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All Gas No Brakes – The FTC, DOJ, and HHS Unveil Online Reporting Portal as Latest Effort to Combat Unfair and Anticompetitive...

On April 18, 2024, the Federal Trade Commission (“FTC”), Justice Department (“DOJ”), and the U.S. Department of Health and Human Services (“HHS”) launched an online reporting portal, HealthyCompetition.gov, for the public to...more

Commercial Litigation Outlook - 2024

By any measure, the world has changed vastly since we issued our first Commercial Litigation Outlook in 2020. We are now on our fourth installment of providing insights and flagging trends for what to expect in the coming...more

FTC Pumps Brakes on CARS Rule, At Least For Now

On January 18, 2024, the Federal Trade Commission (FTC) announced it was staying the effective date of its Combating Auto Retail Scams Trade Regulation Rule (the “CARS Rule”) pending resolution of an administrative challenge...more

FTC Announces Hart-Scott-Rodino Act Thresholds and Filing Fees for 2024

Seyfarth Synopsis: On January 22, 2024, the Federal Trade Commission (FTC) announced that the 2024 threshold for applying the size-of-parties test of the Hart-Scott-Rodino (HSR) Act will increase from $111.4 million to...more

FCA Continues Winning Streak For OEMs On Claims For “Unfair Profit” In Destination Charges

On Friday, December 22, 2023, FCA US LLC, the manufacturer of Chrysler, Jeep, Dodge, Ram vehicles, among others, scored the latest in a series of victories for automakers over claims by consumers that “destination charges”...more

FTC Targets Bait-And-Switch Tactics And Hidden Fees With Rule For New Car Dealers

After more than a year of review, the Federal Trade Commission (FTC) on December 12, 2023 launched its much-anticipated final rule targeting misleading advertising and sales tactics by new car dealers. First proposed in the...more

History Repeats Itself As Automakers Strike Deal With Independent Repair Facilities To Provide Access to Telematics Data

The Alliance for Automotive Innovation, a trade association representing U.S. automakers and other manufacturers, announced on July 11, 2023 that it had entered into an agreement with trade associations representing...more

Massachusetts High Court Finds Federal Law Exempts Dealers From Liability For Loaner Vehicles

The Massachusetts Supreme Judicial Court (SJC) recently joined a majority of other courts in holding that the Graves Amendment, 49 U.S.C. § 30106 – which generally protects rental car companies from being held vicariously...more

NHTSA Sides With Automakers, Informs Court That Massachusetts Data Access Law Preempted By Federal Law

In a June 13, 2023 filing in the Alliance for Automotive Innovation v. Campbell case pending in Massachusetts federal court, the National Highway Traffic Safety Administration (NHTSA) gave notice that it had sent a letter to...more

Massachusetts AG Issues Telematics Notice Under Right to Repair Law: What Comes Next?

On June 1, 2023, the Massachusetts Attorney General published the Massachusetts Vehicle Telematics System Notice that new car dealers in Massachusetts must now provide to purchasers of model year 2022 or later vehicles if...more

Sellers of Extended Auto Warranties Agree to Lifetime Telemarketing Ban To Avoid Trial In Case Alleging Deceptive Sales Practices

The Federal Trade Commission (FTC) continues to focus on the automotive and related industries, with the FTC announcing on March 24, 2023 that it had entered into an agreement settling claims against operators of a...more

Massachusetts AG Gives Notice: Right to Repair Law Enforcement Starts June 1, 2023

Newly-elected Massachusetts Attorney General Andrea Campbell gave notice this week that effective June 1, 2023 her office intends to begin enforcing amendments to the state’s Right to Repair Law. The amendments,...more

Ninth Circuit Affirms Dismissal Of Lawsuit Challenging OEM “Destination Charges” As Deceptive

The Ninth Circuit recently affirmed the dismissal of a putative consumer class action challenging a manufacturer’s “destination charge” as an undisclosed and deceptive “vessel for profit” in violation of California and New...more

Computers on Wheels: One OEM Settles Claims While Another Scores A Win In Cases Involving Allegedly Botched OTA Updates

A recent motion for preliminary approval of a class action settlement filed in federal court in Georgia will bring to a close claims asserted on behalf of a class of Porsche owners for a purportedly botched over-the-air...more

Does DOJ’s Withdrawal Of Healthcare Enforcement Policies Have Broader Implications For Information Exchange And Benchmarking...

On February 3, 2023, the Antitrust Division of the U.S. Department of Justice (DOJ) announced that it was withdrawing three “outdated” antitrust enforcement policy statements related to healthcare markets. “After careful...more

Commercial Litigation Outlook - 2023

Welcome to the third annual installment of Seyfarth Shaw’s Commercial Litigation Outlook, where our nationally recognized team provides insights about litigation issues and trends to expect in 2023. The continuing global...more

Buckle Up: How Privacy Policy And Antitrust Enforcement Could Affect Automakers In 2023

In a January 11, 2023 op-ed published in the Wall Street Journal, President Joe Biden urged “Democrats and Republicans to come together to pass strong bipartisan legislation to hold Big Tech accountable.” He warned that the...more

FTC Builds Case For New Car Dealer Rule With Complaint Alleging Junk Fees And Discriminatory Lending Practices

On October 18, 2022, the Federal Trade Commission (FTC) announced a settlement resolving allegations that Passport Automotive Group, a Maryland-based automobile dealer group, packed junk fees into the cost of the vehicles it...more

FTC Receives Flurry Of Comments As Dealers And Others Oppose New Car Dealer Rule

The Federal Trade Commission (FTC) received dozens of submissions from dealer trade associations, other industry participants, and members of Congress opposing the FTC’s proposed rules for dealers in connection with the...more

Massachusetts Right to Repair Case Inches Toward Decision As NHTSA Revised Guidance Dashes Hopes For Pre-Emptive Rules

Two procedural orders issued on September 14, 2022 by the Massachusetts federal court in Alliance for Automotive Innovation v. Healy suggest that a public decision in that case is unlikely to be forthcoming until October 2022...more

Full Steam Ahead: FTC Declines To Extend Public Comment Period For New Car Dealer Rule

The Federal Trade Commission (FTC) on August 23, 2022 announced that it has decided by a vote of 5-0 to decline requests to extend the public comment period for proposed rules for dealers in connection with the advertising...more

FTC Begins Process To Adopt Rules For New Car Dealer Advertising And Sales

On June 23, 2022, the Federal Trade Commission (FTC) announced that it has initiated the process to adopt regulations for dealers in connection with the advertising and sale of new cars. The proposed rules target “[d]ealer...more

Virginia and West Virginia Adopt Laws Regulating Over-the-Air Updates

With over-the-air (OTA) updates for motor vehicles becoming increasingly prevalent in the United States, consumers will be able to receive and install updates to vehicle firmware and software. Some updates might simply...more

Direct Sale Of Electric Vehicles Continues To Follow Tortured Path With Recent Legislative Developments

The battle continues in state legislatures between electric vehicle (EV) manufacturers who want to sell direct to consumers and interest groups representing dealers and technicians who sell and service traditional internal...more

Judge Again Postpones Decision In Massachusetts Right to Repair Case

On April 15, 2022, the Massachusetts federal court in Alliance for Automotive Innovation v. Healy issued a procedural order informing the parties that the court would need another two and a half months to issue a decision on...more

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