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Misleading Impressions

Arnall Golden Gregory LLP

Gimme Shelter: OPDP’s 2026 Letters Show There’s No “Shelter” From FDA Scrutiny Targeting DTC Ads That Obscure Risk

Key Takeaways - The Food and Drug Administration’s Office of Prescription Drug Promotion (“OPDP”) is scrutinizing overall “net impression,” not merely isolated claims. The recent wave of Untitled Letters shows that...more

Seyfarth Shaw LLP

An Amendment to Washington’s Commercial Electronic Mail Act (CEMA)

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Litigation under Washington’s CEMA, RCW 19.190, have flooded courts following a ruling from the Washington Supreme Court on April 17, 2025, which held that email subject lines containing false or misleading information were...more

Kilpatrick

What’s In a Sandwich? McDonalds Sued in Consumer Class Action Over McRib Claims.

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The iconic McRib, a limited-time fan favorite, recently ignited a high-profile sandwich controversy, leading to a class action lawsuit filed in the U.S. District Court for the Northern District of Illinois (see Le, et al. v....more

The Food Lawyers ®

When Food Label Class Actions Go Wrong: Arbitration Waivers, Sanctions, and Judicial Discretion After Golikov v. Walmart and the...

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Class actions challenging allegedly misleading food labels remain a staple of consumer litigation, particularly in California. One well-known northern California District Court is universally known to class action...more

Smart & Biggar

[Webinar] From buzz to backlash: 2025 ads we can’t stop talking about - January 22nd, 12:00 pm - 1:00 pm ET

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We’ll dive into 2025’s most buzzworthy and controversial advertising campaigns and explore why these campaigns dominated headlines. From celebrity-driven promotions and AI-generated ads, to the Competition Bureau’s heightened...more

Arnall Golden Gregory LLP

OPDP Delivers a Surprise: FDA Issues a Notice of Violation for Another Unlawful TV Ad

Key Takeaways - FDA evaluates direct-to-consumer ads based on the overall impression conveyed to consumers. Visuals, graphics, and on-screen text can equally contribute to an ad’s message. SUPERs function only as secondary...more

Akerman LLP

Misleading email subject lines can lead to substantial liability

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In Brown v. Old Navy, LLC, 567 P.3d 38 (Wash. 2025), the Washington Supreme Court recently interpreted the state’s Commercial Electronic Mail Act to prohibit any false or misleading information in the subject line of a...more

Troutman Pepper Locke

Vermont AG Settles Alleged Deceptive Marketing Practices With Angi

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On October 13, Vermont Attorney General (AG) Charity R. Clark announced a settlement with Angi, Inc., (Angi), resolving allegations related to misleading marketing practices....more

Perkins Coie

Litigation Update: Washington’s Commercial Electronic Mail Act

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Since 2023, Washington courts have seen more than 25 cases filed for alleged violations of Washington’s Commercial Electronic Mail Act (CEMA). ...more

BakerHostetler

[Podcast] AD Nauseam: An Ad Is Not an Ad

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On today’s episode of AD Nauseam, Amy and Daniel explore the legal and regulatory challenges of deceptively formatted advertising, often referred to as native advertising, focusing on how the FTC and NAD assess whether...more

Loeb & Loeb LLP

FDA's Direct-to-Consumer Advertising "Crackdown": Impacts to Brands, Agencies and Influencers

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he Food and Drug Administration (FDA) issued a press release on Sept. 9 announcing a “crackdown” on direct-to-consumer (DTC) pharmaceutical advertising and promising “sweeping reforms" in line with President Trump's same-day...more

Wiley Rein LLP

Wiley Consumer Protection Download (September 9, 2025)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Federal Trade Commission (FTC), Consumer Financial Protection Bureau (CFPB), and the state level. Check out our new FTC Consumer...more

Loeb & Loeb LLP

Two Recent GenAI Controversies Highlight Brand/PR Risks of Use

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Two recent stories highlight how the use of AI can create challenges around perception and trust. The first involves Will Smith. ...more

Troutman Pepper Locke

Florida AG Settles Alleged Moving Brokerage Scheme, Banning Defendants and Securing $4M in Judgments

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On March 21, Florida Attorney General (AG) James Uthmeier’s Consumer Protection Division announced the resolution of ongoing litigation against a network of moving brokerage companies accused of misleading consumers. These...more

Troutman Pepper Locke

Alaska Obtains Six-Figure Civil Penalty in Product Labeling Case

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Alaska’s Department of Law’s Consumer Protection Unit recently announced it obtained a Superior Court order issuing a $250,000 civil penalty against B. Merry Studio, which the state alleged to have marketed products as being...more

Davis Wright Tremaine LLP

Stay ADvised: 2025, Issue 6

Reckitt Benckiser Tastes Sweet Success as Mucinex Honey False Ad Dismissed - Plaintiffs alleging that Reckitt Benckiser falsely advertised certain Mucinex products as containing honey failed to sufficiently allege that the...more

Ballard Spahr LLP

Justice Department files amended complaint against cash advance company Dave Inc. and its CEO

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The Justice Department is asking a federal court to issue a permanent injunction against cash advance firm Dave Inc. and its CEO Jason Wilk, alleging that the company uses misleading marketing tactics to deceive consumers...more

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for November 2024

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Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, SEC Chair Gary Gensler announced his imminent departure in January 2025...more

A&O Shearman

United States Supreme Court Dismisses As “Improvidently Granted” A Putative Securities Class Action Against Meta For Alleged...

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On November 22, 2024, the United States Supreme Court dismissed Meta’s appeal of the United States Court of Appeals for the Ninth Circuit’s decision to partially reinstate a putative class action asserting claims under the...more

K&L Gates LLP

Competition and Consumer Law Round-Up

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What's Inside this Issue? This edition of the K&L Gates Competition & Consumer Law Round-Up provides a summary of recent and significant updates from the Australian Competition and Consumer Commission (ACCC), as well as...more

Davies Ward Phillips & Vineberg LLP

Hold My Popcorn: Canadian Competition Tribunal Decides First Case Under Competition Act’s Amended Misleading Representations...

Canada’s Competition Tribunal (Tribunal) recently released its reasons in the first contested case to apply the amended misleading representations provisions of the Competition Act (Act). The Tribunal’s decision assessed...more

J.S. Held

Unmasking Greenwashing: Avoiding Potentially Deceptive Practices

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Introduction - In today's world, the spotlight on Environmental, Social, and Governance (ESG) practices is brighter than ever. Stakeholders, including investors, consumers, and even corporate employees, are demanding that...more

Baker Botts L.L.P.

CFTC, SEC, and SDNY Break New Ground and File Charges Against Carbon Credit Project Developer and Former Executives for Fraudulent...

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On October 2, 2024, the Commodities Futures Trading Commission (“CFTC”), the Securities and Exchange Commission (“SEC”), and the United States Attorney’s Office for the Southern District of New York announced parallel...more

Klein Moynihan Turco LLP

Private Right of Action for California Email Statute Violations

Readers of this blog may recall a prior piece in which we discussed the return of email marketing in the wake of intense regulatory action in the telemarketing space. However, because of Section 17529.5 of the California...more

Troutman Pepper Locke

Colorado AG Issues Advisory on Deepfakes Ahead of 2024 General Election

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On September 9, Colorado Attorney General (AG) Phil Weiser issued a public advisory warning voters about the dangers of election misinformation and disinformation in the form of realistic-looking images, videos, and audio...more

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