The 47-year-old French First Lady was secretly pictured earlier this year in a bikini, and is suing for invasion of privacy.
The barrister defending Closer magazine, which caused a public furore last month when it published topless photos of Kate Middleton, said:
"You can still be dignified with a bit of cellulite. Valerie Trierweiler is a grown woman who knew these harmless photos would be taken."
In a statement, Closer’s controversial editor Laurence Pieau wrote:
"How dare she complain? She was on a private beach in full view of the boats hired by the paparazzi. In other words, she must have known."
In defence of publishing the pictures of a topless Kate, she also said that the photos were not shocking:
"They show a young woman sunbathing topless, like the millions of women you see on beaches."