Frances Waldmann

Frances Waldmann is of counsel in the firm’s Los Angeles Office and a member of the Privacy, Cybersecurity and Data Innovation, Artificial Intelligence, and Antitrust groups. Her practice focuses on advising companies on a wide range of matters related to artificial intelligence (AI) and other emerging technologies, including product counseling and governance, regulatory enforcement, and high-stakes litigation.

Frances has significant expertise advising technology-focused companies on global regulatory compliance with existing laws that affect AI-related technologies, such as the FTC Act, California Consumer Privacy Act (CCPA), General Data Protection Regulation (GDPR), state biometric privacy laws, and other federal, state, and international laws and regulations. She regularly represents clients in investigations and regulatory inquiries by the FTC, DOJ, and other U.S. and global government regulators, agencies, and bodies, including international cartel and antitrust-related grand jury investigations by U.S. and global antitrust enforcers.

Leveraging her international experience and her deep knowledge of the fast developing AI-related global legal and policy framework and emerging regulatory expectations, Frances also acts as a strategic advisor to clients in their development of AI-related products and services—including large-scale machine learning models, voice assistants, autonomous and connected vehicles, facial recognition, and AR/VR.  She helps clients navigate product design concerns and launches, the development and implementation of policies and responsible corporate governance mechanisms, industry best practices and technical standards, and risk mitigation strategies.

Recent matters include:

• Advising clients across industries on legal and regulatory risk in connection with generative AI tools, and the development and implementation of policies governing their use.

• Counseling major technology company with respect to legal, regulatory, compliance, and policy issues in connection with data governance and AI/ML product development.

• Representing major technology company in class action lawsuit in connection with algorithmic decisioning.

• Representing social networking company in non-public FTC investigation related to disclosures regarding the use of consumers’ personal information.

• Representing public company in non-public FTC investigation of potentially deceptive advertising claims.

• Advising several major technologies companies in legal and regulatory compliance matters with regard to data-driven products and services incorporating advanced AI and automation capabilities, including providing advice on commenting on or preparing for proposed and pending legislation and regulations.

• Advising technology company on regulatory compliance related to the use of biometric technologies, including facial recognition, and on the collection, use, and retention of data, as well as policies and approaches to minimizing bias and disparate impact in its operations.

• Defending technology company against claims brought under Section 2 of the Sherman Act.

Frances devotes substantial time to pro bono matters. In 2021, she was awarded Gibson Dunn’s Frank Wheat Memorial Award for her contributions to the firm’s efforts related to policing accountability, including a collaboration with the Leadership Conference Education Fund on a comprehensive report and toolkit on police reform in the United States.

Frances received her law degree from Magdalen College, Oxford.  She practiced in Gibson Dunn’s London office from 2014 to 2016 and, prior to joining Gibson Dunn, at a leading set of barristers’ chambers, appearing in all manner of proceedings, including jury trials and tribunal hearings, as both a sole and junior advocate. Frances is a native German speaker and proficient in French.

Capabilities

• Artificial Intelligence
• Anti-Corruption & FCPA
• Media, Entertainment, and Technology
• Privacy, Cybersecurity, and Data Innovation
• Tech and Innovation
• Technology Litigation

Credentials

Education:

• Worcester College - University of Oxford - 2009 Masters
• Magdalen College - University of Oxford - 2008 BA (Hons) Jurisprudence

Admissions:

• California Bar
• New York Bar