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Appeals Marketing

McGuireWoods LLP

Seventh Circuit Allows Percentage-Based Marketing Relationship

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On April 14th, 2025, the U.S. Court of Appeals for the Seventh Circuit reversed the Anti-Kickback Statute (AKS) conviction of Mark Sorensen, the owner and operator of a Medicare-registered durable medical equipment...more

King & Spalding

Ninth Circuit Decision Clarifies EKRA Enforcement

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On July 11, 2025, the Ninth Circuit issued a decision clarifying the scope of Eliminating Kickbacks in Recovery Act (EKRA). In affirming a Northern California-based medical testing laboratory’s convictions under EKRA, the...more

Buchalter

9th Circ. Decisions Help Clarify Scope Of Legal Lab Marketing

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The Eliminating Kickbacks in Recovery Act, enacted in 2018, was a bombshell for the addiction treatment and diagnostic laboratory industries. For the first time, paying commissions for sales and marketing services was...more

BakerHostetler

In Case of First Impression, Looking to AKS Precedent, Ninth Circuit Affirms EKRA Conviction for Improper Payments to Marketers

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In one of the few prosecutions based on the Eliminating Kickbacks in Recovery Act (EKRA), and in an even rarer Court of Appeals opinion interpreting the statute, the Ninth Circuit in United States v. Schena, No. 23-2989, 2025...more

Mintz - Health Care Viewpoints

Ninth Circuit Court of Appeals Affirms EKRA Conviction for Lab Operator and Provides Insight into Key Provisions

On July 11, 2025, the Ninth Circuit Court of Appeals affirmed the criminal conviction of laboratory operator Mark Schena for violations of the Eliminating Kickbacks in Recovery Act, 18 U.S.C. § 220 (EKRA) based on...more

Troutman Pepper Locke

Supreme Court Says Affected Retailers May Challenge ENDS Manufacturer’s Marketing Denial Orders

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On June 20, the Supreme Court concluded that marketing denial orders (MDOs) issued by the Food and Drug Administration (FDA) can be challenged not only by the applicants (typically, the manufacturer or importer of the...more

Fishman Haygood LLP

Supreme Court of Texas Holds that Its Anti-Barratry Laws Do Not Apply to Conduct in Other States

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On May 9, 2025, the Supreme Court of Texas reversed an appellate court’s decision in Pohl v. Cheatham. The case involves two Texas-based attorneys, Michael Pohl and Robert Ammons, who solicited out-of-state clients with...more

Troutman Amin LLP

ROBOCALLS ON THE RISE: Latest Robocall Index Update Confirms Trend– Robocalls Up Nearly 20% YoY

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Well Americans have endured 3 billion more robocalls in 2025 than in 2024 according to YouMail’s famous Robocall Index. The Index reveals Americans received 4,829,181,100 robocalls in May, 2025 as opposed to 4,480,264,800 in...more

Rivkin Radler LLP

Seventh Circuit Rejects Extension of AKS to Marketing Companies Without Evidence of Intent to Induce Referrals

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The U.S. Court of Appeals for the Seventh Circuit recently rejected an effort by the federal government to extend the federal Anti-Kickback Statute (AKS) to a marketing company in the absence of influence by the company over...more

BakerHostetler

DSIR Deeper Dive: A Big Year for VPPA Developments

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The past year has brought a number of federal appellate rulings under the Video Privacy Protection Act (VPPA), 18 U.S.C. § 2710, one of the statutes under which plaintiffs have been filing numerous claims in recent years...more

Arnall Golden Gregory LLP

Limitations to the Anti-Kickback Statute? Seventh Circuit Reverses Conviction Finding “Aggressive” Marketing Tactics Insufficient...

On April 14, 2025, the United States Court of Appeals for the Seventh Circuit reversed the conviction of the owner of a durable medical equipment (“DME”) distributor, ruling that there was insufficient evidence to support a...more

Coblentz Patch Duffy & Bass

Second Circuit Limits VPPA Claims Regarding Meta Pixel Data Collection in Solomon v. Flipps Media: A Win for Companies Using...

In a significant development for companies targeted by (or vulnerable to) litigation over website data collection practices, the U.S. Court of Appeals for the Second Circuit affirmed the dismissal of a Video Privacy...more

Morgan Lewis

Seventh Circuit Overturns AKS Conviction in DME Marketing Case

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The US Court of Appeals for the Seventh Circuit recently issued a decision that has important implications for stakeholders in the durable medical equipment (DME), medical device, and telehealth space as well as future civil...more

Venable LLP

Defense-Friendly Anti-Kickback Statute and False Claims Act Marketing and Advertising Decisions

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On April 14, 2025, the Seventh and Second Circuits each issued opinions narrowing the scope of advertising, marketing, and booking fee activities that run afoul of the federal Anti-Kickback Statute (AKS). See United States v....more

Harris Beach Murtha PLLC

Fourth Circuit Confirms: Physical Distance Does Not Avoid Trademark Confusion

The Fourth Circuit Court of Appeals recently issued a decision confirming that using similar names for businesses in the same industry can result in a likelihood of confusion despite the physical distance of the entities. In...more

Foley & Lardner LLP

Health Care Marketing: The Seventh Circuit Addresses “Referrals” Under The Anti-Kickback Statute

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Health care organizations working with marketers, independent sales representatives, advertising, and other consulting support to promote sales of products or services received welcomed news that their arrangements may be...more

Blank Rome LLP

Seventh Circuit Decision Clarifies Distinction Between Face-to-Face Sales and Advertising Under the Anti-Kickback Statute

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Overview - In a significant decision, United States v. Sorensen, --- F.4th ----, 2025 WL 1099080 (7th Cir. Apr. 14, 2025), the United States Court of Appeals for the Seventh Circuit reversed the conviction of Mark...more

Greenberg Glusker LLP

Washington Supreme Court Expands Reach of Anti-Spam Law

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The Washington Supreme Court has just handed down a decision significantly expanding the scope of its anti-spam law to now cover a wide array of false advertising claims relating specifically to commercial emails. The case,...more

BakerHostetler

The Seventh Circuit Narrows AKS Scope for 1099 Marketers and Advertisers

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On April 14, the Seventh Circuit in United States v. Sorensen issued a decision reversing a jury conviction and narrowing the scope of the Anti-Kickback Statute (AKS) as applied to marketers and advertisers....more

Clark Hill PLC

Washington Supreme Court says it’s illegal to include any false or misleading information in the subject line of a commercial...

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On April 17, the Washington Supreme Court held that RCW 19.190.020(1)(b) prohibits sending Washington residents commercial emails that contain any false or misleading information in the subject lines of such emails. In Brown...more

Dorsey & Whitney LLP

The Supreme Court Update - April 2, 2025

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The Supreme Court of the United States issued two decisions today: FDA v. Wages and White Lion Investments, L.L.C., No. 23-1038: This case concerns the validity of the FDA’s denial of electronic cigarette manufacturers’...more

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News — March 2025

We are pleased to present our latest edition of Telephone and Texting Compliance News, providing insights and news related to the Telephone Consumer Protection Act (TCPA). In this month’s Regulatory Update, we cover two...more

Faegre Drinker Biddle & Reath LLP

Seventh Circuit Affirms Summary Judgment and Adopts Narrow Interpretation of “Telephone Solicitations”

The Seventh Circuit recently affirmed entry of summary judgment against a TCPA plaintiff and adopted the Eastern District of Wisconsin’s interpretation of the phrase “telephone solicitations.” Hulce v. Zipongo, Inc., — F. 4th...more

Ballard Spahr LLP

Appeals Court strikes down FCC telemarketing, robocall rule that required specific consent

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The 11th Circuit Court of Appeals has struck down the FCC rule that would have prohibited telemarketing or advertising robocalls to consumers unless they consent to calls from only one entity at a time, and that they consent...more

Troutman Pepper Locke

Supreme Court Weighs Vape Venue Dispute

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On January 21, the Supreme Court heard arguments in a case addressing who may challenge Food and Drug Administration (FDA) marketing denial orders for new tobacco products....more

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