The algorithm is now the carrier in court.
Tokto gives the carrier's General Counsel one record that ties every algorithmic decision, every adjuster prompt, every telematics SDK, and every rate filing to a policyholder and a state, ready for class certification, AG enforcement, and reinsurer audit.
A federal jury in Arkansas finds the carrier breached its contract by paying total losses based on an algorithmic adjustment that subtracted a fabricated typical-negotiation fee. Plaintiffs are now lining up in 19 other states. The state AG opens a TDPSA-class enforcement action on telematics data. The General Counsel is asked, in deposition, for an attributable record of every algorithmic decision in the relevant period. There is none.
What you get with Tokto
- Every algorithmic decision tied to a policyholder, an adjuster, a state filing, and a rate plan.
- A complete record for the state DOI, the AG, the NAIC, opposing counsel, and the reinsurer on the same evidence.
- Policy applied at the model: no algorithmic adjustment outside the rate filing, no SDK telemetry without consent.
- Defensibility under class certification, state DOI examination, AG enforcement, and reinsurer audit at once.
How it works
Tokto governs the AI surface of the carrier. Pricing models, telematics SDKs, claim-triage co-pilots, ambient claim-listening tools, and adjuster prompts all become records at the moment of decision. Each record carries the policyholder, the adjuster, the model version, the state filing, and the rate plan. The General Counsel works the case from one trail.
When 19 parallel cases follow an Arkansas verdict, when the Texas AG opens a TDPSA enforcement, when a reinsurer asks for an AI-decisioning audit at renewal, the record is the same record. The defense theory is no longer assembled in week three of discovery.
What goes wrong without it
- An algorithmic adjustment provably outside the rate filing reaches a federal jury. Class certification follows in five other states.
- Telematics SDKs feed third-party models without consent capture. The Texas AG opens a first-ever TDPSA enforcement.
- Policyholder PII leaves the perimeter through a CRM voice-phishing attack. ShinyHunters-class loss across the Salesforce CRM.
- An ambient claim-listening tool records insureds without consent. CIPA, CMIA, and state UCL claims open at once.
In January 2025, the Texas Attorney General sued Allstate and subsidiary Arity for unlawfully collecting, using, and selling driving and location data from over 45 million Americans through SDKs embedded in Life360, GasBuddy, Fuel Rewards, and Routely. It was the first-ever enforcement action under the Texas Data Privacy and Security Act.
See how Tokto makes enterprise AI visible, governed, and accountable for Legal & Compliance in Insurance.
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