Shruti Bhutani Arora

Consumer Protection & Regulatory Defense
Shruti advises companies on compliance with federal and state consumer protection laws and represents clients in high-stakes investigations and enforcement actions before the Federal Trade Commission (FTC) and state attorneys general. Her work includes responding to civil investigative demands, subpoenas and enforcement proceedings involving digital platforms, advertising practices, subscription models, data-driven products and emerging technologies.

She counsels clients on advertising substantiation, endorsements and influencer marketing, social media campaigns, negative option and subscription programs, automatic renewals, ad targeting practices, media buying arrangements, and promotional marketing initiatives, including raffles, sweepstakes and contests. She works closely with clients to structure consumer-facing programs that withstand regulatory scrutiny while preserving commercial objectives.

Data Protection, Privacy & Governance
Shruti advises companies on data protection, privacy compliance, governance and regulatory defense across the evolving landscape of U.S. state comprehensive privacy laws and related regulatory regimes. She represents clients in regulatory investigations and enforcement actions involving privacy, data governance and cross-border data practices, including matters before the FTC and state attorneys general.

Her work spans biometric privacy laws, employee privacy laws, protections for minors’ data, social media regulation, cross-border data transfers, and sector-specific compliance frameworks. She designs and implements enterprise-wide privacy and governance programs and develops defensible compliance strategies that withstand regulatory scrutiny.

Shruti advises health tech companies on compliance with the Health Insurance Portability and Accountability Act (HIPAA), including privacy, security and breach notification requirements governing protected health information (PHI). She assists clients in preparing for and responding to HIPAA audits and investigations, strengthening compliance controls, and mitigating enforcement exposure. She counsels fintech and financial services companies on compliance with the Gramm-Leach-Bliley Act (GLBA), financial privacy obligations, and safeguarding requirements. Her work enables clients to operationalize defensible compliance frameworks across consumer data, sensitive personal data, financial information, health data, and infrastructure-related data environments.

She also advises companies on compliance with the U.S. Department of Justice’s Data Security Program (DSP) rule and related national security-driven data restrictions. Her work includes restricted transaction analysis, cross-border data transfer risk assessments, vendor and counterparty diligence, and implementation of operational safeguards addressing sensitive personal data and foreign access concerns.

Cybersecurity & Incident Response
Shruti advises companies on cybersecurity risk management, preparedness and breach response. She conducts tabletop exercises and incident response simulations to test escalation protocols, executive coordination and regulatory reporting obligations.

In the event of a security incident, she guides clients through forensic coordination, legal risk assessment, breach notification analysis under state, federal and sector-specific laws, and preparation of required notices to regulators and affected individuals. She also advises on regulatory engagement and communications strategies to mitigate enforcement and reputational exposure.

Artificial Intelligence
Shruti advises companies across the AI lifecycle, from model developers to deployers of AI systems, on governance, risk management and regulatory compliance. She counsels clients on the design, development, testing, and deployment of AI systems, including large language models, machine learning models, agentic AI tools and MCP servers used in both consumer-facing and employment contexts.

She also helps organizations design and implement practical compliance strategies, which include AI impact assessments, governance framework design, transparency and accountability measures, and integration of data protection and security safeguards from product conception through launch.

Shruti closely monitors legislative and regulatory developments in artificial intelligence and helps companies anticipate and operationalize emerging statutory and regulatory requirements.

• Advised a leading social media platform on employee privacy issues and assisted in building employee privacy program.
• Assisted clients in fields such as ecommerce, gaming and SaaS products with California Consumer Privacy Act (CCPA) compliance.
• Assisted a luxury hotel management company with General Data Protection Regulation (GDPR) and CCPA compliance, including preparing internal documentation and training personnel.
• Assisted academic organizations with privacy compliance.
• Advised clients on assessing data incidents and determining appropriate responses.
• Assisted clients with drafting and negotiating complex technology contracts, including a technology partnership agreement for a technology client, a master SaaS and services agreement for COVID-19-related products, and a master services agreement for a client providing sterilization and decontamination services.
• Advised U.S. and India-based clients on trademark prosecution matters, including a brand use agreement for a social networking platform and contest guidelines for an education platform.
• Directed negotiations for complex technology contracts with industry leaders, including Fortune 500 companies, and counseled clients in advertising agreements, services agreements and other commercial transactions.
• Renegotiated escrow clause trigger on behalf of client providing SaaS-based service to Canadian insurance company.
• Enabled client to continue operations in India by demonstrating that exporting customer data from the United States to India was allowed under HIPAA regulations subject to HIPAA compliance.
• Advised startup in redefining the company as a technology platform versus advertising agency, which decreased potential liability surrounding copyright law. Presented case law and federal statute that verified acceptance of terms constitutes proper signature for copyright assignment.
• Built trademark portfolio of more than 200 trademark applications and registrations as lead attorney. Assisted clients in all aspects of trademark prosecution-related matters.
• Defended clients in privacy and unfair competition enforcement actions, including advising clients on the strategy regarding the notices of violations and inquiry letters, preparing responses to the alleged notices of violations and inquiry letters, negotiating settlements and preparing audit reports on behalf of clients pursuant to the settlement terms.
• Assisted clients with a range of counseling and compliance needs related to a variety of U.S. privacy laws, including compliance program planning; operationalizing privacy requirements; recordkeeping and retention requirements; development of internal policies and procedures; and preparing data mapping, data processing agreements (DPAs), data protection impact assessments (DPIAs), public-facing privacy policies and jurisdiction-specific privacy notices.
• Advised clients on the limitations on and exceptions to consumer privacy requests; applicability thresholds and exceptions in U.S. privacy laws; profiling requirements; defensible data deletion; and limitations on service providers, contractors and processors.
• Advised clients on and prepared AI governance practices and documentations.
• Advised on AdTech issues, particularly compliance with laws and regulatory guidance on the use of online tracking technologies, cross-domain tracking, cross-context behavioral advertising, do-not-sell and do-not-share requirements, use of hashed identifiers, and developing architecture that effectively sends the downward opt-out signal to client’s vendors classified as third parties.
• Prepared policies and notices, including online privacy, internal privacy, data classification and handling, acceptable use, personal data transfer and records retention (and related schedules).
• Prepared and negotiated privacy-related portions of master services agreements and data protection addenda for technology consulting, digital marketing, subscriptions and other professional services.
• Conducted privacy-focused M&A due diligence.
• Assisted clients with a range of counseling and compliance needs related to the CCPA and New York City’s Local Law 144, including compliance program planning and establishment, recordkeeping, data subject requests, applicable exceptions and authentication, and privacy policies and notices.
• Advised clients on productivity and monitoring analysis and other uses of HR personnel data.
• Advised clients and prepared and edited responses to the regulator’s inquiry about employee data privacy practices under the CCPA.
• Advised, prepared and negotiated technology agreements, such as technology partnership agreements, software license agreements, purchase agreements, terms of service agreements, master services agreements, software as a service agreements, other as a service agreements and service level agreements, as well as advertising and marketing agreements, such as agency agreements, media buys and activations, brand collaborations, sponsorships, digital marketing and influencer protocols.
• Advised clients on trademark and copyright registrations; responded to office actions from the U.S. Patent and Trademark Office (USPTO) and oppositions from third parties; and negotiated trademark co-existence and settlement agreements, brand use agreements, agreements on behalf of music artists (such as providing voice-over and music for a character in a video game), and agreements with performance-right organizations like the American Society of Composers, Authors & Publishers (ASCAP) and BMI, etc. Also advised clients on contests and sweepstakes.

• “AI Made Me Do It: What Attorneys and HR Professionals Need to Know About Ethical and Compliance Risks When Using AI in Employment Decisions,” California Lawyers Association Annual Meeting, September 13, 2025.
• “Privacy in Flux – Navigating New Laws, Enforcement, and AI’s Impact,” South Asian Bar Association’s Annual Conference, June 20, 2025.