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Eighth Circuit Vacates FTC Click-to-Cancel Rule Days Before Compliance Deadline

Although the entire Rule has been vacated, businesses offering negative option programs should remain aware of general unfair and deceptive advertising principles and applicable state law requirements. KEY POINTS: On July...more

FTC Publishes Updates to COPPA Rule

The first updates to the COPPA Rule since 2013 impose new obligations for sharing children’s personal information with third parties. On April 22, 2025, the Federal Trade Commission (FTC or Commission) published the final...more

FTC Delays Enforcement of Click-to-Cancel Rule Until July 14 2025

Companies with B2C or B2B recurring payment programs that include negative option terms now have until July 14, 2025, to ensure their disclosure, consent, and cancellation practices are compliant with the Negative Option...more

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

FTC Sharpens Its AI Agenda With Novel Impersonation Rulemaking

A new proposed rule would prohibit impersonating individuals or knowingly providing tools for unlawful impersonation — dramatically expanding the FTC’s AI enforcement capabilities. On February 15, 2024, the Federal Trade...more

FTC Proposes Updates to COPPA Rule

On December 20, 2023, the Federal Trade Commission (FTC or Commission) issued a Notice of Proposed Rulemaking (Notice) recommending amendments to the Children’s Online Privacy Protection Rule (COPPA Rule or Rule). The FTC...more

FTC Refines Road Map for AI Enforcement

The agency’s latest report and recent statements indicate its potential enforcement and regulatory priorities regarding artificial intelligence. On December 18, 2023, the Federal Trade Commission (FTC) released a report...more

FTC Serves Notice of Enforcement Approach on Endorsements and Testimonials

Following recent setbacks, the FTC seeks a foothold for monetary remedies in the online advertising space. On October 13, 2021, the Federal Trade Commission (FTC) sent a Notice of Penalty Offenses Concerning Endorsements...more

4 Questions to Consider When Dealing With Children’s Data in the US

The FTC and many state attorneys general aggressively monitor apps, websites, and internet-connected products for COPPA compliance. In the United States, collecting data directly from children under 13 years of age is...more

FTC Hearings Discuss the State of Data Security in the 21st Century

Ninth hearing on Competition and Consumer Protection in the 21st century highlights challenges of addressing persistent threats to data security. On December 11 and 12, the Federal Trade Commission (the FTC or the...more

Deep Dive on Deep Learning: FTC Considers Artificial Intelligence

Seventh Hearing on Competition and Consumer Protection considers ethical, practical, and legal dimensions of artificial intelligence and machine learning. On November 13 and 14, the Federal Trade Commission (FTC) held the...more

FTC Hearing Evaluates Regulatory Oversight of Big Data and Privacy

Sixth hearing on Competition and Consumer Protection in the 21st Century features disagreement over FTC’s enforcement priorities for consumer data. The Federal Trade Commission (FTC) recently held the sixth hearing in its...more

FTC Hearings Consider Pushing Boundaries of Merger Enforcement

Fourth and Fifth FTC Hearings on Competition and Consumer Protection consider more vigorous enforcement over vertical merger and innovation effects. In the past two weeks, the Federal Trade Commission (FTC) held two more...more

FTC Hearing Considers Collusive, Exclusionary, and Predatory Conduct on Digital Platforms

Third FTC hearing on Competition and Consumer Protection in the 21st Century considers calls for additional scrutiny in multi-sided digital platform industries. On October 15, 16, and 17, 2018, the Federal Trade Commission...more

FTC Hearing Reconsiders the Consumer Welfare Standard and Labor Markets

Second FTC hearing on Competition and Consumer Protection in the 21st Century features calls for the Commission to look beyond consumer welfare. On September 21, 2018, the Federal Trade Commission (FTC, or the Commission)...more

FTC Opens Doors and Minds to New Approaches for Competition and Consumer Protection in the 21st Century

Commission kicks off 20 days of hearings to consider whether changes in the economy and new technologies require adjustments to enforcement priorities and policy. Over the course of the next few months, the Federal Trade...more

Court Rules on D-Link Motion to Dismiss in FTC Matter

On September 19, 2017, Judge Donato of the Northern District of California ruled on Defendant D-Link System Inc.’s (D-Link) Motion to Dismiss, which challenged claims by the Federal Trade Commission (FTC) that D-Link’s...more

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