Paul D. Rubin – Debevoise Data Blog

Artificial Intelligence

Federal Trade Commission Finalizes Updates to the Health Breach Notification Rule

By: Andrew L. Bab, Avi Gesser, Paul D. Rubin, Kim Le, Melissa Runsten, Johanna Skrzypczyk, Michael L. Cederblom, Hannah R. Levine, Kaitlyn McGill and Annabella M. Waszkiewicz May 20, 2024

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…

Artificial Intelligence

In 2024, the Biggest Legal Risk for Generative AI May Be Hype

By: Charu A. Chandrasekhar, Avi Gesser, Paul D. Rubin, Kristin Snyder, Melissa Runsten, Gabriel Kohan and Jarrett Lewis January 9, 2024

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…

Artificial Intelligence

National Association of Attorneys General’s 2023 Consumer Protection Spring Conference

By: Courtney M. Dankworth, Avi Gesser, Paul D. Rubin, Jehan A. Patterson, Samuel J. Allaman and Melissa Muse June 12, 2023

On May 10−12, 2023, the National Association of Attorneys General (the “NAAG”) held its Spring 2023 Consumer Protection Conference to discuss the intersection of consumer protection issues and technology. During…

Automated Decision Making

Artificial Intelligence and the Life Sciences Industry: FDA and FTC Regulatory Update

By: Andrew L. Bab, Avi Gesser, Paul D. Rubin and Melissa Runsten May 16, 2023

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…

Artificial Intelligence

Risks of Overselling Your AI: The FTC is Watching

By: Avi Gesser, Erez Liebermann, Jim Pastore, Paul D. Rubin, Christopher S. Ford, Anna Gressel, Mengyi Xu and Melissa Muse March 6, 2023

On February 27, 2023, the FTC released guidance entitled “Keep Your AI Claims in Check” (“AI Claims Blog Post”), reminding companies that false or unsubstantiated claims about a product’s efficacy…

Artificial Intelligence

FTC Proposed Rulemaking Part 4 — Reducing Risks Associated with Artificial Intelligence

By: Avi Gesser, Erez Liebermann, Paul D. Rubin, Johanna Skrzypczyk, Anna Gressel, Michael R. Roberts, Melissa Muse and Melissa Runsten September 29, 2022

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…

FTC

The FTC’s Proposed Rulemaking Part 3 — Key Data Security Takeaways

By: Avi Gesser, Erez Liebermann, Paul D. Rubin, Johanna Skrzypczyk, Michael R. Roberts, Melissa Runsten, Anna Gressel and Melissa Muse August 29, 2022

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…

FTC

The FTC’s Proposed Rulemaking Part 2 — Key Privacy Takeaways

By: Avi Gesser, Erez Liebermann, Paul D. Rubin, Johanna Skrzypczyk, Michael R. Roberts, Melissa Runsten, Anna Gressel and Melissa Muse August 24, 2022

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…

Automated Decision Making

Unpacking the FTC’s 95 Questions for Commercial Surveillance and Data Security Rulemaking (Part 1)

By: Avi Gesser, Erez Liebermann, Paul D. Rubin, Johanna Skrzypczyk, Michael R. Roberts, Melissa Runsten, Anna Gressel and Melissa Muse August 22, 2022

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…