Patreon isn't afraid of people suing them - because technically animated, even hyper-realistic, porn would fall under fair use, as parody (deepfakes are another thing, and one could argue, in court, that due to the presence of the actual faces of said artists it no longer qualifies as parody but as active defamation) but Patreon is much, much, more afraid of losing that sweet-sweet marketing/advertiser money. And those cunts are much more stricter with what type of content they will or will not support (which is also why OF landed in hot water a couple years back, trying to make themselves PG-13).
Beyond that, artists like Ninja and his ilk are too few and far between (I mean seriously, how many can you name? Ninjartist, Viiper - who's based in Germany, so different rules, Negisaray and AmelodyJ. Maybe Krysdecker with some of his pieces. Merrymage doesn't really count since he is using computer-generated imagery, same as many of the SFM artists on Twitter, which isn't the same as actually drawing shit the way Ninja does. Doesn't mean it isn't good though, it is just different.) to actually make any type of impact on celebrity life and moreso, be worthy of suing.
I mean even, fuck, about 80 percent of leaks don't ever get removed from the online space after the first wave of cease and desists, celebs ain't gonna sue a rando vore artist for using their face in his tentacle porn.