Cooling system construction contracts for AI data centers

In short

An AI data center’s cooling system is no longer just mechanical trade work. It is a core performance system that determines whether the chips can run. The move from air cooling to liquid cooling, driven by rack densities that now reach 140 kW or more, is becoming the standard for new AI and some cloud builds. Tom’s Hardware The contract must allocate risk for a technology that can cause an unplanned outage, must comply with new EPA limits on refrigerants that take effect January 1 2027, and must manage equipment that now takes over a year to arrive. 40 CFR § 84.54(a)(11), (c)(13), Law firm analysis EPC contracts are increasingly used for AI data center construction because they put substantial responsibility on the contractor and allow for fast track delivery. Construction Dive The performance guarantees, the testing protocols, the liquidated damages, the water use terms, and the supply chain clauses all look different than they did even two years ago.

What is different about cooling an AI data center?

Ordinary enterprise servers generate heat that a roomful of air handlers can still manage. A rack of NVIDIA Blackwell Ultra GPUs runs at roughly 140 kilowatts. That is roughly seven times the thermal density that air cooling can handle efficiently. Tom’s Hardware Above about 20 to 30 kW per rack, air cooling stops working well, so AI data centers must use liquid cooling.

Two main liquid cooling approaches are used. Direct-to-chip single phase cooling puts cold plates on processors, GPUs, and memory modules. A facility water loop carries heat away to a rooftop cooler or cooling tower. Direct-to-chip two phase cooling uses a refrigerant that boils inside the cold plate, drawing heat away more efficiently. Two-phase systems can handle rack loads up to 170 kW. LinkedIn citing ASME InterPACK 2024

Liquid cooling changes the construction contract because a failure is sudden and sharp. In a traditional air cooled room, if the air handler stops, the volume of air in the room provides several minutes of thermal buffer. In a liquid cooled system, if the flow stops, the chip temperatures spike in seconds. ASHRAE TC 9.9 presentation on liquid cooling resiliency The contract must treat the cooling subsystem as mission-critical infrastructure, not as an MEP afterthought.

The global market for AI data center cooling, both air and liquid, was about $15.65 billion in 2025 and is expected to reach $40.78 billion by 2033. DataM Intelligence Liquid cooling alone was a $4.8 billion market in 2025, on track for $27.1 billion by 2035. Global Market Insights

The regulatory floor, EPA HFC refrigerant limits

The cooling system uses a refrigerant. Under the American Innovation and Manufacturing Act of 2020, the EPA is phasing down hydrofluorocarbons, or HFCs, which are potent greenhouse gases. Two rules matter directly for construction contracts.

First, the Technology Transitions rule (40 CFR Part 84, Subpart B) says that new data center, information technology equipment facility, and computer room cooling equipment, manufactured or imported (for self-contained products) or installed (for field-assembled systems) on or after January 1 2027 must use a refrigerant with a global warming potential below 700. 40 CFR § 84.54, EPA Technology Transitions HFC restrictions by sector Chilled-water plants that serve the data floor face the same GWP limit, but the compliance date for them was January 1 2025 because they are treated as comfort cooling chillers. The 2027 date for the data hall equipment itself was not changed in the May 2026 reconsideration rule. EPA

That is a design specification that a construction contract must impose on the contractor, or the owner will not get a permit to operate. If the owner is buying the equipment, the purchase order must confirm the GWP rating.

Second, the HFC Management Rule (with leak repair requirements applying as of January 1, 2026) imposes leak detection and repair duties on owners and operators of appliances that hold 15 pounds or more of HFC refrigerant. 89 FR 82682 For industrial process refrigeration equipment with a charge of 1,500 pounds or more, automatic leak detection must be installed by January 1 2026 for new systems and January 1 2027 for existing ones. Tax alert The owner must fix leaks that exceed certain thresholds, 30 percent for industrial process refrigeration, 20 percent for commercial refrigeration, and 10 percent for comfort cooling, within 30 days. If a repair does not hold, the owner must develop a retrofit or retirement plan. The contractor’s scope may need to include commissioning the leak detection system and warrantying that the refrigerant charge stays below the trigger level during the warranty period.

Industry standards that shape the cooling specification

The construction contract does not design the system. But it must incorporate the design criteria that the system must meet. Three sets of standards dominate.

ASHRAE thermal guidelines

ASHRAE Technical Committee 9.9 publishes the thermal envelope that IT equipment expects. For standard enterprise servers (the A class), the recommended inlet temperature is 18 to 27 degrees Celsius, and the allowable upper limit is 32 degrees Celsius. For high density AI systems, ASHRAE introduced the H1 class. The recommended inlet temperature is a tighter 18 to 22 degrees Celsius, and the allowable upper limit is only 25 degrees Celsius. Envigilance That tighter band translates directly into a performance specification in the contract.

The ASHRAE guidelines also set water temperature classes. The Facility Water System (FWS) temperature, called the W class, runs from W17 to W45 (about 45 degrees Celsius) and an open ended W plus. The minimum Technology Cooling System (TCS) fluid temperature must stay at least 2 degrees Celsius above the room dew point to avoid condensation. Dallas ASHRAE presentation The Technology Cooling System (TCS) supply temperature, called the S class, now ranges from S 20 (20 degrees Celsius) to S 50. Large CDU approach temperature ranges result in ITE inlet temperatures 3 to 15 degrees Celsius or more higher than the facility water supply temperature. ASHRAE TC 9.9 Thermal Guidelines presentation

The cooling system contract must state the target S class and W class and confirm that the equipment can maintain those temperatures under the design heat load.

Uptime Institute tier requirements

The uptime tier that an AI data center targets drives the redundancy that the cooling contract must deliver. Tier III requires N plus 1 cooling redundancy with multiple independent distribution paths. Any single cooling component or distribution path can be taken out of service without interrupting the IT load. The design expects 99.982 percent uptime. Uptime Institute tier classification Tier IV requires 2N plus 1 redundancy, meaning two completely independent and physically isolated cooling subsystems each capable of carrying the full load. The design expects 99.995 percent uptime. A Tier IV facility is often required for the largest hyperscale AI data centers, and the contract must demonstrate the redundancy and isolation through integrated systems testing.

The critical role of the CDU

The Coolant Distribution Unit, or CDU, sits between the facility water loop and the technology cooling loop that serves the chips. It is a heat exchanger that keeps those two loops thermally connected but physically isolated. ASHRAE issued a Technical Alert in 2025 identifying the CDU’s role in isolating the TCS from the FWS as the key function for reliable liquid cooling. ASHRAE TC 9.9 Technical Alert on CDUs There was no standardized industry rating for most liquid to liquid CDUs until ANSI/ASHRAE Addendum b to Standard 127-2020 established a method of test for rating CDUs, published February 27, 2026. ASHRAE Addendum b to Standard 127-2020 That makes it hard to compare vendor claims, and the contract must rely on factory acceptance testing and a performance specification rather than a published rating.

In October 2025, the Open Compute Project and ASHRAE formed a formal alliance to harmonize OCP cooling specifications with ASHRAE liquid cooling classes for high-density AI workloads. OCP-ASHRAE Alliance That alignment should eventually give contract drafters a more consistent set of technical references.

How the construction contract is being restructured

EPC over design-build

More AI data center owners are choosing an Engineering, Procurement, and Construction (EPC) contract over a traditional design-build arrangement. In an EPC structure, a single contractor takes responsibility for design, procurement, construction, and commissioning of the cooling system under a fixed price, a guaranteed maximum price (GMP), or a target price. In an EPC contract, the contractor bears substantial risk for delivering a turnkey facility that meets the owner’s requirements, including designing and constructing the project on time and on budget. Construction Dive

An EPC contract lets the owner fast-track the schedule by overlapping design, procurement, and construction, which is critical when the equipment alone can take more than a year to arrive. It also gives the owner a single point of accountability for the cooling system, which is valuable because cooling-related failures caused about 13 percent of data center outages in Uptime Institute’s 2023 analysis. Data center delivery models primer, Uptime Institute

AIA forms are a starting point but need heavy customization

Standard AIA documents like A101 and A201 can be adapted for an AI data center, but they require careful attention to address cooling systems, commissioning and systems testing, and coordination with specialized consultants. AIA Contracts, AIA Data Center Design, AIA Contracts The performance guarantee provisions in particular are not part of a typical AIA general conditions and must be added as a special condition or exhibit.

Prefabricated cooling skids

To reduce on-site labor and shorten the schedule, many EPC firms are using factory-built modular cooling skids. The skid includes the CDU, piping, controls, and sometimes the heat rejection unit, all tested at the factory before delivery. The EPC contract typically covers design, factory testing, transport, and site integration of prefabricated power and cooling modules under one scope. Data center EPC analysis This shifts the integration risk from the field back to the factory, which helps when skilled labor is scarce.

Performance guarantees and testing for liquid cooling

The center of the cooling contract is the set of performance guarantees. A typical set for a liquid-cooled AI data center includes five elements. Data center analysis

• Delivered cooling capacity. The system must remove a specified heat load, measured in kilowatts or megawatts, under the design conditions.
• Temperature and humidity envelope. The system must hold the inlet air in the data hall at the specified temperature, often 18 degrees Celsius plus or minus 2 degrees, and humidity at 45 percent relative humidity plus or minus 10 percent, across the full design load.
• Redundancy compliance. The system must demonstrate N plus 1 or 2N redundancy as defined by the Uptime Institute tier standard, including the ability to isolate and maintain any single component without interrupting the IT load.
• Integrated Systems Testing (IST) pass. The entire cooling system, including the controls, must pass a series of simulated failure tests. Typical tests include a loss of facility water flow, a CDU pump failure, and a power loss to the cooling loop.

The contract defines the remedy for a shortfall. The contractor gets a defined period to fix the deficiency, a make good obligation. If the shortfall persists, the contract typically imposes liquidated damages calibrated to the severity. For a capacity shortfall, damages might be calculated per kilowatt of missing capacity. For a runtime failure, damages might be calculated per hour of outage beyond the allowable downtime. The damages must be a genuine pre estimate of the owner’s loss, not a penalty, to be enforceable.

Cooling issues rose to 19 percent of data center outages in Uptime Institute’s 2024 analysis, up from 13 percent the year before, and more than half of organizations report that their most recent significant outage cost over $100,000. Uptime Institute via Envigilance So the liquidated damages clause is not a theoretical exercise.

Equipment procurement and supply chain risk

Critical components including cooling systems often face lead times exceeding one year. Law firm analysis To secure a production slot, developers are executing early purchase orders before the design is fully finalized. Those early purchase orders often require a large upfront payment, forcing the owner to carry the credit risk and the risk that the ordered equipment will still integrate with the final design.

Equipment suppliers in turn are pushing for provisions that shift risk onto the contractor, and the contractor pushes it onto the owner. The typical supplier demands include a tariff pass-through clause and an aggressive payment schedule with upfront payments before delivery, while force majeure provisions should be scrutinized to allow for schedule delays from supply chain disruptions. Tax alert Where a particular supplier is the only one that can meet the specification, the contractor has little choice but to accept those terms and pass the risk through to the owner. The EPC contract should state clearly which party bears the risk of a tariff increase and what happens if the supplier’s force majeure claim extends the delivery date beyond the contract’s liquidated damages cutoff.

The price of cooling units, backup generators, servers, and UPS systems can exceed the cost of an entire small development project, so the early purchase commitment is not trivial. Construction Dive One practical step that counsel can take is to structure the early procurement as a separate limited scope agreement for the long lead equipment only, with the full EPC contract executed later once the design is mature enough to define the full scope.

A real example of the risk. In Rogers-O’Brien Construction v. Microsoft, a contractor on a $1 billion Texas AI data center alleged that Microsoft’s failure to supply equipment and manage vendors on schedule caused cascading delays from software integration failures and faulty components. The contractor sought more than $34 million in damages. Engineering News-Record That dispute illustrates how fast procurement delays become construction delay claims.

Water use, a contract issue that did not exist a few years ago

A 100 MW U.S. AI data center may consume roughly 2 million liters (roughly 530,000 gallons) of water per day, averaged across cooling strategies, with 725,000 liters (roughly 190,000 gallons) per day consumed on site, or a little less than 40%. CRS / IEA Large hyperscale facilities can use up to 5 million gallons a day. The average water usage effectiveness (WUE) of a U.S. data center is 0.48 liters per kilowatt-hour. Lawrence Berkeley National Laboratory via Climate XChange

Water use is no longer just an environmental permit issue. It is a contract issue because of the rapid increase in state legislation. In 2025, at least 30 bills addressing AI data center water use were introduced across 13 states, and two became law. In early 2026, more than 300 AI data center related bills were introduced in 30 states in the first six weeks of the legislative session, and by mid-2026 four states had enacted water related AI data center laws. Law firm analysis, Webinar recap

Some of these laws impose direct water efficiency mandates that a cooling system must meet. Others, like Utah’s HB 76 require new large AI data centers to report water usage data to the state, with water withdrawal data published publicly, and Georgia’s SB 421 would prohibit local governments from entering into non-disclosure agreements regarding electricity or water usage of any entity. Climate XChange, GA Senate press release Oregon’s POWER Act directs the Oregon Public Utility Commission to create a separate rate class for large energy use facilities (20 MW or more) and requires new large energy users to enter into 10-year power-purchase agreements, ensuring grid infrastructure costs are allocated to their developers rather than to residential ratepayers. Tax alert And New York has a pending bill, SB 9144, that would impose a moratorium of at least three years on permits for AI data centers capable of using 20 megawatts or more. Tax alert

On the project cancellation side, Tract withdrew a proposed $14 billion AI data center facility in Maricopa County, Arizona in 2024 after local opposition. The Arizona Republic And a Virginia state court blocked the massive Prince William County Digital Gateway development in August 2025 after a homeowner lawsuit. Allianz Commercial report

The construction contract must address water. It should state whether the cooling system is designed to be closed loop, meaning it recirculates water rather than consuming it, and should include a performance guarantee tied to a maximum WUE or a maximum daily water consumption figure. It should also allocate the risk that a post contract legislative change imposes a tighter water limit, either by treating it as a change in law that entitles the contractor to an adjustment, or by leaving that risk on the owner. In some projects, the hyperscale tenant uses a zero water cooling design, as Microsoft did for its Mount Pleasant, Wisconsin campus, where most buildings will use closed loop cooling and peak daily water use is expected to reach approximately 350,000 gallons per day. WPR

Disputes and what is already happening

Construction disputes are growing. The average value of a construction dispute in North America has risen 43 percent since 2021, and nearly 30 percent of North American construction projects encountered supply chain problems in 2023. The Register

Several high-profile incidents show the particular vulnerability of cooling systems.

• The Equinix Singapore cooling failure in October 2023 happened during a planned system upgrade. A contractor incorrectly closed chilled water buffer tank valves, causing a temperature rise that knocked DBS Bank and Citibank offline for roughly two days. Some 2.5 million payment and ATM transactions failed. The Register / Envigilance The root cause was a single contractor error during maintenance. That same risk exists in a new build if the integrated systems test does not verify the isolation valves and the control sequence under a simulated contractor error condition.
• Microsoft paused construction on several billion-dollar facilities in 2025 to reassess technology choices. Allianz Commercial report
• Google paused and committed to redesigning an AI data center in Chile after an environmental court partially reversed its permit over aquifer impact during drought. Global Arbitration Review

These events give contract drafters a concrete list of risks to address. The contract should define what happens if the owner halts work to change the cooling technology mid build, should allocate the cost of a redesign, and should cover the contractor’s right to an extension of time and an equitable adjustment.

Practical steps for counsel drafting a cooling system contract

1. Anchor the design specification in measurable standards. Reference ASHRAE H1 temperature limits, a specific W class and S class, an Uptime Institute tier, and a GWP of 700 or less. Do not rely on general phrases like industry standard.

2. Build a detailed integrated systems test regime. The IST must include simulated failure of each CDU, each pump, and the primary power supply. The pass/fail criteria should be tied to the time it takes for the IT inlet temperature to exceed the allowable limit. Because a dry liquid cooling loop overheats in seconds, the test must be automated and monitored at the chip level.

3. Address the CDU procurement gap. Because there is no standard rating, the contract should require factory acceptance testing of each CDU at the full design load and temperature before delivery. The performance guarantee should cover the CDU’s thermal transfer capacity and its isolation integrity.

4. Align the liquidated damages clause with the true cost of downtime. Over half of significant AI data center outages cost more than $100,000. For a hyperscale AI cluster, the cost per minute can be far higher. The damages must be a genuine pre-estimate, and they should distinguish between a capacity shortfall, a failure during normal operation, and a failure during maintenance when the redundant component is offline.

5. Structure the early procurement to separate the equipment risk from the construction risk. Execute a limited equipment purchase order early, with the full EPC contract covering integration later. Make clear in the EPC contract which party bears the risk of a tariff increase and the risk that a supplier declares force majeure.

6. Treat water as a performance metric. Include a maximum WUE or maximum daily water volume in the performance guarantees, and assign the risk of a mid project legislative change to water limits by a change in law clause.

7. Be aware of patent risk. The number of patents in AI data center cooling technologies has grown sharply since 2004, with the largest growth in liquid cooling and direct to chip inventions. A patent clearance search before settling on a technology can mitigate infringement claims later. Law firm analysis

8. Provide for the cooling system’s commissioning data to be handed over in a format that the owner’s operations team can use for ongoing EPA HFC leak tracking. The leak detection system must be commissioned and demonstrated before substantial completion.

How the big tech companies are already doing it

Amazon Web Services has deployed a proprietary direct-to-chip system called the In-Rack Heat Exchanger. AWS states it uses 9 percent less water than fully air-cooled sites and improves power efficiency by 20 percent compared to off the shelf solutions. By 2026, AWS expects liquid-cooled capacity will exceed 20 percent of its total machine learning capacity at multi gigawatt scale. LinkedIn citing Andy Jassy

Microsoft’s Mount Pleasant, Wisconsin campus will use closed-loop cooling in most buildings, consuming zero water for cooling except on the hottest days. The peak daily water use is projected at 350,000 gallons, far below the 1 million to 5 million gallons per day that massive AI data centers can require. WPR

Google deployed AI-optimized liquid cooling systems in 2023 that cut cooling energy consumption by more than 30 percent. Fortune Business Insights

Schneider Electric launched the Motivair MCDU-70 CDU in January 2026, rated at 2.5 megawatts per unit and scalable beyond 10 megawatts. Schneider Electric press release Daikin Applied acquired Chilldyne in November 2025 to add negative pressure direct-to-chip technology. Daikin press release Vertiv, the market leader with over an 11.3 percent share of liquid cooling in 2025, acquired CoolTera in 2023 and BiXin Energy Technology assets in late 2024 to build its liquid cooling and chiller portfolio. Global Market Insights, Blackridge Research, Vertiv, Vertiv

The supply side is consolidating fast. That consolidation gives the few suppliers more leverage in contract negotiations, which is itself a risk the owner’s counsel should address through early commitment agreements and, where possible, dual-sourcing the CDU specification.

Key takeaways

• Liquid cooling is the standard for high-density AI workloads. The construction contract must treat the cooling system as a mission-critical performance system, not as ordinary MEP.
• EPA rules require cooling equipment manufactured or imported on or after January 1 2027 to use a refrigerant with GWP below 700, and the HFC leak detection and repair rules are in effect as of January 1 2026. Both must be embedded in the contractor’s scope.
• EPC contracts with fixed-price or GMP structures are the norm because they provide a single point of accountability and enable fast-track delivery. AIA forms need substantial customization.
• Performance guarantees should cover delivered cooling capacity, temperature and humidity envelope, redundancy compliance, and an integrated systems test with simulated failure conditions. Liquidated damages must be a genuine pre-estimate of the owner’s loss from an outage.
• Procurement of long-lead cooling equipment, especially CDUs and chillers, can exceed 12 months. Owners should execute early limited-scope purchase orders and address tariff and force majeure risk explicitly in the EPC contract.
• Water use is now a contract issue. Include a maximum WUE or daily water consumption guarantee and allocate the risk of a mid-project change in water law.
• The single most critical component is the CDU, and it still lacks a standard rating. Rely on factory acceptance testing at full load and a detailed performance specification.
• Case law is developing. The Rogers-O’Brien v. Microsoft dispute and the Equinix Singapore cooling failure show how quickly equipment and commissioning failures become nine figure disputes.

Frequently asked questions

Q:What is the most important EPA rule that governs the refrigerant in a new AI data center cooling system?

A:The Technology Transitions rule under 40 CFR Part 84 limits the global warming potential of the refrigerant in new data center cooling equipment to below 700. The compliance date for the data hall equipment (CRAC, CRAH, in row, in rack) is January 1 2027. The regulation at 40 CFR 84.54(c)(13) covers AI data center cooling systems with a January 1 2027 compliance date but does not explicitly address whether chilled-water plants serving the data floor fall under that subsector or under the separate chiller provisions at 40 CFR 84.54(c)(3), (c)(5), or (c)(6), which carry compliance dates as early as January 1 2025. 40 CFR § 84.54

Q:Why is liquid cooling so different from air cooling for construction contracts?

A:Liquid cooling systems must remove far more heat per rack, up to 170 kW compared with roughly 20 to 30 kW for air. A loss of liquid flow causes the chips to overheat in seconds, so the system has essentially no thermal buffer. The bulletin therefore recommends redundant design, continuous monitoring, rigorous commissioning, and integrated systems testing beyond what a traditional cooling deployment requires. ASHRAE TC 9.9 Technical Bulletin on Liquid Cooling Resilience

Q:What is a CDU and why should the contract focus on it?

A:A Coolant Distribution Unit is the packaged system that sits between the building’s water loop and the loop that cools the chips, containing a heat exchanger that provides isolation and thermal transfer. ASHRAE’s 2025 Technical Alert says CDUs are more critical than ever for liquid cooling systems. The CDU must provide reliable isolation and thermal transfer, yet there is no standard industry rating. ASHRAE Standard 127-2020 Addendum b, published in February 2026, includes a method of test for liquid-to-liquid CDUs. ASHRAE Standard 127-2020 Addendum b, ASHRAE TC 9.9 presentation on CDU guidance

Q:What is an EPC contract and why is it the preferred structure?

A:An EPC (Engineering, Procurement, and Construction) contract appoints a single contractor to design, procure, build, and commission a turnkey facility. It provides a single point of accountability and provides the quickest project delivery. For AI data centers, the EPC structure is popular because it puts substantial responsibility and risk on the contractor to deliver a turnkey facility. Construction Dive

Q:What performance guarantees should a cooling contract include?

A:The contract should guarantee delivered cooling capacity, a defined temperature and humidity range under full load, N plus 1 or 2N redundancy, compliance with the applicable Uptime Institute tier, and a pass on an integrated systems test that simulates failure conditions. Law firm analysis

Q:How does the contract handle long lead times for cooling equipment?

A:Because chillers, CDUs, and cooling towers can take over a year to arrive, developers often execute early purchase orders before the design is complete. The EPC contract should define which party bears the risk of a tariff increase, a supplier force majeure. Troutman Pepper

Q:Why is water use a cooling contract issue?

A:A 100 MW AI data center can consume more than 500,000 gallons of water per day. At least 30 state bills were introduced in 2025 to regulate data center water use, and two states enacted legislation. Climate XChange AI data center construction and procurement contracts increasingly include performance guarantees tied to water efficiency metrics. Law firm analysis

Q:Is there an industry standard for liquid cooling performance testing?

A:Not yet. ASHRAE has published a technical bulletin on liquid cooling resilience and a technical alert on CDUs, and an addendum for CDU testing is out for public review, but no finalized standard rating exists for most liquid cooling equipment. Liquid cooling commissioning currently relies on project-specific testing and verification approaches because standardized industry guidelines are still emerging. ASHRAE TC 9.9 Technical Bulletin on Liquid Cooling Resilience, ASHRAE Journal Podcast Episode 49, ASHRAE TC 9.9 Technical Bulletin on Liquid Cooling Resilience, ASHRAE Journal Podcast Episode 49

Q:What does a liquidated damages clause for cooling performance usually cover?

A:The clause ties a dollar amount to a measurable shortfall. For a capacity shortfall, damages might be calculated per kilowatt of missing cooling. For an outage, damages might be calculated per hour of downtime beyond the permitted amount. The figure must be a genuine pre-estimate of the owner’s loss. Over half of organizations report that a significant data center outage costs over $100,000. Uptime Institute via Envigilance

Q:Are there any live disputes that show how these contracts can fail?

A:Yes. The Rogers-O’Brien v. Microsoft case is a $1 billion Texas data center where the contractor alleged that the owner’s failure to supply equipment and coordinate vendors caused delays and $34 million in damages. The Equinix Singapore outage in 2023 was caused by a single contractor error during maintenance and resulted in two days of banking disruption. Global Arbitration Review, The Register / Envigilance

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Junde Liu, JD, LL.M. (Taxation) candidate at UF Law. Originally published on Compute Law Blog. This article is general information and does not constitute legal advice. Reading it does not create an attorney client relationship. The reader should not act on the basis of any content here without first consulting a licensed attorney in the relevant state. Last reviewed for accuracy May 23, 2026.