Artificial Intelligence

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Key Point: In a significant ruling for the AI industry, the Ninth Circuit vacated a preliminary injunction against Perplexity AI, holding that Amazon was unlikely to succeed on its Computer Fraud and Abuse Act (CFAA) and California Comprehensive Data Access and Fraud Act (CDAFA) claims. The court concluded that Perplexity’s AI Assistant is a “tool, not a person” for statutory purposes, and that it is the user who “accesses” websites visited using the AI-powered Comet browser. The decision provides the first major appellate guidance on how the CFAA applies to agentic AI systems, though the court was careful to cabin its holding to the specific facts presented.

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We have now had a bit of time to work with clients on the new Colorado Automated Decision-Making Technology in Consequential Decisions Bill (SB 26-189) (ADMT law” — replacing the CO AI Act). The sausage making and behind-the-scenes political machinations were interesting to watch unfold. Ultimately, the ADMT law succeeds in narrowing or eliminating many of the more onerous requirements of the CO AI Act, including disparate impact risk assessment requirements, notification obligations to the Attorney General upon discovery of algorithmic discrimination (within 90 days), and the AI framework-compliance affirmative defense.

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Key point: Vermont’s legislature passed a consumer data privacy bill, Illinois’ legislature passed an AI frontier model bill, and eight bills crossed chambers in California.

Below is the 20th update on the status of proposed state privacy and AI legislation in 2026. With state legislative activity slowing, we have combined our weekly privacy and AI posts.

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In this episode of The Consumer Finance Podcast, Chris Willis and Kim Phan unpack Colorado’s brand-new Automated Decision-Making Technology (ADMT) Act, which repeals and replaces the state’s much-criticized 2024 AI law. They explain the shift from “high-risk AI systems” to the broader ADMT framework, what it means for consequential decisions in lending and financial services, and how the statute’s “material influence” standard can sweep in tools that do far more than make final credit determinations.

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Key point: Connecticut’s new AI law adds to the growing complexity of state laws directed at commonly used automated employment decision tools.

On May 27, 2026, Connecticut Governor Ned Lamont signed SB 5 into law. Connecticut Senator James Maroney authored the bill, which covers several different areas involving the regulation of artificial intelligence (AI), including frontier models, chatbots, employment, and provenance. Lamont also signed into law a companion bill, SB 4, which amends Connecticut’s consumer data privacy law and establishes a data broker registration law. Altogether, the two bills significantly redefine the state’s privacy law and introduce requirements for the use of AI.

In the coming weeks, we will be posting articles analyzing several of the key aspects of these bills. In this first article, we analyze SB 5’s provisions as they relate to the use of automated employment decision technologies (AEDT).

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Key point: Louisiana’s legislature passed a consumer data privacy bill, five bills crossed chambers in Illinois, nine bills crossed chambers in California, and Delaware’s House passed a bill to significantly amend the state’s consumer data privacy law.

Below is the 19th update on the status of proposed state privacy and AI legislation in 2026.

This article was republished on IAPP on May 12, 2026.

Key point: The Colorado legislature passed a bill to replace Colorado’s existing artificial intelligence (AI) law with a more business-friendly regulatory regime focused on disclosures and limited consumer rights but, in doing so, added to the growing complexity of state AI regulation.

On May 12, the Colorado legislature passed SB 189, which repeals and replaces the Colorado AI Act. The bill will next head to Colorado Governor Jared Polis, who is expected to sign it, having been a driving force in the drafting of the bill.

SB 189 removes many of the hallmarks of the Colorado AI Act — such as a duty of care, risk management programs, and impact assessments — in favor of a disclosure-based framework with limited rights in narrow circumstances. That said, the bill’s January 1, 2027, effective date means that it will go into effect — the legislature will not reconvene until January 11, 2027 — thereby ending the uncertainty as to whether a Colorado AI law will go into effect.

The bill is complex, with many intertwined definitions and numerous exceptions. The article below provides an overview of the bill, digging into its many nuances. In addition, on May 18 from 12-1 p.m. ET, David Stauss will be hosting a webinar analyzing the bill.

Although the bill removes and narrows obligations under the existing law, Colorado still will have the most far-reaching legislatively enacted deployer/private sector AI law of any state. Further, the bill’s passage only adds to an increasingly complex state regulatory regime for businesses to navigate when deploying AI systems, including the California Consumer Privacy Act’s risk assessment and automated decision-making technology (ADMT) regulations and, in the employment context, laws in Illinois, New York City, and soon-to-be Connecticut.

Key point: Last week, Connecticut’s legislature passed a bill to amend the state’s consumer data privacy law and establish a data broker registration law, Iowa’s governor signed a chatbot bill into law, Colorado’s legislature passed a pricing bill and is poised to pass a bill to repeal and replace the Colorado AI Act, and Vermont’s legislature passed a health care AI bill.

Below is the 17th update on the status of proposed state privacy and AI legislation in 2026. With the state legislative activity slowing, we have combined our weekly privacy and AI posts.