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Courts Reject Theoretical Privacy Violations Due to Lack of Standing

Courts across the country are becoming skeptical of data breach and web tracking claims that assert theoretical privacy violations without alleging any actual injury to the plaintiffs. Recent decisions underscore that courts...more

DOJ Releases New Key Guidance on Its Data Security Program (DSP)

On April 11, 2025, the National Security Division (NSD) of the Department of Justice issued a press release (Press Release) that outlines its approach to implementing and enforcing the DOJ’s recent final rule on “Preventing...more

The Fifth Circuit Held That Parties to an Arbitration Agreement Must Arbitrate Their Claims Even If the Forum They Selected No...

The U.S. Court of Appeals for the Fifth Circuit recently compelled two parties to arbitrate their claims despite the abolishment of the forum that they selected in their international commercial arbitration clause. The case...more

New Interpretation of the Investment Chapter of the U.S.-Colombia Trade Promotion Agreement Will Make It Harder for Investors to...

Amid the flurry of expected international trade actions by the second Trump administration, the outgoing Biden White House reached a significant (but overlooked) agreement of its own to curtail investor-state dispute...more

USTR Implements Sweeping Tariff Increases on Chinese Goods, Tightens Trade Enforcement to Protect U.S. Industries

On September 13, 2024, following a statutory four-year review of tariff actions taken by the U.S. Trade Representative (USTR) pursuant to its Section 301 investigation of China, the USTR announced a series of final...more

Trade Secrets to Be Subject to Export Controls Under House-Passed Bill

On September 9, 2024, the U.S. House of Representatives passed legislation that would expand the scope of the Export Control Reform Act of 2018 (ECRA) to include the protection of trade secrets. The one-sentence bill, which...more

Artificial Intelligence Briefing: Lawsuits, Agreements and Comments – Oh My!

Recent developments in AI continue to highlight its increasing prevalence and the regulatory challenges it poses. The DOJ has sued RealPage, alleging its AI software enables rent price-fixing, while NIST partnered with OpenAI...more

Arbitration Institution Digest (Part 4): ICDR, JAMS, SCC and HKIAC Release Caseload Statistics for 2023

Two U.S.-based arbitral institutions and two international institutions recently released global caseload data from 2023. The American Arbitration Association–International Centre for Dispute Resolution (AAA-ICDR) experienced...more

Countries Poised to Adopt New Cybersecurity Measures After UN Adopts Major Cybercrime Convention

On August 7, 2024, after three years of negotiation, the United Nation’s Ad Hoc Committee to Elaborate a Comprehensive International Convention on Countering the Use of Information and Communications Technologies for Criminal...more

Republican State AGs Challenge CMS Rule Redefining 'Lawfully Present' for ACA Eligibility Under Administrative Procedure Act (APA)

On August 8, 2024, thirteen Republican state attorneys general brought suit in the District of North Dakota against the Centers for Medicare & Medicaid Services (CMS) to challenge the agency’s recent rule allowing...more

Illinois Governor Signs Law That Limits Damages Recoverable Under the Biometric Information Privacy Act

On August 2, 2024, Illinois Gov. J.B. Pritzker signed into law an amendment to the Biometric Information Privacy Act (BIPA), which will limit defendants’ exposure to liability on a “per scan” basis and clarify that electronic...more

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

FTC Updates Health Breach Notification Rule

On July 1, 2024, the amendments to the Health Breach Notification Rule (HBNR) went into effect. First promulgated in 2009, the HBNR applies to vendors of personal health records — entities that are not covered by the Health...more

NIST Releases Cybersecurity Framework 2.0

On February 26, 2024, the National Institute of Standards and Technology (NIST) released the NIST Cybersecurity Framework 2.0 (CSF 2.0). CSF 2.0 represents the first major update to the Cybersecurity Framework, which was...more

Artificial Intelligence Briefing: UN Unanimously Adopts Landmark AI Resolution

The United Nations unanimously adopts a landmark resolution mapping a path for international cooperation on AI, and the Financial Stability Oversight Council announces a two-day conference exploring the benefits and risks of...more

Arbitration Institution Digest (Part 1): China, World Bank and the Netherlands

International arbitration statistics are back in season. In the first couple of months of 2024, the China International Economic and Trade Arbitration Commission (CIETAC), the World Bank’s International Centre for Settlement...more

Biden Administration Announces New Sensitive Data Restrictions

Overview - On February 28, 2024, the Biden administration released an Executive Order that would restrict “countries of concern” from accessing Americans’ sensitive personal data, including “genomic data, biometric data,...more

Artificial Intelligence Briefing: NYDFS Releases Proposed Circular on AI Use in Insurance Underwriting, Pricing

New York’s Department of Financial Services releases proposed guidance on AI and other data sources in insurance underwriting and pricing — and you’ll note plenty of influence from Colorado’s governance regulation and the...more

Supreme Court Ends Saga Over Which Venezuelan Government Could Be Sued in International Investment Dispute

Background - In 2018, several foreign investors obtained international arbitration awards against the Venezuelan government, which nationalized various industries under then-President Hugo Chávez. After confirming their...more

DOJ & FBI Issue New Guidelines for Delayed Reporting of Cyber Incidents to the SEC

Under the Securities and Exchange Commission’s (SEC) new Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule (cybersecurity rule), public companies subject to the cybersecurity rule must promptly...more

Illinois Supreme Court Finds Narrow BIPA Exception for Health Care Workers

Background - The Illinois Biometric Information Privacy Act (BIPA) prohibits companies from collecting, capturing or otherwise obtaining a person’s biometric identifier or biometric information (biometrics) without...more

Cybersecurity Enforcement Update: NYDFS Adopts Final Amendments to its Cybersecurity Regulations and SEC Sues SolarWinds Executive

Recent activity by the New York Department of Financial Services (NYDFS) and the Securities and Exchange Commission (SEC) highlight the continued focus by government regulators on cybersecurity. As these and other regulators...more

Artificial Intelligence Briefing: Sweeping EO “Establishes New Standards for AI Safety and Security”

President Biden has signed an executive order aimed at increasing AI security, protecting Americans’ privacy, and advancing equity and civil rights, among other goals. Meanwhile, the Senate held a second AI Insight Forum, and...more

Employers Beware: Sudden Spike in Class Actions Under the Illinois Genetic Information Privacy Act

The Genetic Information Non-Discrimination Act of 2008 (GINA) is a federal law that regulates the collection and use of genetic information. Among other things, the law prohibits employers from requesting or requiring...more

New CFPB Rules Are Coming for Data Brokers

The director of the Consumer Financial Protection Bureau (CFPB) recently announced that the agency will be developing new rules defining a data broker that sells certain types of consumer data as a “consumer reporting agency”...more

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