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Unfair or Deceptive Trade Practices Artificial Intelligence Consumer Protection Laws

Paul Hastings LLP

Colorado Delays Enforcement of AI Act

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On August 28, Colorado Gov. Jared Polis signed SB4, delaying the effective date of the Colorado AI Act (CAIA) from February 1, 2026, to June 30, 2026. Earlier this summer, Gov. Polis called the Colorado Legislature into a...more

Husch Blackwell LLP

FDIC Removes Disparate Impact Theory from Compliance Exam Manual

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Before the Labor Day holiday weekend, the Federal Deposit Insurance Corporation (FDIC) updated the fair lending and unfair, deceptive act or practices (UDAP) chapters of its Consumer Compliance Examination Manual to remove...more

DLA Piper

FTC’s Latest AI-washing Case: A Focus on Agentic AI and Productivity Claims

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On August 25, 2025, the Federal Trade Commission (FTC) announced a new AI-washing case against Air AI, a company selling business coaching and support services. The FTC alleged that the company made deceptive marketing claims...more

Hudson Cook, LLP

Texas AG Opens Investigation into AI Developers for Allegedly Misleading Children with AI-Generated Mental Health Services

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On August 18, 2025, Attorney General Ken Paxton announced the opening of an investigation into two artificial intelligence (AI) developers for potential deceptive trade practices and misleading marketing. According to the...more

Klein Moynihan Turco LLP

New York Enacts First-Of-Its-Kind Dynamic Pricing Law

On May 9, 2025 New York Governor Kathy Hochul signed the Algorithmic Pricing Disclosure Act (the “Act”) into law. This is the first time that a state jurisdiction has mandated use of certain disclosures if consumer data has...more

Kelley Drye & Warren LLP

State AGs, and Mark Twain, Hold Companies Accountable for AI Use

This week, two state attorneys general on very different ends of the political spectrum announced separate actions related to purported discrimination by AI services. Missouri sent inquiry letters to four Big Tech companies...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts attorney general settles with student lender for $2.5M for UDAP and fair lending violations from alleged AI...

On July 10, the attorney general from Massachusetts (AG) announced a settlement with a student lender for alleged unfair and deceptive acts and practices in violation of consumer protection and lending laws leading to, among...more

Troutman Pepper Locke

Mass. AG Emerges as Key Player in Consumer Protection

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Massachusetts Attorney General Andrea Campbell has emerged as a significant figure in the landscape of consumer protection and corporate accountability. Her actions and initiatives have positioned her as a thought leader...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 1, 2025)

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New York Legislature Passes FAIR Business Practices Act. On June 18, the New York state legislature passed the Fostering Affordability and Integrity through Reasonable Business Practices Act (FAIR Business Practices Act),...more

Verrill

Maine Law Now Requires Limited Disclosures of Artificial Intelligence Technology

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Maine has joined the list of U.S. states requiring disclosures of Artificial Intelligence (A.I.) technologies. This is due to a new law signed by Governor Janet Mills on June 12, 2025, the Act to Ensure Transparency in...more

Eversheds Sutherland (US) LLP

New York’s proposed FAIR Business Practices Act – potential implications for business

The Consumer Financial Protection Bureau recently signaled a retreat from its regulatory and enforcement posture by outlining its 2025 supervisory and enforcement priorities and rescinding 67 regulatory guidance documents. In...more

Holland & Knight LLP

Compliance Needs are Alive and Well: FTC's Recent Enforcement Activity

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In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta provides an early analysis of the Federal Trade Commission's (FTC) direction under Chair Andrew Ferguson, emphasizing that the agency is...more

Cozen O'Connor

The State AG Report – 05.29.2025

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Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: • NY Fights FAIR to Expand State Consumer Protection Law - ...more

Wiley Rein LLP

Privacy, AI, and Consumer Protection Takeaways from FTC Chairman’s House Testimony

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FTC Chairman Andrew Ferguson testified before the House Appropriations Committee’s Financial Services and General Government Subcommittee on May 15 to discuss the agency’s consumer protection and competition efforts and...more

Mayer Brown

(A)Identify Yourself: State Bills Would Require Notification When Interacting with AI

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As the communication capabilities of artificial intelligence (“AI”)-powered chatbots and automated voice assistants (“callbots”) improve, it is becoming increasingly difficult to tell human from machine. At the same time,...more

Kelley Drye & Warren LLP

Multiple Bites at the Apple over AI Claims

When Apple announced the iPhone 16 last year, it advertised that it would be ​“the first iPhone built for Apple Intelligence.” Apple touted several AI features and advertised that Apple Intelligence is ​“Available Now.” In...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Private Civil Consumer Financial Services Litigation to Partially Fill CFPB Void - Part...

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The podcast we are releasing today is part 1 of a re-purposed webinar we produced on March 25 titled “The Impact of the Election on the CFPB - Part 4.” As a result of the diminishing impact of the CFPB on enforcing the...more

Sheppard Mullin Richter & Hampton LLP

New York Attorney General Proposes Bill to Expand Consumer Protection Law 

On March 13, New York Attorney General Letitia James announced the introduction of the Fostering Affordability and Integrity through Reasonable Business Practices Act (FAIR Business Practices Act). The proposed legislation...more

Orrick, Herrington & Sutcliffe LLP

New York attorney general proposes bill against unfair, deceptive and abusive practices

On March 13, New York Attorney General Letitia James announced proposed legislation to strengthen the state’s consumer protection framework by expanding enforcement powers beyond deceptive acts and practices to also include...more

Orrick, Herrington & Sutcliffe LLP

FCC issues consumer alert on “grandparent scam” robocalls targeting the elderly

On March 7, the FCC issued a consumer alert about “grandparent scam” robocalls targeting elderly individuals. The alert highlighted various tactics used in the scams, including using the personal information of real people,...more

BakerHostetler

Consumer Brands Association CPG Legal Forum 2025

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Recently Amy Mudge and I, along with Bethany Lukitsch and Julie Singer Brady, the co-leads of our class action group, attended and spoke at the Consumer Brand CPG Legal Forum....more

WilmerHale

Year in Review: 2024 Generative AI Litigation Trends

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Generative AI continued to be a hot topic for privacy-related litigation in 2024. In the US, companies using and deploying this technology saw themselves subject to lawsuits under various state and federal theories of...more

Pierce Atwood LLP

State Regulators Eye AI Marketing Claims as Federal Priorities Shift

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With the increase in AI-related litigation and regulatory action, it is critical for companies to monitor the AI technology landscape and think proactively about how to minimize risk. To help companies navigate these...more

Alston & Bird

State AGs Publish Guidance on How State Laws Apply to AI

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On December 24, 2024 and January 13, 2025, the Oregon Attorney General’s Office and the California Attorney General’s Office published advisories (collectively, “Advisories”) explaining how existing statutes may be used to...more

Hudson Cook, LLP

FTC Targets Accessibility Overlays

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On January 3, 2025, the Federal Trade Commission ("FTC") announced a proposed $1,000,000 settlement with accessiBe Inc. and accessiBe Ltd. accessiBe is a software provider that sells an AI-powered web accessibility tool...more

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