Purported images of a topless Tallulah have been shopped around several internet publications in the last few days, according to Radar Online.
The woman believed to be 18-year-old Tallulah is also seen apparently smoking a marijuana joint in the pictures.
The Willis and Moore family have not offered any comment on this matter.
Tallulah was picked up by police in April 2011 for alcohol possession.
The teenager is rumoured to have dated Arnold Schwarzenegger's son Patrick Schwarzenegger in the past.