Joint Interpretation Agreement — Advertising and Representations

Requesting party: {{requesting_party_name}} Interpreting authority: Utah Office of Artificial Intelligence Policy (OAIP) Statute at issue: Utah Code §13-72a-202 (prohibited representations) Product: {{product_name}} Marketing channels in scope: {{marketing_channels}}

Summary

The parties agree on which categories of marketing claims about {{product_name}} fall within §13-72a-202's prohibition on misrepresenting an AI mental-health chatbot as a licensed clinician or as a substitute for clinical care, and what claim language remains permissible.

Question presented

Which marketing claims about {{product_name}} cross the line from permissible feature description into prohibited misrepresentation under §13-72a-202?

Interpretation

1. Permissible claim categories: {{claim_types_used}}, when each claim is qualified with language indicating the service is an AI chatbot, not a licensed clinician. 2. Prohibited claims that {{requesting_party_name}} agrees not to make: {{prohibited_claims_acknowledged}}. 3. Any claim using the words "diagnose," "treat," "therapy," or comparable clinical-practice language is presumptively prohibited unless qualified per (1) and submitted for separate review. 4. The same standard applies across every channel listed in {{marketing_channels}}, including third-party listings the provider controls or supplies copy for.

Terms

• Restriction: No claim that {{product_name}} diagnoses, treats, or substitutes for licensed mental-health care.
• Restriction: No use of clinical-practice terminology without the qualifying language required above.
• Requirement: Marketing copy on all listed channels carries a visible "AI chatbot — not a licensed clinician" qualifier in the same view as any feature claim.
• Permission: Claims describing supportive features (listening, journaling prompts, mood tracking) are permitted when properly qualified.

Statute citations

• Utah Code §13-72a-202 — https://everyailaw.com/regulation/utah-sb149/#mental-health-chatbot-prohibited-representations

Limitations

Applies to {{product_name}} as currently marketed. New product lines, materially new claim categories, or new channels not listed above require a superseding interpretation.

Effective date and review

Effective on signature. Reviewed no later than {{review_date}}.