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Trump Administration Releases Sweeping AI Action Plan

On July 23 and 24, 2025, the Trump administration released its “Winning the AI Race: America’s AI Action Plan,” a far-reaching strategy aimed at advancing U.S. leadership in artificial intelligence. ...more

Eighth Circuit Vacates FTC’s Click-To-Cancel Rule

On Tuesday, July 8, the Eighth Circuit struck down the Federal Trade Commission’s new “click-to-cancel” rule just days before the FTC planned to begin enforcement on July 14, 2025. ...more

COPPA’s Coming of Age: Key Compliance Changes in FTC’s Final Rule

On January 16, 2025, the Federal Trade Commission (FTC) finalized amendments to the Children’s Online Privacy Protection Act (COPPA) Rule (Final Rule), which completes the process that started back in 2019 when the FTC sought...more

FTC’s Proposed Updates to the COPPA Rule Seek to Impose New Limitations on the Use of Children’s Personal Information and New...

Enacted in 1996, the Children’s Online Privacy Protection Act (COPPA) is the nation’s longest standing and most comprehensive statute aimed at regulating the collection, use and sharing of the personal information of...more

Remember the CAN-SPAM Act? The FTC Does. Practical Takeaways from the FTC’s Recent CAN-SPAM Enforcement Action

On August 14, 2023, the U.S. Department of Justice and the Federal Trade Commission (FTC) entered a stipulated settlement with Experian Consumer Services to resolve allegations that Experian violated the Controlling the...more

New E-Commerce Marketplace Regulations: Online Marketplaces Must Comply with The INFORM Consumers Act by June 27, 2023

In an effort to “combat the online sale of stolen, counterfeit, and dangerous consumer products,” Congress passed the Integrity, Notification, and Fairness in Online Retail Marketplaces for Consumers Act (the “INFORM...more

FTC Sets Policy Priorities for Biometric Information

The FTC recently published a policy statement with its enforcement priorities for the misuse of biometric information. To be clear, there are no new federal laws that specifically regulate the collection or use of biometric...more

Increased Regulatory Scrutiny on Health Technology Companies’ Use of Advertising Technologies

The proliferation of health apps and connected devices that allow individuals to track their health conditions, treatment, medications, fitness, fertility, sleep, mental health, diet and other vital areas has led to increased...more

Launch of Public RFI Signals FTC Scrutiny of Cloud Computing Industry

On March 22, 2023, the Federal Trade Commission (FTC) announced a request for information (RFI) seeking public comments on business practices in the cloud computing industry. The RFI focuses on three intertwined aspects of...more

FTC’s Aggressive Enforcement of Children’s Privacy and Dark Patterns: A Cautionary Tale and Simple Steps Companies Can Take To...

On December 19, 2022, the Federal Trade Commission (FTC) announced a settlement with Epic Games Inc. (Epic) over its wildly popular game “Fortnite.” The settlement requires Epic to pay $275 million in penalties to resolve...more

[Webinar] The FTC’s Eye on Data Privacy - December 15th, 11:00 am PT

Will the FTC be the new vanguard for federal privacy laws about consumer data? The agency has expressed broad concerns about data handling, including lax data security, harm to children, discrimination and retaliation against...more

FTC Warns Companies Offering Subscription Services to Avoid Using “Dark Patterns”

On October 28, 2021, the Federal Trade Commission issued a new Enforcement Policy Statement (the Statement) warning companies against using “dark patterns” in negative option marketing. “Dark patterns” is a broad term that...more

FTC Issues Notice of Penalty Offenses for Endorsement and Testimonial Marketing

On October 13, 2021, the Federal Trade Commission (FTC) sent a Notice of Penalty Offenses to more than 700 businesses, including top consumer brands, retailers, e-commerce platforms and advertising agencies, regarding...more

Section 230 and the Future of Content Moderation

The Communications Decency Act of 1996 (CDA) was a landmark law enacted to regulate content on the internet. The purpose of the legislation was to regulate indecent and obscene material online, but it is most relevant today...more

FTC, YouTube, and Kids’ Privacy: Key Takeaways from the Biggest COPPA Settlement in FTC History

On September 4, 2019, the U.S. Federal Trade Commission announced Google and YouTube will pay a record $170 million as part of a settlement over allegations that YouTube violated the Children’s Online Privacy Protection Act...more

FTC Toughening Stance on Data Security – Five Key Takeaways from Recent Consent Orders

The Federal Trade Commission is putting more teeth into the multiyear compliance obligations of consent orders it enters into with companies to settle enforcement actions related to data breaches. The FTC recently issued a...more

FTC Not Kidding Around with TikTok’s Record-Setting COPPA Fine - Five Steps to Reduce Your Risk Now

On February 27, 2019, the U.S. Federal Trade Commission announced a record-setting $5.7 million fine to popular short-form video sharing platform TikTok, formerly known as Musical.ly, as part of a consent order over...more

Takeaways From the 11th Circuit’s Reversal of the FTC’s Data Security Order Against LabMD

The U.S. Court of Appeals for the Eleventh Circuit on June 6 issued its long-awaited decision in LabMD v. Federal Trade Commission, vacating a Federal Trade Commission cease and desist order directing LabMD to overhaul its...more

5 Takeaways from the FTC’s First COPPA Settlement Over Internet-Connected Toys

The Federal Trade Commission on Jan. 8 announced its first settlement of alleged violations of the Children’s Online Privacy Protection Act arising from internet-connected toys. The FTC complaint against VTech followed the...more

FTC’s New COPPA Guidance on Recording Children’s Voices: Five Tips for App Developers and Toymakers to Comply

The Federal Trade Commission on October 23, 2017, provided guidance on how it will enforce the Children’s Online Privacy Protection Act (COPPA) with respect to audio recordings of children. This comes as part of a wave of...more

FTC Holds That Disclosure of Sensitive Medical Information Due to Lax Security Violates the FTC Act

Last week, three commissioners from the Federal Trade Commission (FTC) held in In the Matter of LabMD, Inc. that a company’s failure to implement reasonable security measures to protect sensitive consumer information on its...more

Privacy Shield – A Shield worth having?

Earlier this week, the European Commission voted to formally approve the Privacy Shield—a set of principles agreed between the E.U. and the U.S. to enable certified U.S. companies to receive and process personal data from the...more

Litigation Alert: From a Safe Harbor to a Privacy Shield

The October 6, 2015, decision of the Court of Justice of the European Union in the Schrems v. Facebook case left significant uncertainty surrounding the legality and practicality of U.S. technology companies’ ability to...more

Litigation Alert: Third Circuit Permits Federal Trade Commission to Bring Unfair Practice Claim Based on Cybersecurity Practices

In a closely-watched cybersecurity case, a three-judge panel of the U.S. Court of Appeals for the Third Circuit held in Federal Trade Commission v. Wyndham Worldwide Corporation (No. 14-3514) that the Federal Trade Commission...more

Privacy and Information Security Alert: Federal Trade Commission Recommendations for Companies Providing Mobile Shopping...

On August 1, 2014, the Federal Trade Commission (FTC) released a report entitled What’s the Deal? An FTC Study on Mobile Shopping Apps (the FTC Report). The FTC Report is based on a study the FTC conducted (the FTC Study) to...more

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