On February 25, 2026, the Federal Trade Commission (“FTC”) issued an enforcement policy statement announcing that the Commission will not bring enforcement actions under the Children’s Online Privacy Protection Act (“COPPA”) Rule against operators of general audience sites and services and mixed audience sites and services that collect, use, or disclose personal information for the […]
Consumer Protection/FTC
Genetic Goldmine or Legal Landmine? Tempus AI Confronts GIPA Exposure
On February 13, 2026, a putative class filed a Complaint in the U.S. District Court for the Northern District of Illinois alleging that Tempus AI, Inc. (“Tempus AI”) violated the Illinois Genetic Information Privacy Act (410 ILCS 513/1 et seq., “GIPA”). The plaintiffs claim Tempus AI unlawfully obtained and disclosed genetic information belonging to customers […]
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 […]
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 […]