On April 26, 2024, the Federal Trade Commission (the “FTC”) issued a controversial final rule (the “Final Rule”) that, among other things, expands the scope of the Health Breach Notification…
We have previously written about the legal risks that companies face if they oversell the capabilities of their AI systems, known as “AI washing.” In particular, the FTC and the…
On Tuesday, May 16th, 2023, Andrew Bab of the Mergers & Acquisitions and Private Equity Groups and Co-Chair of the Healthcare & Life Sciences Group, Avi Gesser of the Data…
As we wrote in previous posts, on August 11, 2022, the Federal Trade Commission (the “FTC”) announced its Advance Notice of Proposed Rulemaking (the “ANPR”) seeking public comment on 95 questions focused on harms…
As we noted in previous posts, on August 11, 2022, the Federal Trade Commission (“FTC”) announced its Advance Notice of Proposed Rulemaking (“ANPR”) seeking public comment on 95 questions focused…
On August 11, 2022, the Federal Trade Commission (the “FTC”) announced its Advance Notice of Proposed Rulemaking (the “ANPR”) seeking public comment on 95 questions focused on harms stemming from…
On August 11, 2022, the Federal Trade Commission (“FTC”) announced its Advance Notice of Proposed Rulemaking (“ANPR”) seeking public comment on 95 questions focused on purported harms stemming from “commercial…
Companies developing Federal Trade Commission (“FTC”) compliance programs, or under investigation by the FTC’s Bureau of Consumer Protection, should be aware of significant developments impacting the Commission’s regulatory authority and…
Introduction For those following emerging artificial intelligence (“AI”) regulations and enforcement closely, one issue of great interest is remedies. In particular: in what circumstances, if any, would regulators or courts…