Frances Waldmann is a senior litigation associate in the Los Angeles office of Gibson, Dunn & Crutcher.  She is a member of the firm’s Privacy, Cybersecurity and Data Innovation, Artificial Intelligence and Automated Systems, and Antitrust and Competition practice groups.

Ms. Waldmann has represented multinational companies in a variety of industries (including transportation, consumer electronics, telecommunications, entertainment, and financial services) in technology-driven litigation and regulatory investigations by U.S. and international enforcement authorities.  She also advises clients on the global legal and regulatory implications of artificial intelligence (AI) and other emerging technologies.  Ms. Waldmann is admitted to practice in the United States and England & Wales, and bilingual in English and German.

Privacy and AI: Ms. Waldmann counsels technology-focused clients on regulatory compliance with respect to the developing body of law on emerging technologies and the sharing economy, including the development and implementation of policies and governance mechanisms.  She has particular expertise in legal, ethical and policy developments surrounding AI and automation, and advises companies navigating the evolving regulatory landscape for technologies such as autonomous and connected vehicles, facial recognition, advanced augmented reality, and natural language processing.

Ms. Waldmann also has substantial experience representing companies with respect to global privacy and cybersecurity issues, including relating to legal and regulatory compliance with the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), General Data Protection Regulation (GDPR), and other federal, state, and international laws and regulations.

Ms. Waldmann spearheads Gibson Dunn’s Quarterly AI and Automated Systems Client Update.  She regularly speaks on issues concerning AI regulatory and litigation trends, and has contributed to various publications, including “United States: Artificial Intelligence,” published in the GDR Insight Handbook 2021.

Antitrust litigation and investigations: Ms. Waldmann’s antitrust experience includes the defense of civil lawsuits, including class action matters, as well as international cartel and antitrust-related grand jury investigations by U.S. and global antitrust enforcers.  She has represented clients in cross-border competition, white collar defense, and regulatory enforcement matters initiated by government agencies including the DOJ, FTC, SEC, CFTC, EPA, CARB, European Commission, Germany’s Central Bank (Bundesbank), and the U.K.’s Financial Conduct Authority and Serious Fraud Office.  Ms. Waldmann has also conducted sensitive internal investigations on behalf of companies and board committees related to corporate compliance issues.

Representative matters include:

• Advising multiple 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.
• Counseling numerous companies on the legal and ethical policies and procedures applicable to their AI products, systems and services, including the establishment and implementation of data collection, retention, and privacy policies, as well as advising on related aspects of law enforcement disclosures and cybersecurity.
• Advising a 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 a technology company against claims brought under Section 2 of the Sherman Act.
• Representing an electronics company in a civil class action lawsuit alleging a price-fixing conspiracy.
• Representing a financial institution in a class action lawsuit in S.D.N.Y. stemming from governmental investigations regarding the ISDAFIX benchmark rate.
• Representing a global financial institution in connection with international investigations into LIBOR and foreign exchange trading.

Ms. Waldmann maintains an active pro practice.  In 2021, she was awarded Gibson Dunn’s Frank Wheat Memorial Award for her contributions to the firm’s pro bono 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.  On June 1, 2020, President Barack Obama published a blog post, “How to Make this Moment the Turning Point for Real Change,” in which he shared the link to the community-based policing report and toolkit.

Ms. Waldmann 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 in London.

She is a member of the State Bars of California and New York and the Bar of England and Wales.