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 […]
Federal Trade Commission (FTC)
FTC Targets EdTech Data Practices in Final Order Following Major Student Data Breach
On June 5, 2026, the Federal Trade Commission (“FTC”) gave final approval to a modified consent order against Illuminate Education, Inc. (“EdTech Provider”), a K-12 software vendor, settling allegations that the EdTech Provider did not adequately protect the personal data of more than 10 million students. The action — which follows a public comment period […]
The FTC’s COPPA Policy Statement to Incentivize Age Verification Through a More Flexible Enforcement Approach
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 […]
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 […]