The Supply Chain Is a Circle: AI, Privacy, and People

Alicia Solow-Niederman*

Artificial Intelligence (AI) governance underscores the AI “supply chain” and the “many hands” involved in the creation of AI systems. Although invaluable, this production-centered approach risks overlooking what happens when people use AI tools. That’s a mistake, because user intera ctions determine the real-world impact of AI.

This Article contends that regulating AI and holding the appropriate actors responsible requires far more attention to what happens after deployment of an AI system. The supply chain is an invaluable start, but it’s not a linear chain. Rather, it is a circle that must incorporate users’ engagement with AI tools as part of post-deployment feedback. To do so, we must distinguish among different categories of challenges that occur as people engage with AI tools. Focusing on information privacy as a concrete example, I identify three types of challenges that arise in , out of , and via generative AI systems. Each type requires a different kind of policy response. Unless we account for the contextual ways that humans interact with AI systems on the ground, it is users who will bear the cost of harms, and our regulatory interventions will remain incomplete at best and pernicious at worst.

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© 2026 Alicia Solow-Niederman. Individuals and nonprofit institutions may reproduce and distribute copies of the Work in any format, at or below cost, for educational purposes, so long as each copy identifies the author, provides a citation to the Notre Dame Law Review Reflection, and includes this provision and copyright notice.

*Associate Professor of Law, The George Washington University. For invaluable comments, questions, and support, thank you to A. Feder Cooper, Sev Engelmann, James Grimmelmann, Claudia Haupt, Yafit Lev-Aretz, Helen Nissenbaum, Paul Ohm, and Frank Pasquale, as well as participants at the 2024 GenLaw DC Workshop, the 2024 GW Law Faculty Retreat Junior Scholarship Showcase, the Digital Life Initiative Colloquium at Cornell Tech, and the Yale Law School Information Society Project Ideas Lunch. Thank you to Rhyia Bibby and Charlsie Doan for expert research assistance. I wish to also thank technology journalists, including but not limited to individuals at the Washington Post who were laid off in February 2026, whose reporting informed me of so many of the stories I include in this Article. All remaining errors and omissions are my own.