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The “TAKE IT DOWN Act” Goes Up to President Trump’s Desk for Signature

On April 28, 2025, Congress passed the “TAKE IT DOWN Act.” In addition to criminalizing intentional publication of non-consensual intimate imagery, including computer-generated intimate imagery (collectively, NCII), the bill...more

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

FTC Appoints New Bureau Directors: What to Expect from Directors Christopher Mufarrige and Daniel Guarnera

Federal Trade Commission (FTC) Chairman Andrew Ferguson has made two significant management decisions that will impact the trajectory of his enforcement agenda. On February 10, 2025, Chairman Ferguson appointed directors for...more

Consumer Protection Update: With Disruption at the Federal Level, State Attorneys General Are Likely to Loom Large

We are less than a month into the new Trump administration and are seeing an unprecedented wave of activity and major changes at federal agencies. These changes promise to bring significant disruption to the staff and...more

New Year, New Developments: 2025 U.S. Privacy, Cybersecurity, and Consumer Protection Predictions

With Inauguration Day just around the corner, we are likely to see a host of new legislative and enforcement initiatives at the federal level. The Federal Trade Commission (FTC) will shift certain priorities under incoming...more

Shaping Consumer Protection: What to Expect from Incoming Chairman Ferguson's FTC

On December 10, 2024, President-elect Trump named FTC Commissioner Andrew Ferguson as next Chairman of the Federal Trade Commission (FTC), replacing Chair Lina Khan on January 20, 2025. As a Senate-approved sitting...more

FTC Files Consumer Protection Complaint Against GOAT

On December 2, 2024, the Federal Trade Commission (FTC) announced it had filed a complaint against GOAT, an online retailer of sneakers, apparel, and accessories. In the complaint, the FTC alleged, among other things, that...more

Subscription and Auto-Renew Offerings Face New Hurdles: FTC Issues Broad “Click-to-Cancel” Rule Imposing Nationwide Requirements

Companies that automatically renew customers’ subscriptions or memberships, take note. On October 16, 2024, the Federal Trade Commission (FTC) announced sweeping amendments to the Negative Option Rule, which would apply to a...more

All Eyes on AI: Regulatory, Litigation, and Transactional Developments – Q2 2024

The firm is pleased to distribute the Q2 2024 edition of All Eyes on AI: Regulatory, Litigation, and Transactional Developments, which closely follows the evolving regulatory landscape for artificial intelligence (AI) in the...more

FTC Issues Final Rule Banning Fake and Misleading Consumer Reviews and Testimonials

On August 14, 2024, the Federal Trade Commission (FTC) issued a final rule that prohibits publishing or trading in fake or misleading consumer reviews and testimonials, or engaging in other related deceptive promotional...more

All Eyes on AI: Regulatory, Litigation, and Transactional Developments – Q1 2024

The firm is pleased to distribute the Q1 2024 edition of All Eyes on AI: Regulatory, Litigation, and Transactional Developments, which closely follows the evolving regulatory landscape for artificial intelligence (AI) in the...more

FTC Final Rule Officially Broadens Health Breach Notification Rule, Targets Health and Wellness Apps

On April 26, 2024, the Federal Trade Commission (FTC) announced a Final Rule that amends the Health Breach Notification Rule (HBNR or Rule) to significantly broaden the FTC’s enforcement power in the area of digital health....more

Congress Proposes New Comprehensive Privacy Legislation: The American Privacy Rights Act

On April 7, 2024, Representative Cathy McMorris Rogers (R-WA) and Senator Maria Cantwell (D-WA) announced that Congress will once again consider a comprehensive federal data privacy bill that, if passed, would dramatically...more

Focus on Fintech – Q4 2023

In this issue, we discuss updates and developments from federal regulators, including those related to the intersection of fintech and artificial intelligence, crypto-asset and central bank digital currencies, and consumer...more

All Eyes on AI: Regulatory, Litigation, and Transactional Developments – Q4 2023

The firm is pleased to distribute the Q4 2023 edition of All Eyes on AI: Regulatory, Litigation, and Transactional Developments, which closely follows the evolving regulatory landscape for artificial intelligence (AI) in the...more

U.S. Privacy Predictions: What to Watch for in 2024

2023 was one of the busiest years for privacy yet—with more to come in 2024. Five new U.S. state privacy laws (in Texas, Florida, Oregon, Montana, and Washington) will come into effect in 2024. And federal and state...more

FTC Proposes Significant Changes to COPPA Rule

On December 20, 2023, the Federal Trade Commission (FTC) announced proposed changes to the Children’s Online Privacy Protection Rule (COPPA Rule) that would place significant new restrictions on companies that collect...more

FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches

On October 27, 2023, the Federal Trade Commission (FTC) announced it is amending the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA) to include a requirement for non-bank financial institutions to report certain data...more

All Eyes on AI: Regulatory, Litigation, and Transactional Developments – Q3 2023

The firm is pleased to distribute the Q3 2023 edition of All Eyes on AI: Regulatory, Litigation, and Transactional Developments, which closely follows the evolving regulatory landscape for artificial intelligence (AI) in the...more

FTC Seeks Comments on Proposed Rule Requiring Disclosure of Fees in Consumer Goods and Services

Last week, the Federal Trade Commission (FTC) announced a proposed rule that would regulate a broad range of “junk fees” in consumer goods and services, from resort fees associated with travel and lodging, to delivery fees...more

All Eyes on AI: Regulatory, Litigation, and Transactional Developments – Q2 2023

The firm is pleased to distribute the Q2 2023 edition of All Eyes on AI: Regulatory, Litigation, and Transactional Developments, which closely follows the evolving regulatory landscape for artificial intelligence (AI) in the...more

FTC Announces Proposed Settlement with 1Health.io Genetic Testing Firm for Privacy and Security Violations

On June 16, 2023, the Federal Trade Commission (FTC) announced a proposed settlement agreement (in the form of a stipulated order) with genetic testing company Vitagene, Inc., now known as 1Health.io (1Health.io), for...more

FTC Alleges Amazon Prime Subscription and Cancellation Screens Violate Federal Law

The recent suit filed by the Federal Trade Commission (FTC) represents the latest guidance in the rapidly evolving patchwork of federal and state laws that govern online subscription models. Any company offering subscription...more

FTC Announces Proposed Settlement with Premom Fertility Tracking App for Privacy Practices

On May 17, 2023, the Federal Trade Commission (FTC) announced a proposed settlement agreement (in the form of a stipulated order) with Easy Healthcare Corporation, which operates the Premom fertility tracking app (Premom)....more

FTC Announces First Enforcement Action Under the Health Breach Notification Rule Against GoodRx

On February 1, 2023, the Federal Trade Commission (FTC) announced a complaint against and proposed settlement agreement (the “proposed order”) with GoodRx, a digital health company, over its data sharing practices that...more

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