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Texas Enacts Responsible Artificial Intelligence Governance Act

Key Takeaways - - Texas’ new law governing artificial intelligence, which takes effect at the start of 2026, introduces both familiar and novel regulations on the use of AI by companies and government entities. - Provisions...more

How the FTC’s Approach to Privacy, Security, and AI Enforcement May Change Under Trump 2.0

The election of Donald Trump is likely to have a significant impact on the Federal Trade Commission’s (FTC’s) approach to privacy, data security, and other technology-related aspects of consumer protection, including...more

FTC and State Coalition Settle Data Breach Cases with Marriott

The Federal Trade Commission (FTC) announced a complaint and proposed consent order against Marriott International Inc. and its subsidiary, Starwood Hotels & Resorts Worldwide LLC, on October 9, 2024, concerning three alleged...more

With Operation AI Comply, the FTC Steps Up AI Enforcement

The Federal Trade Commission (FTC) recently announced several enforcement actions and proposed settlements as part of a new sweep it calls “Operation AI Comply.” These cases appear focused on companies that the FTC alleges...more

FTC Proposes Rule Addressing Use of AI To Impersonate Individuals

The Federal Trade Commission (FTC) issued a supplemental notice of proposed rulemaking (SNPRM) on February 15, 2024, in which it recommended a trade regulation rule that would (1) impose liability on businesses who provide...more

FTC Brings First Standalone Section 5 Unfairness Claims for Unreasonable Data Retention and Inaccurate Breach Notice

On February 1, 2024, the Federal Trade Commission (FTC) announced a complaint and proposed consent order against Blackbaud, Inc. concerning a 2020 data security incident that included a ransomware demand and payment....more

FTC Signals Tough Line in First AI Discrimination Case Under Section 5

The Federal Trade Commission (FTC) announced its first enforcement action alleging that discriminatory use of artificial intelligence (AI) was an unfair practice under Section 5 of the FTC Act on December 19, 2023. According...more

What’s Next for Privacy at the FTC Following the Confirmation of Alvaro Bedoya

Alvaro Bedoya was sworn in as a commissioner of the U.S. Federal Trade Commission (FTC) on May 16, 2022. Bedoya is well known in privacy circles. He founded the Center on Privacy and Technology at Georgetown Law School, where...more

FTC Chair Lina Khan Gives First Public Address Regarding Privacy

Federal Trade Commission (FTC) Chair Lina Khan spoke at the opening of the International Association of Privacy Professionals Global Privacy Summit on April 11, 2022, in Washington, D.C. In her first public speech on privacy...more

Critical Takeaways From the D.C. Circuit’s Long-Awaited Robocall Ruling

Last Friday, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) issued its long-awaited decision in ACA International v. Federal Communications Commission, No. 15-1211 (D.C. Cir. Mar. 16, 2018). The...more

Commission Holds FTC Unfairness Claim Does Not Require “Probable” or Tangible Injury in LabMD Data Security Case

The Federal Trade Commission unanimously (3-0) ruled on July 29, 2016 that LabMD’s data security practices were “unfair” under Section 5 of the FTC Act, reversing a decision of its Administrative Law Judge (ALJ). As we...more

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