Feature Overview and Restrictions

Google Photos recently introduced Conversational Editing, an AI-powered tool that lets users edit images by typing commands or speaking, without needing advanced software. The feature debuted on the Pixel 10 series and rolled out to eligible Android and iOS users in the United States. However, the rollout excluded Texas and Illinois, where the tool is not available.

Biometric Legal Conflict

Conversational Editing depends on another Google Photos feature called Face Groups, which automatically groups similar faces and creates facial geometry models—a form of biometric data. Both Texas and Illinois have laws that restrict how biometric identifiers such as face geometry or voiceprints can be stored, transmitted, or retained. In Illinois, the Biometric Information Privacy Act (BIPA) requires consent before biometric data collection and allows individuals to sue for violations, with penalties ranging from $1,000 to $5,000 per affected person. In Texas, the Capture or Use of Biometric Identifier Act (CUBI) permits the state attorney general to bring lawsuits and can impose fines up to $25,000 per violation.

Legal History and Settlements

Google previously settled a $100 million lawsuit over its Face Groups feature in Illinois in 2022. Texas also sued Google in 2022 for collecting biometric data without consent, and that case was settled in May 2025. These settlements reflect the ongoing tension between tech companies and state biometric privacy regulations.

Compliance Decision

Legal experts suggest that the simplest compliance route for Google is to disable the feature in the two states, as the biometric collection required for Face Groups creates a legal conundrum. The conversational editing experience remains available through the Gemini app, which does not rely on Face Groups and is accessible in Texas and Illinois.

Industry Context

Google is not alone in facing biometric privacy challenges; other tech firms, such as Meta, have settled large BIPA-related lawsuits, including a $650 million settlement for tracking users without consent.

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