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Exploring California’s Generative AI Training Data Transparency Act

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Stephanie Sharron, Marian Waldmann Agarwal and Joshua Fattal wrote an article for Corporate Compliance Insights entitled "Exploring California’s Generative AI Training Data Transparency Act" that discusses California’s new requirements for developers to disclose information about data used to train generative AI systems. The authors explain that the law applies broadly, including to companies that substantially modify or fine-tune models, and requires disclosures across 12 categories, including data sources, intellectual property status and personal information. They also examine exemptions, potential enforcement through California’s Unfair Competition Law and practical compliance considerations, urging companies to assess developer status and audit training-data provenance.Read the <a href="https://www.corporatecomplianceinsights.com/exploring-californias-generative-ai-training-data-transparency-act/" target="_blank">full article</a>.

Exploring California’s Generative AI Training Data Transparency Act

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Stephanie is a trusted advisor to companies with respect to technology and life sciences transactions, related IP counseling, and responsible tech and AI governance practices.Stephanie represents both private and public companies, from emerging growth through the Fortune 50. For over 25 years, her practice has focused on helping companies that leverage data through technology.Stephanie serves on the Responsible AI Venture Council, part of the recently launched Lucas Institute for Venture Ethics at Santa Clara University’s Markkula Center for Applied Ethics and currently serves as an advisor to certain research projects of the Institute. Stephanie is also a member of the firm’s global Sustainability + Corporate Responsibility and FinTech steering committees.In addition to publishing on a variety of legal topics related to AI, since 2016, Stephanie has taught as a guest lecturer on data licensing and other IP-related topics in Cornell Law School’s Technology and Entrepreneurship LLM program at CornellTech and has served as a guest lecturer at Cornell Law School.

Stephanie Sharron

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Marian Waldmann Agarwal is a partner in the Data, Cyber + Privacy Group at Morrison Foerster. She also co-leads the firm’s Artificial Intelligence Group and is a member of the global Environmental, Social, and Governance (ESG) Responsible Tech Committee. Marian’s unique blend of business and legal skills, honed through her background in information systems and business management, is a key asset in her role. Her in-house experience as a secondee to two different companies has provided her with firsthand knowledge of the internal business needs required for company initiatives to succeed. Marian has been instrumental in advising global clients on the developing field of AI. Clients seek her guidance due to her extensive understanding of, and experience with, the ethical use of AI and the developing legal compliance requirements, including data privacy and regulatory provisions, in connection with the design and implementation of innovative AI tools. Her work extends to helping clients identify and mitigate the potential risks associated with AI technologies. In connection with this work, Marian has played a leading role in the development of <a href="/artificial-intelligence" target="_self">MoFo’s AI Resource Center</a>, a free online resource providing links to enacted AI laws, regulations, and guidance in 55 countries, including the United States at the federal and state levels. A recognized authority in AI governance, she was named to the IAPP’s AI in Legal Services Advisory Board, joining a select group of leaders guiding its Legal AI Initiative as AI transforms the delivery, governance, and practice of legal services.Marian counsels clients across a range of industries, including technology, finance, consumer goods and services, healthcare, insurance, media, and hospitality. She assists in designing and building their privacy programs, advising on compliance with U.S. and foreign privacy and data protection laws, such as the California Consumer Privacy Act (CCPA) and the EU’s General Data Protection Regulation (GDPR). Her work includes drafting internal policies, procedures, and guidelines for legal and non-legal audiences that incorporate privacy best practices and legal requirements in daily operations. One of Marian’s core strengths is her ability to comprehensively assess and improve privacy programs, and ensure they remain compliant with evolving privacy laws and regulations. She also drafts and negotiates contracts to protect clients’ data in key commercial agreements, advises on cross-border data transfer issues, and assists with completing multijurisdictional surveys of privacy obligations.In addition, Marian uses her privacy, data security, and AI implementation skills to provide pro bono counseling services to a variety of non-profit clients.Marian received her J.D. from University of Pennsylvania Law School in 2004 and her B.S. and M.B.A. from the State University of New York at Buffalo in 1999. Prior to attending law school, she worked as an application specialist for a small software company.

Marian A. Waldmann Agarwal

Joshua Fattal advises clients across industries on data protection best practices, with a focus on emerging issues at the intersection of data privacy, security, and new technologies, including artificial intelligence (AI) and national security regulations pertaining to sensitive U.S. personal data.Joshua regularly counsels clients ranging from startups to multinational corporations on the legal implications of using AI and large language models (LLMs). He advises on compliance with global AI regulations, including the EU AI Act and Colorado AI Act, and provides guidance on AI governance, responsible AI use, and generative AI best practices.He also advises clients on compliance with U.S. laws and regulations governing the protection of sensitive data from adversary countries, including the U.S. Department of Justice Data Security Program and the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (PADFAA). He has assisted in clients’ complex due diligence of their data use and disclosure practices and in developing cross-functional compliance programs to meet evolving cross-border data transfer requirements. He has represented multiple companies subject to investigation by the U.S. Federal Trade Commission and state attorneys general in connection with PADFAA and the disclosure of sensitive data.Joshua’s experience spans a variety of industries, including AI, technology, life sciences, edtech, fintech, crypto, and consumer services. He counsels clients on compliance under local, state, and federal privacy regulations such as the California Consumer Privacy Act (CCPA), biometric and financial data privacy laws, and cybersecurity regulations. He also guides clients through compliance with international frameworks like the General Data Protection Regulation (GDPR), the EU-U.S. Data Privacy Framework, and the EU ePrivacy Directive.His practice encompasses data incident response strategies, including breach investigations and regulatory notifications. He conducts privacy and cybersecurity due diligence for corporate transactions and advises on information security policies, cybersecurity governance, vendor risk management, and privacy-by-design product development. He also represents companies subject to privacy and consumer protection investigation by federal and state regulators.Joshua maintains an active pro bono practice. He has successfully secured asylum for multiple clients, including a Cameroonian political activist and a Honduran survivor of gender-based violence. He has also represented tenants in housing litigation and advised nonprofits on privacy and cybersecurity matters. Joshua served as a student mentor for the Historical Society of the D.C. Circuit 2026 Mock Court Program.Joshua earned his J.D. cum laude from NYU School of Law, where he was a Robert McKay Scholar and received the full tuition ASPIRE Cybersecurity Scholarship. He received his B.A. magna cum laude from Columbia University and is a member of Phi Beta Kappa. He previously served in the U.S. Intelligence Community, including as an attorney advisor in the Intelligence Law Division at the U.S. Department of Homeland Security. He also clerked for the Honorable Sarah Netburn, U.S. Magistrate Judge in the Southern District of New York.