Images of the model on holiday with her bodyguard boyfriend Martin Kirsten in the south of France have emerged online.
According to TMZ, Klum has compared her situation to that of the Duchess of Cambridge.
The royal successfully sought an injunction in the French courts after Closer published topless photographs of her last week.
Klum was reportedly on a private and secluded beach when the photographs were taken, and her camp is said to be trying to find out which publication first printed the images.
It is claimed that Klum will wait until the Duchess of Cambridge's lawsuit is concluded before moving on with her own action.