“Colorado’s efforts to regulate artificial intelligence (“AI”) in employment decisions have reached a critical turning point. The most recent reform proposals under Senate Bill 25B-004 (“SB-004”) include liability provisions that would significantly expand exposure to AI developers under both the Colorado Anti-Discrimination Act (“CADA”), Colo. Rev. Stat. § 24-34-401 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. (“Title VII”), despite the AI developer not being an employer. “
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