Director, WS Interactive – Miami
As AI-driven search and generative engine optimization (GEO) reshape how companies are discovered, referenced, and trusted online, expanding across borders has become as much a strategic and legal challenge as a commercial one. For European and American businesses alike, visibility in this new digital landscape depends on aligning brand, technology, and regulatory considerations from the outset.
Our two experts, one. expert approaching the issue from a legal and intellectual property standpoint, and the other from a digital strategy perspective, share their views on what U.S. companies entering France should consider when navigating market entry and growth on both sides of the Atlantic in an AI-driven search environment.
Why is this issue important? Who is affected?
Alex McCardell:
For U.S. companies establishing operations in Europe, particularly in France, digital visibility is undergoing a fundamental shift. As digital strategy moves from SEO to GEO, discoverability depends less on technical keyword placement and more on how widely and credibly a brand is referenced across a broad ecosystem of data sources.
In this new search paradigm, well-established global brands may still surface organically, but emerging or niche U.S. companies risk becoming effectively invisible to French audiences unless they are deliberately cited within relevant AI training datasets, media ecosystems, and language models.
This evolution makes a clearly defined, distinctive brand identity more critical than ever—not just for marketing impact, but to ensure the brand is consistently, accurately, and recognizably represented across markets. In other words, GEO is redefining not just how people find your brand, but whether they find you at all.
Alexandre Mochon:
Intellectual Property (“IP”) considerations are fundamental for all organizations. Notably, French IP law diverges considerably from US IP law, particularly with respect to the “work made for hire” and “fair use” doctrines.
In the United States, the “work made for hire” concept established under the Copyright Act means that works created by employees typically belong to the employer. By contrast, French law does not grant employers automatic ownership of employees’ creations (except for software), unless a written agreement specifies the assignment of rights (as outlined in Article L.131-2 and L.131-3 of the French IP Code). Such agreements must clearly enumerate the rights being transferred. This distinction compels US companies operating in France to develop comprehensive IP assignment clauses, which can increase administrative complexity and legal exposure if terms are ambiguous or disputed.
Regarding fair use, US law permits limited utilization of copyrighted materials without prior authorization, subject to a four-factor test. Conversely, French law offers few exceptions to copyright protection, with narrowly defined scenarios such as private copying and educational use, strictly interpreted by courts. As a result, US businesses in France must secure additional licenses for third-party content usage and may face greater risk of infringement claims.
What have you seen on the ground?
Alexandre Mochon:
US companies commonly face two significant challenges: managing relationships with employees in foreign jurisdictions and handling the use of copyrighted works. Many organizations opt to utilize a single employment contract template for all global employees, including those based in Europe and France. However, this often proves ineffective, as US-centric templates are typically not compliant with French law, particularly regarding intellectual property regulations.
Similarly, patentable inventions developed by employees present unique considerations under French legislation. For instance, the French IP Code mandates additional compensation for employees or a fair price based on the nature of the invention, which is a public order rule. US companies sometimes rely on general provisions that may inadvertently override these mandatory French requirements.
Regarding copyrighted works, US entities frequently overlook the rights of foreign authors, such as omitting attribution. Under French IP law, moral rights cannot be assigned or waived, which can result in legal complications and pose risks to business operations.
Alex McCardell:
These legal and structural differences are mirrored on the digital front. U.S. companies entering France can no longer rely solely on search engine rankings to test or reach new markets abroad. A new communication strategy must emerge, requiring a more grassroots approach to visibility. Success increasingly depends on creating genuine interactions with audiences rather than broadcasting polished marketing messages.
It is no longer enough to publish a strong blog or accumulate followers; what matters is cultivating engaged communities that respond, comment, and share. I see innovative French startups, particularly in the robotics and industrial tech sectors, encouraging their teams to participate directly in online discussions, forums, and events where potential partners and customers gather. U.S. entrants are learning to do the same, leaning on clusters, local partners, and sector-specific networks to relay their added value into circles that are otherwise difficult to access.
From a GEO perspective, this is more about linguistic and cultural fluency than simple visibility. Brands that adapt to local vernaculars and actively join conversations in region-specific channels are far more likely to surface in AI-driven search results. Increasingly, we are also seeing that inconsistent brand usage across markets, including different product names, slogans, or visual identities, can weaken performance in GEO environments, since AI models pick up and propagate those inconsistencies.
In the GEO era, recognition comes less from being indexed and more from being referenced through authentic engagement, credible mentions, and the collective voice of communities discussing your brand.
What’s coming next?
Alexandre Mochon:
Although intellectual property law is largely harmonized on a global scale—an advantage for businesses—certain regional distinctions persist. In France, author-friendly regulations are deeply rooted in the country’s legal tradition, making significant changes unlikely; accordingly, U.S. companies should remain particularly mindful of these differences.
As the digital economy expands, intangible assets such as trademark rights are increasingly vital for businesses worldwide.
Moreover, the growing influence of artificial intelligence is expected to introduce new legal challenges for both U.S. and French enterprises, including issues related to the ownership of copyrighted works and the use of such works in training AI models.
Alex McCardell:
In parallel with these legal developments, as user search habits evolve, it is evident that while the global playing field feels smaller, sustainable visibility is becoming harder to attain. Even though technology is connecting audiences across continents, it is also dispersing attention within local ecosystems. The brands that succeed are those that bridge this gap through authentic, context-aware connections.
For U.S. companies establishing themselves in France, this means adopting genuinely local strategies within international campaigns. It means building presence through partnerships, events, and French-based voices that carry regional trust. It also means ensuring that brand assets, including names, logos, and messaging, are coherent and protected across the markets where they appear, since this consistency increasingly influences how AI-driven engines interpret and surface them.
Given the complex and evolving nature of organic reach in AI-driven environments, many will need to complement these efforts with targeted paid endorsements, influencer collaborations, and strategic amplification to overcome new barriers to entry.
The future of GEO is half algorithmic and AI learning, half human. Visibility will belong to the businesses and brands that can master both.
