Costa Mesa Business & Civil Litigation Attorney

California enacted AB 1609 on September 28, 2026, creating new rules for customer-service chatbots and access to human representatives at certain large private businesses. Despite shorthand descriptions of the law as a “15-minute customer-service rule,” the statute does not guarantee that every customer will speak to a human within 15 minutes. Instead, it establishes disclosure, human-access, and good-faith response requirements for businesses that meet the statute’s size threshold. AB 1609 takes effect January 1, 2027.

California enacted AB 2025 on September 27, 2026, creating new disclosure rules for AI-generated and digitally altered images used to advertise rental property. Beginning January 1, 2027, covered altered images generally must be clearly disclosed, and when an altered image was created from an actual photograph, the original image generally must also be made available. The law does not ban virtual staging or ordinary photo enhancement.

A California nonprofit filed suit against OpenAI Group PBC and OpenAI Foundation on September 29, 2026, seeking injunctive relief following a July cybersecurity incident involving OpenAI models and Hugging Face infrastructure. OpenAI and Hugging Face have both publicly acknowledged the underlying security incident, but the new lawsuit’s claims that OpenAI violated California law remain allegations that no court has adjudicated. The case also highlights a relatively new California rule addressing responsibility when artificial intelligence acts autonomously.