I wonder if, besides imaginary depictions of non-consensual acts (and what of consensual non-consent, CNC? Do you have to add a frame to your comic where the characters discuss their limits and safe words?) -- maybe it's meant more to address deepfakes / porn involving depictions of people who didn't agree to be depicted that way. I think the law around usage of your image (and your voice) is in a very interesting place but could use clarification so all citizens can benefit; right now its hollywood actors and basketball players who get to explicitly control how images of them are used. Facebook did get in trouble once for putting photos of your friends into ads, "Your aunt bettie likes walmart!", they still can list that text since you did hit the like button, but there was some law that prevented them from using your face to imply endorsement.