Character.AI filed for bankruptcy on October 12. Disney is licensing some of its technology for $20 million. Not in that deal: the app, the chats and the characters people built, including personas of mothers, fathers and friends who have died. Those stay in the estate, and any other bidder can make an offer until November 20 at 5 p.m. The federal law that limits selling customer data protects the customer. It was not written for the dead.
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Company counsel told the court Disney “is not interested” in sensitive user data, and that no buyer has yet offered for the user data or the chatbot business. REPORTED That narrows the risk today. It does not close it: the bidding rules let others bid for “other assets” until November 20. INFERENCE
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Three people are tied to one memorial persona. Tap each to see which laws reach them. The legal readings are Infera's, from the statute text and reporting. Not legal advice. INFERENCE
The statute protects the one who typed. Not the one who was typed about.
And one more clause: Character.AI's privacy policy reportedly reserves the right “to keep that Character active on the Services” after its creator deletes their account. A user who deletes everything to keep a parent's persona out of a sale may leave the public character behind, as an estate asset. REPORTED SAN INFERENCE
The help center says chat exports take three to four weeks and the download link expires after seven days. REPORTED Drag to the day you request yours and see where it lands against the court's calendar.
If a persona holds someone you lost, request the export today from the app's settings. Save the file somewhere you control within seven days of the link arriving.
Deleting your account may not remove a public character, and deletion “may not mean that that data is gone from model training,” per Common Sense Media. REPORTED
Attorneys general from 39 states and D.C. filed notice on October 14 seeking nine conditions on any buyer, including a chance for every user to delete before a sale. FACT REPORTED
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Of the data-sale bankruptcies we found, only one produced a written recommendation about people who have died. INFERENCE from the cases below.
Sold to TTAM for $305 million. The court-appointed privacy ombudsman, Neil Richards, recommended the buyer honor existing policies and add safeguards for the dead. REPORTED
Implement posthumous use safeguards, since people who have died cannot delete their data.
Google bought the dead airline's workplace archive for $10 million, to train AI. Customer and loyalty data on about 150 million records was carved out to stay clear of the customer-data rule. REPORTED A chat about a dead parent isn't anonymized by removing the user's email. INFERENCE
The “talk with the dead” video company filed Chapter 11 owing $10.5 million. The case was dismissed in April 2025. There is no public record of what happened to the recordings of the dead. REPORTED
The FTC's rule of thumb: privacy promises travel with the data, no standalone sale of customer files, and a buyer in the same line of business. FACT The rule protects promises. It does nothing where the promise allowed transfer, or for someone who never got a promise because they were already dead. INFERENCE
Before the bid deadline, Infera names the branches and the signal for each. We will score this brief after the proposed November 24 sale hearing and publish whichever branch happened, including if it is one we did not list.
A buyer offers for the consumer app, chats or characters. Expect a motion for a consumer privacy ombudsman and the states' nine conditions in the sale order.
Disney's deal closes; the consumer platform is wound down. The question becomes a data destruction plan, and whether anyone asks what happens to personas of the dead.
A buyer keeps the app alive. Personas survive under a new owner's policy, with or without the states' conditions attached.