Davis Polk partner Joe Hall authored “Agentic AI and securities law: The machine as a manipulator” in Law360. The third article in a five-part series, this piece examines how agentic AI creates new challenges for securities law doctrines governing market manipulation. Joe notes, “The manipulation doctrine has always been built around an actor whose intent is to mislead the market. Agentic AI threatens that construction in a particularly direct way.”

Throughout the article, Joe discusses the traditional concept of manipulation, the spoofing problem in the agentic context, the limits of designing against fraud, and potential doctrinal responses. 

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