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Impersonation Rulemaking: FTC Takes Steps to Tackle AI

On February 15, 2024, the Federal Trade Commission (FTC) announced a two-step approach to tackling impersonation fraud. First, the FTC finalized a rule regulating the impersonation of businesses and government entities (the...more

Tracking the Impact of Securities and Exchange Commission v. Jarkesy and Other Constitutional Challenges Against the FTC

In recent years, independent agencies have continued to face a number of constitutional and statutory challenges before the Supreme Court. AMG Capital Management struck down the Federal Trade Commission’s authority to obtain...more

Addressing the Redress: District Court Limits the Scope of FTC Consumer Redress for Rule Violations

In the wake of AMG Capital Management v. FTC and Liu v. SEC, uncertainty has loomed as to how courts should measure the consumer redress available to the FTC under Section 19 of the FTC Act. Earlier this month, a court in the...more

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