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NIST Releases Second Draft of AI Risk Management Framework

On August 18, the National Institute of Standards and Technology (NIST) released a second draft of its Artificial Intelligence Risk Management Framework (the Second Draft) for public comment. The first draft was released in...more

FTC Proposed "Commercial Surveillance and Data Security" Rulemaking Raises Significant Questions About Risks Arising From...

The Federal Trade Commission has formally launched a rulemaking proceeding that nominally is focused on consumer privacy issues, but actually raises significant questions about the impact of artificial intelligence/machine...more

FTC Issues Advance Notice of Proposed Rulemaking on Commercial Surveillance and Data Security

The Federal Trade Commission (FTC) may have just taken its first steps towards the creation of generally applicable federal privacy and security rules. On Aug. 11, 2022, the FTC published an advance notice of proposed...more

Privacy in a Post-Roe World: What Businesses of All Types Should Consider

Following the U.S. Supreme Court's decision in Dobbs v. Jackson Women's Health Organization overruling Roe v. Wade, businesses and organizations that process personal data—including those outside the health or reproductive...more

First Circuit Splits on Whether Warrantless Pole-Mounted Video Surveillance Violates Fourth Amendment; District Court Suppression...

Last week, the First Circuit issued a decision that could be destined for Supreme Court review, but that nonetheless will immediately impact the course of criminal defendants' Fourth Amendment rights, particularly concerning...more

European Commission Releases Additional Guidance on SCCs for International Data Transfers

On May 25, 2022, the European Commission announced the release of a new guidance document relating to standard contractual clauses (SCCs) and international data transfers. The guidance is included in a series of questions and...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law (UPDATED)

Update March 31, 2022: Utah Governor Spencer Cox signed the bill into law March 24, 2022. With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy...more

NIST - Two Guidance Documents for Developing Trustworthy AI

On March 16 and 17, 2022, the National Institute of Standards and Technology (NIST) released two documents as part of its effort to establish a voluntary framework for developing trustworthy and responsible artificial...more

California Attorney General Issues Opinion Interpreting "Inferences" Under CCPA

The California Office of Attorney General (OAG) on March 10, 2022, issued its first opinion interpreting the California Consumer Privacy Act (CCPA), addressing when businesses must disclose internally generated "inferences"...more

FTC COPPA Settlement Requires Deletion of Algorithms

Algorithmic disgorgement is back in the spotlight at the FTC, this time in connection with a recently announced settlement with WW International, Inc., formerly known as Weight Watchers (WW), and a subsidiary called Kurbo,...more

And Utah Makes 4—Beehive State Passes Consumer Privacy Law

With passage of the Utah Consumer Privacy Act (UCPA), Utah will become the fourth state to adopt omnibus consumer privacy legislation—following California, Virginia, and Colorado— when Utah Governor Spencer Cox signs the...more

Growing Trouble for EU-U.S. Data Transfers Through Google Analytics

France's data protection authority (DPA), Commission Nationale de l'Informatique et des Libertés (CNIL), announced its ruling on February 10, 2022, that the use of Google Analytics by companies in the EU violates Article 44...more

Illinois "Protecting Household Privacy Act" Takes Effect

Leading on the data privacy front again after passing one of the toughest biometric data privacy laws in the nation, Illinois is now the first state to expressly limit law enforcement access to household digital device data....more

Does the U.S. Need an AI "Bill of Rights"?—White House Says "Yes"

The White House Office of Science and Technology Policy (OSTP) announced a plan to develop a "bill of rights" to protect against what the OSTP perceives to be potentially harmful consequences of AI, including anticipated and...more

Colorado Adds to the Privacy Law Patchwork – What to Expect

On July 7, Colorado became the third state to enact comprehensive data privacy legislation, following California and Virginia. The Colorado Privacy Act (CPA), modeled largely after its predecessor in Virginia (the Consumer...more

TransUnion v. Ramirez: SCOTUS Limits Article III Redressable Injuries

The U.S. Supreme Court's opinion in TransUnion LLC v. Ramirez, No. 20-297, 594 U.S. __, 2021 WL 2599472 (June 25, 2021), includes powerful language for defendants to use in seeking an early dismissal of consumer class actions...more

SCOTUS Denial of Certiorari in City of Portland v. FCC Renders Effective FCC's Rulings on Access to Municipal Utility Poles and...

On June 28, 2021, the U.S. Supreme Court denied the petition for certiorari filed by consortiums of various municipal governments and associations seeking to overturn the Ninth Circuit's decision in City of Portland v. FCC,...more

“F--- school, f--- softball, f--- cheer, f--- everything,” Except First Amendment Protections for Student Speech

Last week, the U.S. Supreme Court issued its highly anticipated ruling in Mahanoy Area School District v. B. L., No. 20-255, (U.S. June 23, 2021), upholding students' free speech rights for the first time since 1969. In an...more

Understanding "Trustworthy" AI: NIST Proposes Model to Measure and Enhance User Trust in AI Systems

Advances in artificial intelligence (AI) come with the promise of life-changing improvements in technologies such as smart buildings, autonomous vehicles, automated health diagnostics, and autonomous cybersecurity systems....more

New York City Biometrics Law Takes Effect in July 2021

Following the municipal ban on the use of facial recognition technology in Portland, Oregon, New York City's more expansive "biometric identifier information" law, set to go into effect July 9, 2021, will ban the sale of...more

Federal Court Says Voice Service Providers "Mey" Face TCPA Liability for Facilitating Spoofed Robocalls, Denies Motion to Dismiss

When a dialing platform or voice service provider is sued under the Telephone Consumer Protection Act (TCPA), it often can successfully move to dismiss because it did not "make" the calls at issue or is immune from liability...more

Predicting the Future of Privacy Class Actions After Oral Argument in TransUnion v. Ramirez

Last week, the U.S. Supreme Court heard oral argument on whether and to what extent class members' injuries and standing are relevant to class certification in TransUnion v. Ramirez. The complaint in the district court...more

Challenges to Google's Collection of Web Browsing Data Survive Motion to Dismiss

A class action lawsuit will proceed against Google over its collection of data from users browsing in "incognito mode," as District Judge Lucy Koh denied Google's motion to dismiss on March 12, 2021. In Brown v. Google, Judge...more

FTC Sets Its Eye on Algorithms, Automated Tech, and AI-Enabled Applications

Two recent Federal Trade Commission (FTC) enforcement actions reflect increased scrutiny of companies using algorithms, automated processes, and/or AI-enabled applications. In January 2021, the agency announced it had settled...more

FCC Reaffirms Deregulation of Internet Access Services

On Thursday, October 29, the Federal Communications Commission (FCC) released its Order on Remand (adopted at its October 27 meeting), responding to the D.C. Circuit's remand of certain aspects of the agency's earlier...more

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