X.AI LLC v. Rob Bonta

Issue: Whether California Assembly Bill 2013's mandatory public disclosure requirements compelling AI developers to reveal training dataset sources, descriptions, and data-point counts violate the First Amendment's prohibition on compelled speech, the Takings Clause's just-compensation requirement, and the void-for-vagueness doctrine as applied to xAI's proprietary generative AI training data.

X.AI LLC filed a pre-enforcement complaint on December 29, 2025 in the Central District of California under 42 U.S.C. §1983 and *Ex parte Young*, seeking declaratory and injunctive relief against California Attorney General Rob Bonta before AB 2013 takes effect on January 1, 2026. xAI argues that AB 2013's compelled disclosure of training-dataset information constitutes both a per se and regulatory taking under the Fifth Amendment because it destroys the economic value of trade secrets protected under the federal Defend Trade Secrets Act and California law. On the First Amendment claim, xAI contends that because AB 2013's legislative history explicitly targets bias "identification and mitigation," the disclosures are content- and viewpoint-based compelled speech subject to strict scrutiny, which the law cannot survive given its lack of narrow tailoring and availability of less restrictive alternatives. xAI further argues the statute is unconstitutionally vague because it fails to specify which AI systems it covers, whether it applies to training or all development datasets, and how detailed the required disclosures must be.

This complaint presents a direct First Amendment challenge to a state government's attempt to regulate AI transparency through mandatory disclosure of proprietary training data, potentially setting precedent on whether compelled disclosure regimes targeting AI development methods receive strict or intermediate scrutiny. The case also tests the outer boundary of trade-secret property rights as against state AI accountability legislation, a question no circuit court has yet resolved.