Your Client’s AI Drew a State AG Inquiry: Response and Resolution for Business Counsel

Paul Singer, Partner | Kelley Drye

Paul Singer is a partner at Kelley Drye & Warren LLP and a nationally recognized authority on state attorney general investigations, consumer protection, advertising, privacy, and regulatory enforcement. Drawing on more than two decades of service in the Texas Attorney General’s Office, he advises companies facing investigations and enforcement actions by state attorneys general and other regulators. Paul leverages his extensive government experience to help clients navigate regulatory scrutiny, develop compliance strategies, and protect their legal, business, and reputational interests.

• Education & Credentials

Paul earned his Juris Doctor from The University of Texas School of Law and his Bachelor of Arts, with high honors, from The University of Texas at Austin. His practice focuses on consumer protection, advertising, privacy, data security, and state attorney general enforcement matters.

• Recognition & Leadership

Paul is ranked by Chambers USA as a leading lawyer for State Attorneys General practice, with clients praising his commercial judgment, legal insight, and ability to resolve complex regulatory matters. He has also been recommended by The Legal 500 and received the Career Staff of the Year Award from the National Association of Attorneys General in 2020 and the Faculty of the Year Award from the National Attorneys General Training and Research Institute for his contributions to legal education. He was also selected for the NAGTRI International Fellows Program in 2018.

• Professional Involvement

Paul is an active member of the American Bar Association Antitrust Section and Consumer Protection Committee, the State Bar of Texas Consumer and Commercial Law Section, and the Austin Bar Association. He is also a Fellow of the American Academy of Forensic Sciences and a delegate to the International Association of Forensic Sciences. A frequent speaker, Paul regularly presents nationally on consumer protection, privacy, technology, and state attorney general enforcement issues.

• Experience

Before joining Kelley Drye, Paul spent more than 20 years in the Texas Attorney General’s Office, including serving as Division Chief of the Consumer Protection Division and later Associate Deputy Attorney General for Civil Litigation, where he oversaw the agency’s plaintiff-side civil litigation. He led numerous multistate investigations involving Fortune 500 companies and played a key role in securing significant nationwide settlements. His experience includes serving as principal drafter of the $26 billion opioid settlement with distributors and a manufacturer, leading the first state enforcement action under COPPA, participating in major antitrust litigation involving digital advertising, negotiating a wireless carrier settlement that provided more than $300 million in consumer redress, and leading investigations that resulted in more than $30 million in restitution. Today, he applies that experience to representing companies in government investigations, enforcement actions, compliance counseling, and public policy matters involving consumer protection and privacy.

Beth Chun, Special Counsel | Kelley Drye

Beth Chun is Special Counsel at Kelley Drye & Warren LLP, where she advises clients on state attorney general investigations, consumer protection, advertising, privacy, data security, and regulatory compliance. Drawing on nearly a decade of experience in the Texas Attorney General’s Consumer Protection Division, Beth helps companies respond to consumer complaints, civil investigative demands, subpoenas, and enforcement actions while minimizing legal and business risks.

• Education & Credentials

Beth earned her Juris Doctor from The University of Texas School of Law in 2012, where she served as a submissions and articles editor for the Texas International Law Journal. She received her Bachelor of Arts in History and Managerial Studies from Rice University in 2009. She is admitted to practice in Texas, the District of Columbia, and the U.S. District Court for the Western District of Texas.

• Recognition & Leadership

During her tenure with the Texas Attorney General’s Office, Beth co-chaired the states’ CAFA Working Group, served as the principal drafter for numerous multistate investigations, and supervised the Consumer Protection Division’s intake and complaint team. Her leadership in multistate enforcement matters has made her a trusted advisor on state consumer protection priorities and regulatory investigations.

• Professional Involvement

Beth is a member of the Texas Bar and the District of Columbia Bar. She frequently advises businesses across financial services, healthcare, media, real estate, retail, software, and technology sectors on consumer protection compliance, subscription marketing, privacy, and advertising law.

• Experience

Before joining Kelley Drye, Beth spent nearly ten years in the Texas Attorney General’s Consumer Protection Division, where she investigated and prosecuted violations of state and federal consumer protection laws and led numerous multistate investigations involving national companies. Her representative matters include serving as lead counsel in a digital payment processing investigation, participating on the executive committee for a $113 million multistate smartphone manufacturer settlement, leading a tourism website investigation, and serving as co-counsel on wireless cramming settlements that secured more than $300 million in consumer restitution. She now represents companies in state attorney general investigations, compliance counseling, and consumer protection matters involving advertising, privacy, and automatic renewal laws.

Abigail Stempson, Special Counsel | Kelley Drye

Abby Stempson focuses her practice on state attorneys general (AG) investigations and advising on AG priorities and consumer protection compliance. Abby’s experience includes both proactive and defensive counseling. She frequently advocates for clients and trade associations at the staff and executive level at State AG offices, using her wide network of contacts to obtain superior client results. Abby also defends clients in state and federal enforcement actions, responds to subpoenas and civil investigative demands, and leads internal investigations and compliance review. She has engaged in this work for clients in many industries ranging from the pharmaceutical, real estate, travel, multinational retail, and financial sectors.

• Education & Credentials

Abigail earned her J.D. from the University of Nebraska College of Law in 2004 and her B.S. in Business Administration with an accounting emphasis from the University of Nebraska–Lincoln in 2001. She is admitted to practice in the District of Columbia and Nebraska.

• Recognition & Leadership

Abigail is ranked nationally in Chambers USA for State AG work (2026). She received the FTC Bureau of Consumer Protection Partner Award in 2022 and the NAAG Executive Director Award in 2021.

• Professional Involvement

Abigail has served as a board member of the National Association of State Charities Officials and taught as an adjunct professor at the University of Nebraska–Lincoln College of Business from 2004 to 2017.

• Experience

Prior to joining KDW, Abby was Director of the National Attorneys General Training and Research Institute’s Center for Consumer Protection at the National Association of Attorneys General (NAAG), where she interacted with state AGs and their staff, at every level, in all 50 states. She provided training and research and was often called upon to serve as a national resource on state AG consumer protection priorities and enforcement authority.

Prior to NAAG, Abby was Chief of the Public Protection Bureau and Consumer Protection Division in the Nebraska Attorney General’s Office and an assistant attorney general, where she focused on consumer fraud and deceptive trade practices, nonprofit organizations, charitable trusts, and antitrust matters. She led Nebraska’s White Collar Fraud Task Force, was a member of the Suspicious Activity Report state review team and served as a board member of the National Association of State Charities Officials. Abby acted in leadership roles on numerous multi-state consumer protection matters. She also served as an adjunct professor at the University of Nebraska for 13 years.

Andrea deLorimier, Senior Associate | Kelley Drye

Andrea deLorimier focuses her practice on consumer protection and advertising law, advising companies on compliance across the full lifecycle of the customer experience. Her work spans product formulation and safety, packaging and labeling, advertising development and claim substantiation, and point-of-purchase considerations.

• Education & Credentials

Andrea earned her J.D., magna cum laude, from Southern Methodist University’s Dedman School of Law in 2020 and her B.S., cum laude, in Philosophy and Psychology from Texas A&M University in 2017. She is admitted to practice in Texas (2020) and is a Certified Information Privacy Professional/United States (CIPP/US). Andrea is only admitted in Texas; she practices under the supervision of principals of the firm who are members of the D.C. Bar.

• Recognition & Leadership

Andrea received a 2026 Burton Award for Distinguished Legal Writing (with John Villafranco).

• Professional Involvement

Andrea serves as the Young Lawyer Representative to the American Bar Association’s Consumer Protection Committee.

• Experience

Andrea also has significant privacy law experience, counseling businesses regarding comprehensive state privacy laws and federal privacy frameworks such as the FTC Act, COPPA, and financial privacy laws. She counsels on topics including data collection and use, targeted advertising, and emerging technologies like artificial intelligence.

She regularly represents clients in contested advertising and privacy matters before the Federal Trade Commission (FTC), state attorneys general, and the National Advertising Division (NAD), helping companies navigate investigations and enforcement actions.

Prior to joining the firm, Andrea was a litigator and defended clients in consumer class actions, privacy litigation, and antitrust disputes. She continues to leverage this litigation experience in her current practice, representing clients in complex advertising and privacy-related cases.

Andrea also was an intern for the Federal Trade Commission’s Southwest Regional Office, where she gained firsthand insight into the agency’s investigative processes. She is a Certified Information Privacy Professional/United States (CIPP/US).

SESSION 1 – Responding to a State AG Demand Over a Small Company’s AI Tools | 1:00pm – 2:00pm

This session equips business counsel with a practical framework for responding when a state attorney general issues a civil investigative demand or demand letter targeting a small company’s AI tools. Attorneys will learn how AGs are applying existing consumer protection, privacy, and anti-discrimination statutes to AI deployments, what the anatomy of a CID looks like and how to challenge or narrow it, and how to execute a defensible first-30-days response without triggering escalation. At the end of this session, attendees will be able to triage an AG inquiry, assess multistate exposure, protect privilege, and make the critical early tactical decisions that determine whether an investigation resolves cooperatively or escalates to litigation.

BREAK | 2:00pm – 2:10pm

SESSION 2 – Negotiating the Assurance of Voluntary Compliance and Closing the AI Inquiry | 2:10pm – 3:10pm

This session guides business counsel through the negotiation, drafting, and post-resolution compliance obligations of state AG assurances of voluntary compliance (AVCs) and assurances of discontinuance (AODs) in AI-related enforcement matters. Using landmark resolutions — Texas v. Pieces Technologies (2024) and Massachusetts v. Earnest Operations (2025) as teaching templates, the session examines what drives monetary exposure versus no-penalty outcomes, how to negotiate AVC terms, and what ongoing compliance obligations a resolved AI inquiry typically imposes. Attorneys leave with a practical framework for evaluating settlement posture, negotiating specific AVC provisions, managing multistate escalation risk, and structuring post-resolution compliance programs.