Introduction

On September 16, 2026, the Ninth Circuit held in Doe v. GitHub, Inc. that outputs produced by a generative AI coding tool are newly generated works, not copies of existing works, and therefore fall outside the Digital Millennium Copyright Act’s (DMCA) prohibition on removing or altering copyright management information (CMI).1 The court limited that characterization to the § 1202(b) removal and alteration analysis, and declined to reach whether AI outputs that reproduce copyrighted material could constitute copyright infringement.2 The ruling turned on the generative architecture of the accused AI systems, distinguishing generative AI tools that generate outputs by predicting sequences from statistical patterns from retrieval-based systems that retrieve and disseminate existing copyrighted material, with the court suggesting the latter could face different legal treatment. The Ninth Circuit also declined to reach, on procedural grounds, the question of whether training on copyright-protected materials from which CMI has been stripped violates § 1202(b).

Continue Reading Ninth Circuit Rules Generative AI Outputs Are Not “Stripped Copies” Under the DMCA

In the final weeks of California’s 2026 legislative session, lawmakers passed a series of bills that stand to significantly reshape the state’s privacy and AI regulatory landscape. Of particular significance, Senate Bill 690 (SB 690) seeks to curtail one of the principal theories underlying the recent wave of California Invasion of Privacy Act (CIPA) litigation, which has swept across diverse industries to affect website operators ranging from consumer brands to financial services firms. The bill would eliminate private actions under CIPA’s pen register and trap-and-trace provision, leaving the California Attorney General as the sole party authorized to bring those civil claims. If enacted, SB 690 would also apply retroactively to any pending pen/trap claim in actions filed within two years before its operative date, potentially affecting certain website-tracking cases already in litigation.

Continue Reading California Legislature Advances Key Privacy and AI Bills, Including Limits on Website Tracking Lawsuits

On August 4, 2026, the United States Court of Appeals for the Ninth Circuit issued its decision in Amazon.com Services, LLC v. Perplexity AI, Inc., vacating a preliminary injunction that had barred Perplexity’s AI-enabled web browser from interacting with Amazon’s website. The decision addresses a question of first impression: whether an AI “agent” that assists a user in navigating a website constitutes unauthorized “access” under the federal Computer Fraud and Abuse Act (CFAA). The court held that, on the facts presented, it does not, concluding that it is the user, not the AI tool, who “accesses” the website for purposes of the statute. This alert summarizes the decision and its practical implications for AI developers and deployers, as well as for businesses whose platforms or data may be implicated by AI-driven interactions.

Continue Reading Tool or Intruder? What Amazon v. Perplexity Means for Agentic AI and the CFAA

On April 29, 2026, the United States Supreme Court issued a unanimous opinion in First Choice Women’s Resource Centers, Inc. v. Davenport, where it held that a nonprofit suffered an injury to its First Amendment right of association when it was subpoenaed by a state attorney general to produce donor information, including donor identities.1 Justice Gorsuch, writing for the Court, held that the nonprofit petitioner could challenge the subpoena in federal court without first waiting for a state court to compel compliance.

Continue Reading Supreme Court Reinforces Donor Privacy Protections, Permitting Immediate Federal Court Challenge to State Subpoena

On March 20, 2026, the White House released its National Policy Framework for Artificial Intelligence (“Framework”), outlining legislative recommendations for Congress to establish a unified federal approach to AI regulation. The Framework builds on prior executive actions, including the December 2025 Executive Order (the “Executive Order”) and the Trump administration’s “America’s AI Action Plan,” and it proposes that Congress adopt legislation broadly preempting state AI laws deemed to impose “undue burdens.” This alert summarizes the Framework’s key provisions, analyzes their potential impact on state laws, and highlights considerations for healthcare and life sciences stakeholders navigating the evolving regulatory landscape. While the Framework does not itself change the current legal status of the Executive Order, it signals increased policy focus and may prompt further agency action.

Continue Reading The White House Legislative Recommendations: National Policy Framework for Artificial Intelligence and Federal Preemption of State AI Laws

Last week, the U.S. Supreme Court agreed to hear a case that is expected to resolve a long-developing split among federal courts of appeals over the scope of the Video Privacy Protection Act of 1988 (“VPPA”), 18 U.S.C. § 2710. In granting certiorari in Salazar v. Paramount Global, the Court will address a question that has increasingly shaped VPPA class action litigation in recent years: who qualifies as a “consumer” protected by the statute.

Continue Reading Supreme Court to Consider the Video Privacy Protection Act

An increasingly aggressive plaintiffs’ bar has brought purported class action suits based on the nearly ubiquitous use of tracking technologies used for website analytics. Although any actual harm to the plaintiffs is difficult to articulate, the health care industry has been plagued by a series of these cases. Now the plaintiffs may be moving to financial services with the potential for statutory penalties of hundreds of dollars per user when a duty of confidentiality can be credibly implicated. 

The tracking tags, pixels and similar website analytics technologies are nothing new. Rather, the technologies at issue in such complaints are widely used on websites and mobile applications across industries, including by government entities, to collect information about user behaviors and interactions with the online platform where they are embedded. That information is then sent to a third party for analytics used to enhance user experience on the platform. Many of these technologies are integral to an organization’s ability to ensure its websites and applications are functioning properly, among other things providing crash reports when users encounter issues. Additionally, many consumer-facing businesses contract with third parties to provide session replay scripts, a software that monitors and records web-user activity such as keystrokes, clicks, and scrolling.  Despite the pervasiveness of these technologies, plaintiffs have seized on ambiguities in the California state wiretap act, known as the California Information Privacy Act, as well as federal wiretap law as the basis for exceptionally large damage demands.

Continue Reading Pixel Litigation Risk at Financial Institutions

The U.S. Department of Justice (DOJ) announced last Wednesday that settlements and judgments under the False Claims Act (FCA) exceeded $2.9 billion in fiscal year 2024—up approximately 5% from last year. DOJ’s announcement underscores its commitment to FCA enforcement, particularly in the healthcare industry and now with increased activity in the areas of pandemic…

Data breaches made headlines throughout 2024, affecting governments, health care groups, and telecoms. Follow-on litigation has kept pace. Nearly 4,000 class actions involving data privacy issues are estimated to be filed in federal courts by the end of this year.

Growth in litigation meant that 2024 saw legal developments in several areas including standing to sue and web video suits. Increased attention on cybersecurity and privacy incidents unsurprisingly corresponded with active SEC enforcement and derivative suits related to inadequate data security.

Continue Reading Unwrapping 2024’s Key Trends in Data Privacy Litigation

On this episode of the R&G Tech Studio podcast, managing principal and global head of advanced E-Discovery and A.I. strategy Shannon Capone Kirk sits down with data, privacy & cybersecurity partner Fran Faircloth to discuss how new and ever-evolving technology is impacting her clients, particularly generative AI, and the challenges that arise in litigation and…