Comment from Cline, Stevie
Stevie ClineSupportIndividual
Summary: Stevie Michelle Cline, a legal scholar and practitioner, submits a comment in support of the Proposed Policy Statement Concerning the Suppression of Accuracy in Artificial Intelligence Systems. She argues that the statement addresses a genuine problem of consumer deception but recommends six specific revisions to ensure the policy is durable against litigation, clear for compliance, and aligned with existing national frameworks.
Please see the attached comment of Stevie Michelle Cline, submitted in her personal capacity, in support of the Proposed Policy Statement Concerning the Suppression of Accuracy in Artificial Intelligence Systems, 91 Fed. Reg. 41,638 (July 7, 2026), subject to six recommended revisions addressed to the final statement's durability in litigation and implementation: (1) fortifying the preemption analysis; (2) defining the intentionality predicate; (3) making the disclosure safe harbor operational; (4) aligning the guardrail carve-outs with the National Policy Framework; (5) answering the First Amendment defense in advance; and (6) completing the evidentiary record. The complete comment with citations is contained in the attached PDF.