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 […]
Artificial Intelligence (AI)
California Attorney General Announces Investigative Sweep into “Surveillance Pricing”
On January 28, 2026, California Attorney General (“AG”) Rob Bonta announced an investigative sweep targeting “surveillance pricing” practices among businesses in the retail, grocery, and hotel sectors. The investigation focuses on companies that use consumers’ personal information to set individualized prices. According to the AG’s press release, surveillance pricing practices could violate the California Consumer […]
New York Regulates Large Artificial Intelligence Models
On December 19, 2025, just eight days after President Trump issued an executive order titled “Ensuring a National Policy Framework for Artificial Intelligence” to challenge burdensome state laws that regulate artificial intelligence (the “December 2025 EO”), New York Governor Kathy Hochul signed the Responsible Artificial Intelligence (“AI”) Safety and Education Act (the “RAISE Act”). The […]
Spanish DPA Highlights Privacy Risks in GenAI Content Creation
Earlier this month, the Spanish Data Protection Authority (Agencia Española de Protección de Datos, or AEPD) issued new guidance on the privacy and data protection risks associated with uploading images or photos – whether directly or indirectly identifying individuals – into generative AI tools. The guidance is particularly focused on situations where those images are […]
How to Comply with the EU AI Act: Guidance from the Spanish AI Regulator
On December 10, the Spanish supervisory authority for the EU AI Act (Agencia Española de Supervisión de Inteligencia Artificial, or AESIA) published a set of 16 detailed guidelines and non-binding checklists (available online here in Spanish) designed to help companies navigate their obligations under the AI Act, which entered into force in August 2024. The […]