The Limits of AI Data Transparency Policy: Three Disclosure Fallacies

Data transparency has emerged as a rallying cry for addressing concerns about AI: data quality, privacy, and copyright chief among them. Yet while these calls are crucial for accountability, current transparency policies often fall short of their intended aims. Similar to nutrition facts for food, policies aimed at nutrition facts for AI currently suffer from a limited consideration of research on effective disclosures. We offer an institutional perspective and identify three common fallacies in policy implementations of data disclosures for AI. First, many data transparency proposals exhibit a specification gap between the stated goals of data transparency and the actual disclosures necessary to achieve such goals. Second, reform attempts exhibit an enforcement gap between required disclosures on paper and enforcement to ensure compliance in fact. Third, policy proposals manifest an impact gap between disclosed information and meaningful changes in developer practices and public understanding. Informed by the social science on transparency, our analysis identifies affirmative paths for transparency that are effective rather than merely symbolic.

Comparing AI Agents to Cybersecurity Professionals in Real-World Penetration Testing

We present the first comprehensive evaluation of AI agents against human cybersecurity professionals in a live enterprise environment. We evaluate ten cybersecurity professionals alongside six existing AI agents and ARTEMIS, our new agent scaffold, on a large university network consisting of ~8,000 hosts across 12 subnets. ARTEMIS is a multi-agent framework featuring dynamic prompt generation, arbitrary sub-agents, and automatic vulnerability triaging. In our comparative study, ARTEMIS placed second overall, discovering 9 valid vulnerabilities with an 82% valid submission rate and outperforming 9 of 10 human participants. While existing scaffolds such as Codex and CyAgent underperformed relative to most human participants, ARTEMIS demonstrated technical sophistication and submission quality comparable to the strongest participants. We observe that AI agents offer advantages in systematic enumeration, parallel exploitation, and cost -- certain ARTEMIS variants cost $18/hour versus $60/hour for professional penetration testers. We also identify key capability gaps: AI agents exhibit higher false-positive rates and struggle with GUI-based tasks.

Near-Exponential Savings for Mean Estimation with Active Learning

We study the problem of efficiently estimating the mean of a $k$-class random variable, $Y$, using a limited number of labels, $N$, in settings where the analyst has access to auxiliary information (i.e.: covariates) $X$ that may be informative about $Y$. We propose an active learning algorithm ("PartiBandits") to estimate $\mathbb{E}[Y]$. The algorithm yields an estimate, $\widehatμ_{\text{PB}}$, such that $\left( \widehatμ_{\text{PB}} - \mathbb{E}[Y]\right)^2$ is $\tilde{\mathcal{O}}\left( \frac{ν+ \exp(c \cdot (-N/\log(N))) }{N} \right)$, where $c > 0$ is a constant and $ν$ is the risk of the Bayes-optimal classifier. PartiBandits is essentially a two-stage algorithm. In the first stage, it learns a partition of the unlabeled data that shrinks the average conditional variance of $Y$. In the second stage it uses a UCB-style subroutine ("WarmStart-UCB") to request labels from each stratum round-by-round. Both the main algorithm's and the subroutine's convergence rates are minimax optimal in classical settings. PartiBandits bridges the UCB and disagreement-based approaches to active learning despite these two approaches being designed to tackle very different tasks. We illustrate our methods through simulation using nationwide electronic health records. Our methods can be implemented using the PartiBandits package in R.

AI for Statutory Simplification: A Comprehensive State Legal Corpus and Labor Benchmark

One of the emerging use cases of AI in law is for code simplification: streamlining, distilling, and simplifying complex statutory or regulatory language. One U.S. state has claimed to eliminate one third of its state code using AI. Yet we lack systematic evaluations of the accuracy, reliability, and risks of such approaches. We introduce LaborBench, a question-and-answer benchmark dataset designed to evaluate AI capabilities in this domain. We leverage a unique data source to create LaborBench: a dataset updated annually by teams of lawyers at the U.S. Department of Labor, who compile differences in unemployment insurance laws across 50 states for over 101 dimensions in a six-month process, culminating in a 200-page publication of tables. Inspired by our collaboration with one U.S. state to explore using large language models (LLMs) to simplify codes in this domain, where complexity is particularly acute, we transform the DOL publication into LaborBench. This provides a unique benchmark for AI capacity to conduct, distill, and extract realistic statutory and regulatory information. To assess the performance of retrieval augmented generation (RAG) approaches, we also compile StateCodes, a novel and comprehensive state statute and regulatory corpus of 8.7 GB, enabling much more systematic research into state codes. We then benchmark the performance of information retrieval and state-of-the-art large LLMs on this data and show that while these models are helpful as preliminary research for code simplification, the overall accuracy is far below the touted promises for LLMs as end-to-end pipelines for regulatory simplification.

BountyBench: Dollar Impact of AI Agent Attackers and Defenders on Real-World Cybersecurity Systems

AI agents have the potential to significantly alter the cybersecurity landscape. To help us understand this change, we introduce the first framework to capture offensive and defensive cyber-capabilities in evolving real-world systems. Instantiating this framework with BountyBench, we set up 25 systems with complex, real-world codebases. To capture the vulnerability lifecycle, we define three task types: Detect (detecting a new vulnerability), Exploit (exploiting a specific vulnerability), and Patch (patching a specific vulnerability). For Detect, we construct a new success indicator, which is general across vulnerability types and provides localized evaluation. We manually set up the environment for each system, including installing packages, setting up server(s), and hydrating database(s). We add 40 bug bounties, which are vulnerabilities with monetary awards from \$10 to \$30,485, and cover 9 of the OWASP Top 10 Risks. To modulate task difficulty, we devise a new strategy based on information to guide detection, interpolating from identifying a zero day to exploiting a specific vulnerability. We evaluate 5 agents: Claude Code, OpenAI Codex CLI, and custom agents with GPT-4.1, Gemini 2.5 Pro Preview, and Claude 3.7 Sonnet Thinking. Given up to three attempts, the top-performing agents are Claude Code (5% on Detect, mapping to \$1,350), Custom Agent with Claude 3.7 Sonnet Thinking (5% on Detect, mapping to \$1,025; 67.5% on Exploit), and OpenAI Codex CLI (5% on Detect, mapping to \$2,400; 90% on Patch, mapping to \$14,422). OpenAI Codex CLI and Claude Code are more capable at defense, achieving higher Patch scores of 90% and 87.5%, compared to Exploit scores of 32.5% and 57.5% respectively; in contrast, the custom agents are relatively balanced between offense and defense, achieving Exploit scores of 40-67.5% and Patch scores of 45-60%.

Extracting memorized pieces of (copyrighted) books from open-weight language models

Plaintiffs and defendants in copyright lawsuits over generative AI often make sweeping, opposing claims about the extent to which large language models (LLMs) have memorized plaintiffs' protected expression. Drawing on adversarial ML and copyright law, we show that these polarized positions dramatically oversimplify the relationship between memorization and copyright. To do so, we leverage a recent probabilistic extraction technique to extract pieces of the Books3 dataset from 13 open-weight LLMs. Through numerous experiments, we show that it's possible to extract substantial parts of at least some books from different LLMs. This is evidence that the LLMs have memorized the extracted text; this memorized content is copied inside the model parameters. But the results are complicated: the extent of memorization varies both by model and by book. With our specific experiments, we find that the largest LLMs don't memorize most books -- either in whole or in part. However, we also find that Llama 3.1 70B memorizes some books, like Harry Potter and 1984, almost entirely. We discuss why our results have significant implications for copyright cases, though not ones that unambiguously favor either side.

A Reasoning-Focused Legal Retrieval Benchmark

As the legal community increasingly examines the use of large language models (LLMs) for various legal applications, legal AI developers have turned to retrieval-augmented LLMs ("RAG" systems) to improve system performance and robustness. An obstacle to the development of specialized RAG systems is the lack of realistic legal RAG benchmarks which capture the complexity of both legal retrieval and downstream legal question-answering. To address this, we introduce two novel legal RAG benchmarks: Bar Exam QA and Housing Statute QA. Our tasks correspond to real-world legal research tasks, and were produced through annotation processes which resemble legal research. We describe the construction of these benchmarks and the performance of existing retriever pipelines. Our results suggest that legal RAG remains a challenging application, thus motivating future research.

Fairness through Difference Awareness: Measuring Desired Group Discrimination in LLMs

Algorithmic fairness has conventionally adopted a perspective of racial color-blindness (i.e., difference unaware treatment). We contend that in a range of important settings, group difference awareness matters. For example, differentiating between groups may be necessary in legal contexts (e.g., the U.S. compulsory draft applies to men but not women) and harm assessments (e.g., calling a girl a terrorist may be less harmful than calling a Muslim person one). In our work we first introduce an important distinction between descriptive (fact-based), normative (value-based), and correlation (association-based) benchmarks. This distinction is significant because each category requires distinct interpretation and mitigation tailored to its specific characteristics. Then, we present a benchmark suite composed of eight different scenarios for a total of 16k questions that enables us to assess difference awareness. Finally, we show results across ten models that demonstrate difference awareness is a distinct dimension of fairness where existing bias mitigation strategies may backfire.

Machine Unlearning Doesn't Do What You Think: Lessons for Generative AI Policy, Research, and Practice

We articulate fundamental mismatches between technical methods for machine unlearning in Generative AI, and documented aspirations for broader impact that these methods could have for law and policy. These aspirations are both numerous and varied, motivated by issues that pertain to privacy, copyright, safety, and more. For example, unlearning is often invoked as a solution for removing the effects of targeted information from a generative-AI model's parameters, e.g., a particular individual's personal data or in-copyright expression of Spiderman that was included in the model's training data. Unlearning is also proposed as a way to prevent a model from generating targeted types of information in its outputs, e.g., generations that closely resemble a particular individual's data or reflect the concept of "Spiderman." Both of these goals--the targeted removal of information from a model and the targeted suppression of information from a model's outputs--present various technical and substantive challenges. We provide a framework for thinking rigorously about these challenges, which enables us to be clear about why unlearning is not a general-purpose solution for circumscribing generative-AI model behavior in service of broader positive impact. We aim for conceptual clarity and to encourage more thoughtful communication among machine learning (ML), law, and policy experts who seek to develop and apply technical methods for compliance with policy objectives.

Belief in the Machine: Investigating Epistemological Blind Spots of Language Models

As language models (LMs) become integral to fields like healthcare, law, and journalism, their ability to differentiate between fact, belief, and knowledge is essential for reliable decision-making. Failure to grasp these distinctions can lead to significant consequences in areas such as medical diagnosis, legal judgments, and dissemination of fake news. Despite this, current literature has largely focused on more complex issues such as theory of mind, overlooking more fundamental epistemic challenges. This study systematically evaluates the epistemic reasoning capabilities of modern LMs, including GPT-4, Claude-3, and Llama-3, using a new dataset, KaBLE, consisting of 13,000 questions across 13 tasks. Our results reveal key limitations. First, while LMs achieve 86% accuracy on factual scenarios, their performance drops significantly with false scenarios, particularly in belief-related tasks. Second, LMs struggle with recognizing and affirming personal beliefs, especially when those beliefs contradict factual data, which raises concerns for applications in healthcare and counseling, where engaging with a person's beliefs is critical. Third, we identify a salient bias in how LMs process first-person versus third-person beliefs, performing better on third-person tasks (80.7%) compared to first-person tasks (54.4%). Fourth, LMs lack a robust understanding of the factive nature of knowledge, namely, that knowledge inherently requires truth. Fifth, LMs rely on linguistic cues for fact-checking and sometimes bypass the deeper reasoning. These findings highlight significant concerns about current LMs' ability to reason about truth, belief, and knowledge while emphasizing the need for advancements in these areas before broad deployment in critical sectors.