2023 has arrived, and with it comes a novel patchwork of privacy requirements arising out of comprehensive state privacy laws that have been adopted (or amended) by legislatures in California,…
On December 5, 2022, the Securities and Exchange Commission (the “SEC”) Division of Examinations (“EXAMS”) published a Risk Alert providing observations from recent examinations relating to investment adviser and broker-dealers’…
There has been significant regulatory attention recently to “dark patterns,” including FTC guidance, state privacy laws, and state and federal enforcement actions. Some of this activity involves new regulations, and…
As we wrote in previous posts, on August 11, 2022, the Federal Trade Commission (the “FTC”) announced its Advance Notice of Proposed Rulemaking (the “ANPR”) seeking public comment on 95 questions focused on harms…
On September 15, 2022, California Governor Gavin Newsom signed into law the bipartisan AB 2273, known as the California Age-Appropriate Design Code Act (“California Design Code”). The California Design Code…
On August 24, 2022, the California Attorney General announced updates to its California Consumer Privacy Act’s (“CCPA”) enforcement case examples. A large number of the examples focused on compliance with…
On August 31, 2022, the legislative session in California came to a close without any amendments that would further extend—or make permanent—existing limited exemptions under the California Consumer Privacy Act…
As we noted in previous posts, on August 11, 2022, the Federal Trade Commission (“FTC”) announced its Advance Notice of Proposed Rulemaking (“ANPR”) seeking public comment on 95 questions focused…
On August 11, 2022, the Federal Trade Commission (the “FTC”) announced its Advance Notice of Proposed Rulemaking (the “ANPR”) seeking public comment on 95 questions focused on harms stemming from…
On August 11, 2022, the Federal Trade Commission (“FTC”) announced its Advance Notice of Proposed Rulemaking (“ANPR”) seeking public comment on 95 questions focused on purported harms stemming from “commercial…