The student athletes, some as young as 14, are from 11 schools in the Orange County area, as well as schools in the Los Angeles and San Diego areas.
According to investigators, the photos may be the work of a University of California, Irvine police dispatcher named Scott Cornelius.
Cornelius was a credentialed photographer at the 2007 Junior World Water Polo Championships, held last summer at Los Alamitos.
University police department detective Shaun Devlin sent an email to parents of students that participated in the event, informing them that the matter was under investigation but, pending charges, Cornelius is still considered to be on active duty.
In a report in the Orange County Register, Drake University's Intellectual Property Law Center director Peter Yu said photos taken at public events like high school sports competitions are generally protected by the Constitution.
In August, Assemblyman Smyth Cameron, R-Santa Clarita proposed the Surrogate Stalker Act, which would prosecute individuals engaged in stalking minors by charging them under child endangerment laws.
The bill was prompted by the activities of Jack McClellan, a self-proclaimed pro-pedophile activist that took pictures of young children at various parks and playgrounds and posted them on his website.