I propose that there are never any hacks of any celebrity accounts. Most if not all are managed by PR firms who know about how to keep a photo in or out of the media.
I doubt there are many if any actual nude photos of any of these celebs, especially when it comes to the naught bits.
Therefore all these stories are fake, for publicity sake.
Now, if you are part of the growing numbers that believe that most, if not all, of the promoted celebs are EGI (see my dedicated subblog here), then these stories go one step further: to reinforce the perception that these “women” are natural and not EGI – because the millions that may or may not see these leaked photos would surely be able to tell the difference.
Many times you will never even be able to find these photos – because they don’t even need to leak them out, photoshopped or not!
Perception management is what this art is called, and the cheaper you can run the scam, the better. After all, it’s a business.