Lawyers for the child claim the picture was blackmailed from her and repeatedly published online as a form of revenge.
The girl is taking legal action against Facebook and the man who posted the photo in what is believed to be the first case of its kind in the world.
At a hearing in the High Court in Belfast, a barrister for the girl said the picture was put on a "shame" page.
He said that blocking its re-publication should have been a "red-line" issue for the company.
Claim for damages
"A naked 14-year-old picture was being put on a shame page," the barrister told the High Court in Belfast.
"If they had blocked it all this subsequent publication of her naked image would not have taken place."
But a lawyer for Facebook argued the claim for damages should be dismissed, saying the company always took down the picture when it was notified.
The girl, who cannot be identified, is seeking damages for misuse of private information, negligence and breach of the Data Protection Act.
The judge reserved his decision on an application to have the case halted.
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