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The Federal Trade Commission (FTC) has a long-standing habit of creating legal obligations through blog posts. Recent communications from the FTC by way of its Office of Technology Blog evidence an aggressive expectation...more
The FTC’s recently issued Final Rule banning non-competes for most workers prohibits an employer from (1) threatening to enforce a non-compete against a worker, (2) advising the worker that, due to a non-compete, they should...more
In October 2023, the Department of Justice (DOJ) announced a new Mergers & Acquisitions Safe Harbor Policy (“Safe Harbor Policy”) designed to encourage acquiring companies to voluntarily disclose criminal misconduct...more
As previously blogged about, on March 7, 2024, the Federal Trade Commission announced a final rule extending telemarketing fraud protections to businesses and updating the Telemarketing Sales Rule’s recordkeeping...more
The Federal Trade Commission (FTC) has declined to approve a new method for obtaining parental consent under the Children’s Online Privacy Protection Act (COPPA) that would involve analyzing facial geometry to verify an...more
In this episode of On Record PR, Gina Rubel goes on record with Aihong Yu, Chief Privacy Counsel of CDK Global, to discuss how embracing privacy and security measures…...more
By maintaining a robust compliance program, healthcare companies are better able to identify potential red flags early and to prevent violations of fraud and abuse laws. A failure to maintain an effective compliance program...more
The FTC is proposing significant changes to the Children’s Online Privacy Protection Act (COPPA) rule to place new restrictions on the use and disclosure of children’s personal information. The COPPA Rule requires websites...more
On December 20, the Federal Trade Commission released a notice of proposed rulemaking to update the Children’s Online Privacy Protection Rule, known as the “COPPA Rule.” (We are linking to the official version of the proposed...more
On December 20, the Federal Trade Commission (FTC or “the Commission”) published a notice of proposed rulemaking (NPRM) proposing amendments to the Children’s Online Privacy Protection Rule (the “COPPA Rule” or the “Rule”)....more
On December 20, the Federal Trade Commission (FTC) announced a Notice of Proposed Rulemaking (NPRM) proposing revisions to its Children’s Online Privacy Protection Rule (COPPA Rule) and requesting comment on a number of...more
In the November edition of our Public Company Watch, we cover key issues impacting public companies, including how to prepare for the 2024 10-K season; the SEC announcing a new intake system for Rule 14a-8 submissions; the...more
The third quarter of 2023 was eventful for both domestic and international cartel enforcers. In the United States, the Department of Justice (DOJ) continues to revamp policies to sharpen its enforcement efforts. On...more
On October 4, 2023, Deputy Attorney General Lisa Monaco (the “DAG”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy issued by the Department of Justice (“DOJ”) as part of her comments detailing increased...more
On Sept. 18, 2023, 19 Democratic state attorneys general (AGs) filed public comments to the Draft Merger Guidelines (Draft Guidelines) proposed by the U.S. Department of Justice and the Federal Trade Commission (the Agencies)...more
On August 16, 2023, the Federal Trade Commission (FTC) announced an agreement with natural gas producer EQT Corporation (EQT) and private equity firm Quantum Energy Partners (Quantum) to resolve concerns stemming from alleged...more
On July 14, 2023 the Federal Trade Commission (FTC) announced that it is withdrawing two antitrust policy statements related to antitrust enforcement in health care markets (the policy statements). Specifically, the FTC is...more
On 10 July 2023, the European Commission announced a major development1 in EU-U.S. personal data transfer relations by adopting a long-anticipated adequacy decision2 for the EU-U.S. Data Privacy Framework (“DPF”). The...more
On February 3, 2023, The Department of Justice (“DOJ”) announced the withdrawal of three antitrust policy statements related to the healthcare industry, which collectively created numerous longstanding “safe zones” for...more
On February 3, 2023, the U.S. Department of Justice’s Antitrust Division (DOJ) announced that it is withdrawing three policy statements the DOJ and Federal Trade Commission (FTC) issued between 1993 and 2011, related to...more
On February 2, 2023, the Principal Deputy Assistant Attorney General for the U.S. Department of Justice’s (DOJ) Antitrust Division, Doha Mekki, announced that the DOJ was withdrawing three policy statements outlining safe...more
In December 2022, the the Federal Trade Commission published new guidance regarding representations about the benefits and safety of health-related products: Health Products Compliance Guidance. Federal Trade Commission...more
In what appears to be a significant expansion of its antitrust enforcement efforts, the U.S. Department of Justice (DOJ) issued letters to multiple public companies, investors, and individuals this week, stating it may bring...more
When companies make advertising claims (including websites, social media, print, and product labels) that a product is beneficial to or not harmful to the natural environment, California law requires those companies to...more
The FTC recently announced the removal of Aristotle International, Inc. from the list of seven approved safe harbor programs under the Children’s Online Privacy Protection Act. Programs that are approved by the FTC must place...more