Hmm, the latest article [1] specifically about the California authorization says:
> When active, Mercedes takes responsibility for Drive Pilot's actions.
and
> "Mercedes-Benz Drive Pilot is the world's only SAE Level 3 system with internationally valid type approval," Mercedes CTO Markus Schäfer said in a statement.
Not as clear-cut as you'd want it to be but certainly leaning towards the claim. I guess we'll know for sure once the cars actually go on sale in California.