PREPARED WRITTEN TESTIMONY AND STATEMENT FOR THE RECORD OF Danielle Keats Citron Morton Sophia Macht Professor of Law University of Maryland Carey School of Law HEARING ON “The National Security Challenge of Artificial Intelligence Manipulated Media and ‘Deep Fakes’” BEFORE THE House Permanent Select Committee on Intelligence June 13 2019 Longworth House Office Building Room 1100 Washington D C As of July 1 2019 Citron will join the faculty of Boston University School of Law as a Professor of Law 1 I INTRODUCTION Chairman Schiff Ranking Member and Committee Members thank you for inviting me to appear before you to testify about manipulated media generally and “deep fakes” specifically My name is Danielle Keats Citron I am the Morton Sophia Macht Professor of Law at the University of Maryland Carey School of Law where I have taught for fifteen years On July 1 2019 I am joining the faculty of Boston University School of Law as a Professor of Law In addition to my home institutions I am an Affiliate Scholar at Stanford Law School’s Center on Internet Society Affiliate Fellow at Yale Law School’s Information Society Project and Tech Fellow at NYU Law’s Policing Project I am a member of the American Law Institute where I have been an adviser to the Restatement Third Information Privacy Principles Project I have written extensively about privacy free speech and civil rights publishing more than 30 articles in major law reviews and scores of opinion pieces for major news outlets 1 My book HATE CRIMES IN CYBERSPACE Harvard University Press 2014 tackled the phenomenon of cyber stalking In academic and popular writing Professor Robert Chesney and I have explored the looming challenges to democracy national security and privacy posed by deep fakes 2 My testimony grows out of and draws upon that research Pictures may be worth a thousand words but little is as persuasive as audio and video recordings Audio and video recordings allow us to become firsthand witnesses to events obviating the need to trust others’ accounts They let us see and hear for ourselves 3 Even the Supreme Court has endorsed the truth-telling power of audio and video content If a video shows someone driving recklessly then the person drove recklessly 4 Creators of deep fakes count on us to rely on what our eyes and ears are telling us and therein lies the danger 1 See e g Sexual Privacy 128 YALE L J 1870 2019 When Law Frees Us to Speak 87 F ORDHAM L R EV 2317 2019 with Jonathon Penney Why Sexual Privacy Matters for Trust 96 WASH U L R EV forthcoming 2019 Four Principles for Digital Speech 95 WASH U L R EV 1353 2018 with Neil Richards Extremist Speech Compelled Conformity and Censorship Creep 93 N OTRE D AME L R EV 1035 2018 Risk and Anxiety A Theory of Data Breach Harms 96 T EXAS L R EV 2018 with Daniel J Solove The Internet Will Not Break Denying Bad Samaritans Section 230 Immunity 86 F ORDHAM L R EV 401 2017 with Benjamin Wittes The Privacy Policymaking of State Attorneys General 92 N OTRE D AME L R EV 747 2016 Spying Inc 72 WASH L EE L R EV 1243 2015 Criminalizing Revenge Porn 49 WAKE F OREST L R EV 345 2014 with Mary Anne Franks The Scored Society 89 WASH L R EV 1 2014 with Frank Pasquale The Right to Quantitative Privacy 98 MINN L REV 62 2013 with David Gray Intermediaries and Hate Speech Fostering Digital Citizenship for the Information Age 91 B U L REV 1435 2011 with Helen Norton Network Accountability for the Domestic Intelligence Apparatus 62 HASTINGS L J 1441 2011 with Frank Pasquale Mainstreaming Privacy Torts 99 CAL L REV 1805 2010 Government Speech 2 0 87 DENVER U L REV 899 2010 with Helen Norton Fulfilling Government 2 0’s Promise with Robust Privacy Protections 78 GEO WASH L REV 822 2010 Law’s Expressive Value in Combating Cyber Gender Harassment 108 MICH L REV 373 2009 Cyber Civil Rights 89 B U L REV 61 2009 Technological Due Process 85 WASH U L REV 1249 2008 Reservoirs of Danger The Evolution of Public and Private Law at the Dawn of the Information Age 80 S CAL L REV 241 2007 2 Deep Fakes The Looming Crisis for Privacy Democracy and National Security 107 CALIF L REV forthcoming 2019 with Robert Chesney Symposium Foreword 21st Century Truth Decay Deep Fakes and the Challenge for Free Expression National Security and Privacy MD L REV forthcoming 2019 with Robert Chesney Deep Fakes and the New Disinformation War F OREIGN AFFAIRS January February 2019 edition with Robert Chesney Disinformation on Steroids The Threat of Deep Fakes COUNCIL ON FOREIGN RELATIONS ISSUE BRIEF Oct 16 2018 with Robert Chesney Deep Fakes A Looming Crisis for National Security Democracy and Privacy L AWFARE February 21 2018 with Robert Chesney I rely extensively on my coauthored work in writing this testimony I am indebted to my coauthor Bobby Chesney for his insights 3 See Jennifer L Mnookin The Image of Truth Photographic Evidence and the Power of Analogy 10 YALE J L HUM 1 1-4 1998 4 Scott v Harris 550 U S 372 380–81 2007 ruling that a videotape of a car chase constituted definitive proof of facts so as to preclude the necessity of a trial on the merits 2 At a time when even the most basic facts are in dispute the persuasiveness of audio and video content might offer welcome clarity Video and audio recordings however can do more to mislead and misdirect than to illuminate and inform Widely-available technologies now permit the creation of fabricated video and audio recordings Today with a laptop internet access and some technical skills anyone can create fairly convincing video and audio fakes Put simply what our eyes and ears are telling us may not be true The technology behind the fakery is poised to take a great leap forward Deep-fake technologies will enable the creation of highly realistic and difficult to debunk fake audio and video content Soon it will be easy to depict someone doing or saying something that person never did or said Soon it will be hard to debunk digital impersonations in time to prevent significant damage Video and audio fakes will be impossible to distinguish from the real thing Yes disinformation has a long and storied history but it has urgent relevance today Deep fakes arrive just as the functioning of the marketplace of ideas is under serious strain Whereas media outlets committed to professional standards once supplied much of our information diet social media platforms are increasingly the go-to source for information Companies tailor content to our interests and views The resulting digital echo chambers make it seem as if everyone shares our way of thinking Falsehoods spread like wildfire on social networks Social media platforms are susceptible to information cascades whereby people pass along information shared by others without checking its validity Information that goes viral tends to be controversial and salacious People are attracted to and more likely to spread negative and novel information 5 Bots escalate the spread of misinformation 6 The declining influence of traditional media cognitive biases and social-media information dynamics have already fueled the spread of fake video and audio recordings 7 Although today’s fake video and audio content can be debunked fairly quickly particularly if creators manipulate recordings of events for which authentic copies exist real recordings often fail to catch up to salacious fakes Far too often the fakery is believed This will grow worse as more sophisticated deep-fake technology emerges The circulation of deep fakes has potentially explosive implications for individuals and society Under assault will be reputations political discourse elections journalism national security and truth as the foundation of democracy My testimony will outline the risks as well as potential legal and market solutions and their limits 5 DANIELLE KEATS C ITRON HATE CRIMES IN CYBERSPACE 2014 6 Robinson Meyer The Grim Conclusions of the Largest Ever Study of Fake News THE ATLANTIC Mar 8 2018 https www theatlantic com technology archive 2018 03 largest-study-ever-fake-news-mit-twitter 555104 quoting political scientist Dave Karpf 7 Robert Chesney Danielle Citron and Quinta Jurecic That Pelosi Video What To Do About ‘Cheapfakes’ in 2020 Lawfare May 29 2019 https www lawfareblog com about-pelosi-video-what-do-about-cheapfakes-2020 3 II DESCRIBING THE THREAT LANDSCAPE A Harm to Individuals and Companies Deep-fake videos can target individuals damaging their reputations and causing severe emotional distress 8 Let’s begin as the deep-fake trend did—with fabricated sex videos In late 2017 word got out about a subreddit devoted to deep-fake sex videos of celebrities 9 At the time the subreddit now closed had countless threads Redditors posted deep-fake sex videos of Gal Gadot and Emma Watson They sought help in making deep fakes One person said he wanted to make a deep-fake sex video of his ex-girlfriend and wondered if 30 photographs would be sufficient Posters directed one another to YouTube tutorials providing instructions on the creation of deepfake videos 10 Consider the experience of Noelle Martine Ms Martine was a high-school student in Australia when she posted videos and photos of herself on social media 11 Someone used the photos to insert her face into pornographic images the doctored photos were posted online alongside her home address and cell phone number Not long thereafter a deep-fake sex video of Ms Martine appeared showing her performing oral sex on a strange man She was inundated with death and rape threats and strangers contacted her for sex Keep in mind that Ms Martine was a high-school student Law enforcement told her that nothing could be done about the postings 12 Rana Ayyub is a journalist whose reporting has exposed corruption in Hindu national politics 13 In an apparent effort to silence her pseudonymous posters circulated a deep-fake sex video featuring her The video went viral 14 It was shared via Twitter and text messages It appeared in posts alongside her home address phone number and the phrase “I am available ”15 Her Twitter feed was overwhelmed with screenshots of the video Death and rape threats filled her email inbox Ms Ayyub was terrified For weeks she could not write let alone speak She could barely eat 16 She fears having people take photos of her in public lest they use them to create more deep fakes 17 8 See Robert Chesney Danielle Keats Citron Deep Fakes and the New Disinformation War The Coming Age of Post-Truth Geopolitics Foreign Aff Jan –Feb 2019 at 153 https www foreignaffairs com articles world 2018-12-11 deepfakes-and-new-disinformation-war 9 Samantha Cole AI-Assisted Fake Porn Is Here and We’re All Fucked MOTHERBOARD Dec 11 2017 7 18 PM https motherboard vice com en_us article gydydm gal-gadot-fake-ai-porn For a description of subreddits see What are Communities or “Subreddits” REDDIT https www reddithelp com en categories reddit-101 communities what-are-communities-or-subreddits last visited Apr 6 2019 “Reddit is a large community made up of thousands of smaller communities known as ‘subreddits ’” 10 See e g tech 4tress Deepfakes Guide Fake App 2 2 Tutorial Installation Totally Simplified Model Folder Included YOUT UBE Feb 21 2018 https www youtube com watch v Lsv38PkLsGU The Great Zasta How to Merge Faces with Fake App in 5 Minutes Quickest Tutorial YOUT UBE Feb 18 2018 https www youtube com watch v i4bar4X7ghs 11 See Ally Foster Teen’s Google Search Reveals Sickening Online Secret About Herself NEWS COM AU June 30 2018 https www news com au technology online security teens-google-search-reveals-sickening-online-secret-about-herself newsstory ee9d26010989c4b9a5c6333013ebbef2 12 TEDx Talks Sexual Predators Edited My Photos into Porn—How I Fought Back Noelle Martin TEXxPerth YOUTUBE Mar 6 2018 https www youtube com watch v PctUS31px40 13 See e g RANA AYYUB GUJARAT F ILES ANATOMY OF A COVER UP 2017 14 Siobhan O’Grady An Indian Journalist Has Been Trolled For Years Now U N Experts Say Her Life Could Be At Risk WASH POST May 26 2018 15 Rana Ayyub Opinion In India Journalists Face Slut-Shaming and Rape Threats N Y TIMES May 22 2018 https www nytimes com 2018 05 22 opinion india-journalists-slut-shaming-rape html 16 Id 17 Skype Interview of Rana Ayuub dated May 9 2019 notes on file with author 4 Like other sexual-privacy invasions deep-fake sex videos are likely to have a disproportionate impact on women and marginalized communities 18 As Ms Martin and Ms Ayyub explained being turned into a sex object without consent is terrifying embarrassing and life altering Deepfake sex videos reduce people to genitalia breasts buttocks and anus affixing them with a sexual identity not of their making 19 People have difficulty finding or keeping jobs when deep-fake sex videos appear in searches of their names They go offline even though it may hurt their careers Deep-fake videos could be used to sabotage corporate CEOs and their companies Imagine the night before a company’s Initial Public Offering a deep-fake video appears showing the CEO committing a crime If the deep-fake video is shared widely the company’s stock price may falter and a tremendous amount of money may be lost Of course the video could be debunked in a few days but by that time the damage has already been done B Disrupting Democracy Social Cohesion Public Safety and Elections at Risk Deep fakes can undermine social cohesion essential for democratic discourse We have seen the damage caused by low tech impersonations In 2016 Russia’s state-sponsored disinformation operations succeeded in deepening existing social and ideological fissures in the United States In the name of Black Lives Matters activists Russian social media accounts shared inflammatory content in an effort to stoke racial tensions In the future the disinformation could come in the form of a deep-fake video of a white police officer shouting racial slurs A deep-fake video could feature a well-known imam in New York City celebrating an ISIS attack on American soldiers in Afghanistan Deep fakes could so exacerbate societal divisions that violence ensues A century ago Justice Oliver Wendell Holmes warned of the danger of falsely shouting fire in a crowded theater 20 The panic that Holmes imagined might be modest compared to the fallout from a perfectly-timed deep fake A deep-fake video if inflammatory enough and timed just right could fuel unrest and violence Consider Baltimore City residents’ grief and anger after the senseless killing of resident Freddie Gray in police custody Imagine if the day after Mr Gray’s death a deep-fake video appeared featuring the police chief endorsing the mistreatment of Mr Gray If the video was circulated to protestors there might have been civil unrest resulting in physical violence Deep-fake videos and audios could undermine the democratic process by tipping an election Imagine that the night before the 2020 election a deep fake showed a candidate in a tight race doing something shocking he never did The deep fake if spread widely could alter the election’s outcome The deep fake creator could be a hostile state actor or non-state actors motivated to sway the election a particular way No matter the damage would be irreparable Elections cannot be undone 18 See Mary Anne Franks Ari Ezra Waldman Sex Lies and Videotape Deep Fakes and Free Speech Delusions 78 MD L REV 2019 19 See Danielle Keats Citron Sexual Privacy 128 YALE L J 1870 2019 20 Schenck v United States 249 U S 47 52 1919 Holmes J 5 C Decaying Trust Essential for Democratic Institutions Deep-fake videos will risk deepening people’s distrust in civic and political institutions Deep fakes will find an audience primed to believe the worst about lawmakers police officers and reporters Deep-fake videos could feature public officials taking bribes They could purport to show FBI special agents discussing ways to abuse their authority They could feature journalists saying they made up a politically-divisive story All of this could spark outrage at the institutions that serve as the foundation of our democracy Deep fakes may undermine journalism in other ways News organizations may be chilled from rapidly reporting real disturbing events for fear that the evidence will turn out to be fake One can expect that people will try to trap news organizations in this way We have already seen stings pursued without the benefit of deep-fake technology Convincing deep fakes may make such stings more likely to succeed leaving news organizations fearful to publish video and audio content in the future Without a quick and reliable way to authenticate video and audio the press may find it difficult to fulfill its ethical and moral obligations to the truth D Endangering National Security and Diplomacy Hostile state and nonstate actors will surely leverage deep fakes to accomplish their goals Terrorist organizations for instance could distribute deep fakes depicting adversaries— government officials military officers or soldiers—engaging in provocative actions with content chosen to maximize the galvanizing impact on target audiences Deep fakes could purport to show an Army general burning a copy of the Koran or U S soldiers murdering children Such fakes could lead to violent reprisals and aid terrorist recruitment Diplomacy is at risk as well What if in the middle of sensitive negotiations diplomats are shown a deep fake suggesting an adversary is disingenuous The video could scuttle diplomatic efforts Deep fakes could be used in counterintelligence operations inspiring reprisal against U S assets and agents E Escaping Accountability for the Truth The Liar’s Dividend It is not just that deep fake content can wreak havoc by spreading lies Wrongdoers could invoke the possibility of deep fakes to escape the truth In an environment of pervasive highly-realistic deep fakes people caught in genuine recordings of misbehavior will find it easier to cast doubt on damning evidence They could dismiss real video and audio as “deep fakes ” Education about deep fakes could inure to the benefit of wrongdoers in giving the public a sound reason to disregard real videos or audios 21 Professor Robert Chesney and I have called this the “Liar’s Dividend ” President Trump has tried to leverage this possibility in denouncing the veracity of the Lester Holt interview where he admitted that he fired FBI Director James Comey because of that “Russia 21 See Chesney Citron supra note 6 issue” and the Access Hollywood tape where he said when you are a star you can “grab ‘em by the pussy” 22 If the public were more sensitized to the deep-fake phenomenon his assertions might have been believed The more people are educated about the advent of deep fakes the more they may disbelieve real recordings Regrettably and perversely the Liar’s Dividend grows in strength as people learn more about the dangers of deep fakes But that is not to give up on the project of educating the public about deep fakes but rather to note that education efforts must include warnings about the Liar’s Dividend III SKETCHING LEGAL SOLUTIONS AND CHALLENGES Unfortunately there are no easy answers to these concerns Law could mitigate some but only some of the threat A legal agenda also faces significant practical hurdles We need the law tech companies and a heavy dose of societal resilience to make our way through these challenges A Legal Tools and Free Speech Considerations No criminal or civil liability regime specifically addresses the creation or distribution of deep fakes A ban on deep fake technology would not be desirable Digital manipulation is not inherently problematic There are pro-social uses of the technology Deep fakes exact significant harm in certain contexts but not in all 23 Existing civil and criminal laws would address certain deep fakes Tort law would provide redress for some deep-fake scenarios Deep-fake creators could be sued for defamation where falsehoods are circulated recklessly in the case of public figures or officials or negligently in the case of private individuals The “false light” tort—recklessly creating a harmful and false implication about someone in a public setting—likewise has potential for certain cases Subjects of deep fakes may be able to bring claims for intentional infliction of emotional distress which requires proof of “extreme and outrageous conduct ” Public figures could bring “right of publicity” claims if defendants generate financial gain from the fakes 24 Criminal law offers limited avenues for deterrence and punishment A handful of states criminalize impersonations that cause certain injuries In a few jurisdictions creators of deep fakes could face charges for criminal defamation if they posted videos knowing they were fake or if they were reckless as to their truth or falsity 25 If perpetrators post deep fakes in connection 22 In public congressional testimony in the winter of 2019 DNI Director Dan Coats and CIA Director Gina Haspel expressed their disagreement with the President’s policy towards Syria and ISIS President Trump responded swiftly to the video Rather than criticizing them the President simply asserted that neither Coats nor Haspel had disagreed with him President Trump said in so many words that it was all fake news—that the officials said that they agreed with his policies 23 It may be possible to draft a federal criminal law banning deep fakes in a sufficiently narrow way that would withstand judicial scrutiny Senator Ben Sasse has proposed a federal criminal statute that would extend to creators and publishers of deep fakes including online platforms if they knew that the deep-fake content is fake and published a deep fake knowing it enabled crimes or torts 24 See generally JENNIFER ROTHMAN R IGHT OF P UBLICITY PRIVACY REIMAGINED FOR A P UBLIC WORLD 2018 25 See Eugene Volokh One to One Speech Versus One-to-Many Speech 107 NW U L REV 731 2013 7 with the persistent targeting of individuals they might be prosecuted for violating the federal cyberstalking law as well as analogous state statutes Deep fakes implicate freedom of expression even though they involve intentionally false statements In United States v Alvarez 26 decided in 2012 plurality and concurring opinions of the Supreme Court concluded that “falsity alone” does not remove expression from First Amendment protection 27 As the plurality noted falsehoods generally warrant protection because they inspire rebuttal and “reawaken respect” for valuable ideas in public discourse 28 Central to this point is faith in the public’s willingness to counter lies and engage in reasoned discourse All of the Justices however agreed that false factual statements could be regulated in the presence of harm but differed in the particulars 29 The legal approach outlined here would comport with First Amendment commitments To start certain categories of speech are not covered by the First Amendment due to their propensity to bring about serious harms and their slight contribution to free speech values 30 Some deep fakes will fall into those categories and thus provide the basis for legal restrictions This includes defamation of private persons fraud true threats and the imminent-and-likely incitement of violence 31 Speech integral to criminal conduct like extortion blackmail and perjury has long been understood to enjoy no First Amendment protection 32 The First Amendment would likely countenance prosecutions for harm-causing impersonations of individuals As Helen Norton explains laws banning the impersonation of government officials are “largely uncontroversial as a First Amendment matter in great part because they address real if often intangible harm to the public as well as to the individual target ” 33 Free expression values would not be undermined Lies about the source of speech—whether a particular person is the one actually speaking—often undermine rather than protect free speech values 34 Deep fakes deny listeners the ability to assess the quality and credibility of speech undermining democratic self-governance and the search for truth 35 They undermine trust as to who is actually speaking and make it difficult to assess speakers’ reliability To be sure law should not proscribe deep fakes that amount to parody and satire and the legal agenda advocated here would not do so 26 United States v Alvarez 567 U S 709 2012 plurality opinion 27 Id at 719 28 Id at 719 722 29 Alvarez 567 U S at 719 plurality opinion 731-34 Breyer J concurring and 750 Alito J dissenting 30 See generally C ITRON HATE CRIMES IN CYBERSPACE supra note Error Bookmark not defined at 199-218 discussing narrow categories of low-value speech accorded less rigorous protection or no protection under First Amendment analysis 31 See Alan Chen Justin Marceau High Value Lies Ugly Truths and the First Amendment 68 VAND L REV 1435 2015 32 CITRON HATE CRIMES IN CYBERSPACE supra note at 203-05 33 Helen Norton Lies to Manipulate Misappropriate and Acquire Government Power in L AW AND L IES 143 168 Austin Sarat ed 2015 34 Id at 168 35 Helen Norton Thirteen Ways of Looking at Election Lies 71 OKLA L REV 117 131 2018 8 B Limits In some contexts legal claims and criminal prosecutions may be theoretically possible but practically infeasible For a start it may be difficult to attribute the creation of a deep fake to a particular person or group For civil claims and criminal prosecutions to work perpetrators need to be found and identified Even if perpetrators are identified they may be beyond the court’s reach as in the case of foreign individuals or governments To pursue actions against creators courts need to have jurisdiction over them Then too criminal investigations may founder if officers lack training in technology and the law 36 Civil litigation may not be a practical response given its expense Individuals usually bear the costs of bringing civil claims and those costs can be steep For most people it would be too costly to sue deep-fake creators It would be difficult to find lawyers to work on cases on a contingency basis because many creators will be judgment-proof To be sure lawyers would have an incentive to take cases on contingency if social media providers could be sued Although online platforms are in the best position to minimize harm they enjoy a broad-sweeping immunity from liability for user-generated content under Section 230 of the Communications Decency Act The immunity means that platforms are free to ignore the propagation of damaging deep fakes even ones that platforms know cause specific and immediate harms As I have argued with Benjamin Wittes 37 Quinta Jurecic 38 and Professor Chesney 39 that federal immunity should be amended to condition the immunity on reasonable moderation practices rather than the free pass that exists today The current interpretation of Section 230 leaves platforms with no incentive to address destructive deep-fake content To be sure there are platforms that do not need civil liability exposure to combat such obvious harms market pressures and morals in some cases are enough However market pressures and morals are not always enough and they should not have to be I am grateful to Chairman Schiff for inviting me to discuss my research with Professor Robert Chesney I appreciate the Committee’s engagement on this issue and its desire to tackle the looming challenges raised by deep fakes 36 As I explore in my book law enforcement routinely fails to address cyber stalking and other forms of online abuse for these reasons Citron supra note 37 See Danielle Keats Citron Benjamin Wittes The Internet Will Not Break Denying Bad Samaritans Section 230 Immunity 86 FORDHAM L REV 401 407 n 52 2017 38 Danielle Citron Quinta Jurecic Platform Justice Content Moderation at an Inflection Point HOOVER INST 2018 https www hoover org sites default files research docs citron-jurecic_webreadypdf pdf https perma cc V7T4-X8Y4 39 Chesney Citron supra note 9 BIOGRAPHY On July 1 2019 Professor Danielle Citron will join the faculty of Boston University School of Law as a Professor of Law From 2004 to June 30 2019 she taught at the University of Maryland Carey School of Law where she received the 2018 UMD Champion of Excellence award for teaching and scholarship Professor Citron has been a Visiting Professor at Fordham University School of Law Fall 2018 and George Washington Law School Spring 2017 After settling in at BU Law she will visit Harvard Law School Professor Citron teaches and writes about data privacy free expression civil rights and administrative law Professor Citron is an internationally recognized privacy expert Her book Hate Crimes in Cyberspace Harvard University Press explored the phenomenon of cyber stalking and the role of law and private companies in combating it The editors of Cosmopolitan included her book in its “20 Best Moments for Women in 2014 ” Professor Citron has published numerous book chapters and more than 30 law review articles published in the Yale Law Journal California Law Review twice Michigan Law Review twice Harvard Law Review Forum Boston University Law Review three times Notre Dame Law Review twice Fordham Law Review twice George Washington Law Review Minnesota Law Review Texas Law Review Washington University Law Review three times Southern California Law Review Washington Lee Law Review Wake Forest Law Review Washington Law Review twice UC Davis Law Review and other journals Her current scholarly projects concern sexual privacy privacy and national security challenges of deep fakes and the automated administrative state Professor Citron's opinion pieces have appeared in major media outlets including The New York Times The Atlantic Slate Time CNN The Guardian New Scientist Lawfare ars technica and New York Daily News She is a technology contributor for Forbes and served as a long-time member of the now-defunct Concurring Opinions blog 2008-2019 Professor Citron's work has been recognized at home and abroad In 2015 the United Kingdom’s Prospect Magazine named Professor Citron one of the “Top 50 World Thinkers ” The Maryland Daily Record named her one of the “Top 50 Most Influential Marylanders ” In 2011 Professor Citron testified about misogynistic cyber hate speech before the Inter-Parliamentary Committee on Anti-Semitism at the House of Commons Professor Citron is an active member of the cyber law community She is an Affiliate Scholar at the Stanford Center on Internet and Society Affiliate Fellow at the Yale Information Society Project Senior Fellow at Future of Privacy and Tech Fellow at the NYU Policing Project She is a member of the American Law Institute inducted in 2017 and serves as an adviser to the American Law Institute’s Restatement Third Information Privacy Principles Project She is a member of the Principals Group for the Harvard-MIT AI Fund Professor Citron works with civil liberties and privacy organizations She is the Vice President of the Cyber Civil Rights Initiative She served as the Chair of the Electronic Privacy Information Center’s Board of Directors from 2017-2019 and now sits on its Board Professor Citron has served on the Advisory Boards of Without My Consent Teach Privacy SurvJustice and the International Association of Privacy Professionals Privacy Bar In connection with her advocacy work she advises tech companies 10 on online safety privacy and free speech She serves on Twitter’s Trust and Safety Council as well as Facebook's Nonconsensual Intimate Imagery Task Force She has presented her research at Twitter Facebook Google and Microsoft Professor Citron advises federal and state legislators law enforcement and international lawmakers on privacy issues In July 2017 she testified at a congressional briefing on online harassment and sexual violence co-sponsored by Congresswoman Jackie Speier In April 2015 she testified at a congressional briefing sponsored by Congresswoman Katharine Clark on the First Amendment implications of a federal cyber stalking legal agenda She has worked with the offices of Congresswoman Katharine Clark Senator Elizabeth Warren Senator Kamala Harris and Senator Diane Feinstein on federal legislation Professor Citron helped Maryland State Senator Jon Cardin draft a bill criminalizing the nonconsensual publication of nude images which was passed into law in 2014 From 2014 to December 2016 Professor Citron served as an advisor to California Attorney General Kamala Harris She served as a member of AG Harris’s Task Force to Combat Cyber Exploitation and Violence Against Women In October 2015 Professor Citron with AG Harris spoke at a press conference to discuss the AG office’s new online hub of resources for law enforcement technology companies and victims of cyber sexual exploitation Professor Citron has presented her research in over 200 talks at federal agencies meetings of the National Association of Attorneys General the National Holocaust Museum the AntiDefamation League Wikimedia Foundation universities companies and think tanks She appeared in HBO’s Swiped Hooking Up in the Digital Age directed by Nancy Jo Sales and Netizens which premiered at the 2018 Tribeca Film Festival directed by Cynthia Lowen She has been quoted in hundreds of news stories in publications including The New York Times Washington Post Wall Street Journal Los Angeles Times San Francisco Chronicle USA Today National Public Radio Time Newsweek the New Yorker New York Magazine Cosmopolitan HBO’s John Oliver Show Barron’s Financial Times The Guardian Vice News and BBC She is a frequent guest on National Public Radio shows including All Things Considered WHYY’s Radio Times WNYC’s Public Radio International Minnesota Public Radio WYPR’s Midday with Dan Rodricks Wisconsin Public Radio WAMU's 1A WAMU’s The Diane Rehm Show and Chicago Public Radio She will be giving a TED talk on the issue of deep fakes at this year’s Global TED Summit in Edinburgh Scotland 11