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Fake News & Paid Reviews: FTC Seeks Comments On Its Endorsement Guides

The Federal Trade Commission (FTC) appears to be using its ongoing review of current rules and guides to revisit its approach to driving home the message that the relationship between a social media “influencer” and the brand...more

Influencing the Influencers: FTC Staff Release “Disclosures 101” Guidance for Online Endorsers

The Federal Trade Commission is trying yet another approach to convey the message that the relationship between a social media “influencer” and the brand he or she is endorsing must be disclosed. This new guidance from FTC...more

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFS-Like Security Requirements for the Safeguards Rule

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more

The FTC’s Quest for Better Influencer Disclosures

In the last few years, as advertising has followed consumers from legacy media such as television to online video and social media platforms, the Federal Trade Commission has been attempting to ensure that participants in...more

Brands Beware: FTC Continues Campaign on Social Media Influencer Disclosures

With much fanfare, the Federal Trade Commission (FTC) continues to take actions relating to so-called “social media influencers” who allegedly fail to disclose material connections to the products or brands they endorse....more

Socially Aware: The Social Media Law Update Volume 8, Issue 2

Welcome to the newest edition of Socially Aware, our Burton Awardwinning guide to the law and business of social media. In this edition, we explore the threat to U.S. jobs posed by rapid advances in emerging technologies;...more

FTC Report Reinforces the Rules for Cross-Device Tracking

Well over a year after holding a workshop addressing privacy issues associated with cross-device tracking, Federal Trade Commission (FTC) staff have issued a report. The report sets the stage by describing how cross-device...more

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

Interest-Based Advertising Disclosure Requirements Become More Clear—and Potentially More Burdensome

Recent enforcement decisions within the digital advertising industry indicate a shift in—and a clarification of—the required disclosures for companies engaged in interest-based advertising (IBA). In particular, these...more

Socially Aware: The Social Media Law Update Volume 7, Issue 4

Mixed Messages: Courts Grapple With Emoticons and Emoji - Emoticon and emoji are ubiquitous in online and mobile communications; according to one study, 74 percent of Americans use emoticons, emoji and similar images...more

Innovative Social Media Marketing Cannot Overlook Old-Fashioned Compliance

Social media is all about innovation, so it is no surprise that social media marketers are always looking for innovative ways—such as courting social media “influencers” and using native advertising—to promote products and...more

Socially Aware: The Social Media Law Update Volume 7, Issue 2

Welcome to the newest issue of Socially Aware, our Burton Award winning guide to the law and business of social media. In this edition, we offer tips for a successful—and legal—advertising campaign; we examine a New York...more

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

Socially Aware: The Social Media Law Update Volume 7, Issue 1

Three Steps To Help Ensure The Enforceability Of Your Website’s Terms Of Use - Operators of social media platforms and other websites typically manage their risks by imposing terms of use or terms of service for the...more

An FTC Warning on Native Advertising

“Native advertising”—ads that may blur the distinction between advertising and editorial, video or other content—has been a hot topic in recent years for both marketers and regulators. It is popular with marketers because it...more

Financial Services Report, Winter 2015

BELTWAY - Finally Faster than Amazon Prime - The Federal Reserve Board recently announced that banks and other financial institutions that use its payments system will have to be able to process same-day...more

Cross-Device Tracking Attracts Interest from the FTC and Guidance from the DAA

Cross-device tracking is a hot new issue for regulators. Companies engaged in the practice should take note of two recent developments. On November 16, 2015, the Federal Trade Commission (FTC) hosted a workshop on the issue...more

Socially Aware - Volume 6, Issue 3 - July/August 2015

Welcome to the newest issue of Socially Aware, our Burton Award winning guide to the law and business of social media. In this edition, we present a “grand unifying theory” of today’s leading technologies and the legal...more

Digital Advertising Alliance Focuses on Mobile Ads

As more users spend more time on their mobile devices, advertising dollars are following. And the compliance regime that governs interest-based advertising (IBA) (formerly referred to as online behavioral advertising or OBA)...more

The FTC Weighs in on In-Store Tracking. Or Does It?

In law school, everybody learns the adage that hard cases make bad law. When it comes to the Federal Trade Commission, a better aphorism might be, “easy cases make new law.” The FTC’s recent settlement with Nomi Technologies...more

What The Nomi Case Could Mean For Retail Tracking

In law school, everybody learns the adage that hard cases make bad law. When it comes to the Federal Trade Commission, a better aphorism might be, “easy cases make new law.” The FTC’s recent settlement with Nomi Technologies...more

Socially Aware - Volume 6, Issue 1 - January/February 2015

In This Issue: - Good Rep: Social Media Assets in M&A Transactions - Narrow Vision: Did Anti-Glass Hysteria Contribute to the Demise of Google Glass? - Forced to Cyber-Spy: Court Rules Parents Can Be Held...more

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