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 […]
Consumer Protection/FTC
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 […]
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 […]
CPPA Issues Revised Draft CCPA Regulations; Votes to Initiate Public Comment Period
On May 1, 2025, the California Privacy Protection Agency (“CPPA”) Board convened to discuss revisions to the California Consumer Privacy Act (“CCPA”) draft regulations on cybersecurity audits, risk assessments, automatic decisionmaking technology (“ADMT”), insurance, and updates to the existing CCPA regulations. The revisions were informed by comments received by the CPPA during the formal public […]