with help, CBC (Sept. 18, 2024), https://www.cbc.ca/news/world/french-rape-trial-copycat-1.7326535.
[177] https://dictionary.cambridge.org/us/dictionary/english/boys-will-be-boys
[178] Colette Davidson, France updates rape laws after Pelicot case. But is recognizing consent enough?, The Christian Science Monitor (Oct. 31, 2025).
[179] Amos N. Guiora, Armies of Enablers: Survivors Stories of Complicity and Betrayal in Sexual Assaults (American Bar Association 2020), see interactions with Tiffany Thomas (then Lopez) and Mattie Larson
[180] Andrew Harding, Dominique Pelicot’s double life: who is the man who plotted his wife’s mass rape, BBC News (Dec. 19, 2024) https://www.bbc.com/news/articles/clynx2q93q1o; Eleanor Beardsley, Dozens of men are found guilty in mass rape case of French woman drugged by her husband, NPR (Dec. 19, 2024).
[181] Katie Ebner-Landy, The Chat Room Behind the Pelicot Rape Trial, The New Yorker (Feb. 22, 2025), https://www.newyorker.com/news/the-weekend-essay/coco-the-chat-room-behind-the-dominique-pelicot-rape-trial.
[182] Graphic created by Gianna LaRoche
[183] The Good Men Project, Legal Accountability, Cult Dynamics and Institutional Complicity: Chat with Amos Guiora and Irina Tsukerman, October 31, 2025; Amos N. Guiora on Institutional Complicity and Legal Reform, Insight Publishing, October 5, 2025.
[184] For discussion regarding criminal conspiracy, see Federal Law Enforcement Centers, Federal Conspiracy Law, https://www.fletc.gov/audio/federal-conspiracy-law-mp3
[185] Amos N. Guiora, Diana Pogosyan, Matylda Blaszczak, Sacred Secrets Enabling Child Sex Abuse, 49 Law & Psych. Rev. (2025).
[186] Amos N. Guiora, Armies of Enablers: Survivors Stories of Complicity and Betrayal in Sexual Assaults (American Bar Association 2020), see interactions with Tiffany Thomas (then Lopez) and Mattie Larson
[187] Megan Banta, Michigan State University’s insurers paying millions to help cover Nassar settlement, Lansing State Journal, Aug. 9, 2020.
[188] Amos N. Guiora, Armies of Enablers: Survivors Stories of Complicity and Betrayal in Sexual Assaults (American Bar Association 2020).