On August 19, 2026, the Federal Trade Commission (FTC) announced that it is seeking public comment on a proposed enforcement policy statement regarding personalized pricing. The proposed statement makes clear that the FTC intends to scrutinize personalized pricing practices under Section 5 of the FTC Act and marks the latest development in the FTC’s ongoing […]
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Connecticut Court Issues First Prompt Injection Sanctions
A Connecticut pro se plaintiff has been caught—and sanctioned for—attempting to manipulate a court he believed was relying on an Artificial Intelligence tool to reach decisions by hiding instructions directed to the tool in court filings. The court held that the plaintiff’s attempted use of an AI “prompt injection” attack offended the integrity of the […]
FTC Sends Letters Reminding Data Brokers of their Obligations under PADFAA
On February 9, 2026, the Federal Trade Commission (“FTC”) sent letters to thirteen data brokers reminding them of their obligations to comply with the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (“PADFAA”). We previously wrote an article and Peter Swire published a white paper at the Cross-Border Data Forum (“CBDF”) describing PADFAA in […]
FTC Reverses Rytr Consent Order Amid Push for Federal AI Standards
On December 22, 2025, the Federal Trade Commission (FTC) set aside its 2024 consent order against Rytr, a generative AI-powered company, concluding that the original complaint “failed to satisfy the legal requirements of the FTC Act” and that the order unduly burdened AI innovation in violation of the Trump Administration’s January 2025 AI Executive Order […]
FTC Cracks Down on Messaging App Operator on Child Data Exploitation
On September 29, 2025, the Federal Trade Commission (FTC) announced a legal action against the operator of the anonymous messaging app Sendit and its CEO for violations of multiple consumer protection and privacy laws. The complaint, filed in the United States District Court for the Central District of California by the Department of Justice at […]