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Tips For Managing the Response to an FTC Civil Investigative Demand in Privacy and Data Security Cases

The Federal Trade Commission (FTC) is more active in privacy and data security enforcement actions now than at any time in recent memory. It announces new enforcement actions almost daily, together with press releases, public...more

Leaked FTC Civil Investigative Demand to OpenAI Provides a Rare Preliminary View of the Future of AI Enforcement

On July 13, 2023, The Washington Post broke the news that the Federal Trade Commission (FTC) had issued a Civil Investigative Demand (CID) — a sort of a pre-litigation subpoena as part of what is supposed to be a nonpublic...more

February Privacy Report: FTC Expands Its Use of “Unfairness” Authority in GoodRx Matter

GoodRx Faces Million Dollar Proposed Penalty from FTC in First Enforcement Action Under the Health Breach Notification Rule - Settlement reveals views on application of unfairness authority to sharing of sensitive...more

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