Board Thread:Speculation House/@comment-4830106-20140808001942/@comment-209421-20140809030404

Pretty sure the Halo AI were created via thought-pattern replication, not brain cells, but that could just be me misremembering.

However, I agree that Penny is more than likely an android body with something of organic origin providing her intelligence - either an organic brain, "brain cells" or thought-patterns.