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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…

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…