Earlier this summer, the Federal Trade Commission’s (FTC’s) “click-to-cancel” rule was overturned by the U.S. Court of Appeals for the Eighth Circuit, just days before the new rule was set to go into effect. According to the...more
9/30/2025
/ Appeals ,
Automatic Renewals ,
Cancellation Rights ,
Disclosure Requirements ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Intent to Cancel ,
Negative Option Rule ,
ROSCA ,
Subscription Services ,
Unfair or Deceptive Trade Practices ,
Wellness Programs
The Federal Trade Commission announced on September 11 that it is issuing orders to seven companies that provide consumer-facing AI-powered chatbots. The Commission is seeking information on how these companies measure, test...more
9/16/2025
/ Advertising ,
Artificial Intelligence ,
Bots ,
Compliance Monitoring ,
COPPA ,
Data Collection ,
Data Privacy ,
Digital Services ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Information Sharing ,
Information Technology ,
Online Safety for Children ,
Personal Information ,
Regulatory Requirements ,
Telecommunications
The use of algorithmic pricing software, including dynamic and competitive pricing, raises fairness, antitrust and privacy concerns when the data is based on personal, nonpublic or competitively sensitive data....more
9/9/2025
/ Algorithms ,
Antitrust Violations ,
California ,
Consumer Privacy Rights ,
Corporate Counsel ,
Data Privacy ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
New York ,
Non-Discrimination Rules ,
Personal Data ,
Product Pricing ,
Surveillance
As the Summer of Privacy fades into fall, California is—unsurprisingly—in the privacy news. The California Privacy Protection Agency (CPPA) succeeded in finalizing proposed regulations under the California Consumer Privacy...more
9/9/2025
/ Antitrust Violations ,
Artificial Intelligence ,
Automated Decision Systems (ADS) ,
California Consumer Privacy Act (CCPA) ,
California Privacy Protection Agency (CPPA) ,
CIPA ,
Data Privacy ,
Data Protection ,
Data Transfers ,
Department of Justice (DOJ) ,
National Security ,
Software ,
State Privacy Laws
On July 23, 2025, the White House released its artificial intelligence action plan, “Winning the AI Race: America’s AI Action Plan,” which follows from President Donald Trump’s AI Executive Order 14179, signed in January. The...more
Welcome to the Summer of Privacy! As we hit the middle of 2025, California is once again the focus of our attention, as both its legislators and regulators are attempting to square privacy protections with developing...more
7/18/2025
/ 23andMe ,
Artificial Intelligence ,
California ,
CIPA ,
Commercial Bankruptcy ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Privacy ,
Genetic Materials ,
Legislative Agendas ,
Machine Learning ,
New Regulations ,
Ombudsman ,
Personal Information ,
Privacy Laws ,
Regulatory Reform ,
State Privacy Laws ,
Tracking Systems
The U.S. Court of Appeals for the Eighth Circuit vacated the FTC's “click to cancel” rule which was set to take effect on July 14. According to the court, the FTC erred in its rulemaking process by failing to produce a...more
Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more
5/14/2025
/ Auto-Renewal ,
Cancellation Rights ,
Compliance Dates ,
Disclosure Requirements ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Final Rules ,
Goods or Services ,
Negative Option Rule ,
Regulatory Requirements ,
Subscription Services