Frances Waldmann is an associate in the Los Angeles office of Gibson, Dunn & Crutcher.  She practices in the firm’s Privacy, Cybersecurity and Data Innovation, Artificial Intelligence and Automated Systems, and Antitrust and Competition groups, with a focus on data privacy and consumer protection matters.

Ms. Waldmann’s practice spans litigation, regulatory enforcement, and counseling representations.  She represents technology-focused companies in regulatory investigations and inquiries by the Federal Trade Commission (FTC), Department of Justice (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.  Ms. Waldmann has substantial experience representing technology-focused companies in complex litigation, including data privacy, consumer protection, antitrust, and commercial contract disputes and class action matters.

Ms. Waldmann also advises companies on regulatory compliance with the FTC Act, California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), General Data Protection Regulation (GDPR), state biometric privacy laws, and other federal, state, and international laws and regulations.  She has particular experience counseling clients across industries on regulatory compliance and product strategies with respect to the developing body of law in the United States, the UK, and the EU on data regulation, AI/ML, and other emerging technologies.  Ms. Waldmann has advised clients on the development and implementation of policies and governance mechanisms, industry best practices and technical standards, and risk mitigation strategies for a variety of cutting-edge technologies, including autonomous and connected vehicles, facial recognition, advanced augmented reality, and natural language processing.

Representative matters include:

• Represented social networking company in non-public FTC investigation related to disclosures regarding the company’s use of consumers’ personal information.
• Represented public company in non-public FTC investigation of potentially deceptive advertising claims.
• Advised 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.
• Advised 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.
• Defended technology company against claims brought under Section 2 of the Sherman Act.
• Defended numerous major businesses in connection with antitrust-related grand jury investigations brought by DOJ.
• Represented electronics company in a civil class action lawsuit alleging a price-fixing conspiracy.
• Represented financial institution in a class action lawsuit in S.D.N.Y. stemming from governmental investigations regarding the ISDAFIX benchmark rate.
• Represented global financial institution in connection with international investigations into LIBOR and foreign exchange trading.

Ms. Waldmann maintains a significant 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.

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.