As part of a new enforcement initiative called “Operation AI Comply,” the FTC recently announced that it has brought the following five enforcement actions against businesses that use or sell AI tools in a manner that the FTC has alleged is deceptive and unfair:

  1. DoNotPay. The FTC brought suit against DoNotPay, which had claimed

The California Privacy Protection Agency (“CPPA”) discussed at its July 16 meeting new enforcement focuses in addition to current goals.  While the new focuses are largely in line with general trends, they also serve as a reminder that specific and nuanced compliance decisions can make a big difference.

As the CPPA has made clear in

Colorado has become the first state to pass legislation (SB24-205) regulating the use of artificial intelligence (AI) within the United States. This legislation is designed to address the influence and implications, ethically, legally, and socially, of AI technology across various sectors.

Any person doing business in Colorado, including developers or deployers of high-risk

On March 7, 2024, a bipartisan coalition of 43 state attorneys general sent to the Federal Trade Commission (“FTC”) a letter urging the FTC to update the regulations (“COPPA Rules”) implementing the Children’s Online Privacy Protection Act (“COPPA”).

Through regulations known as the “COPPA Rule,” state attorneys general are authorized to bring actions as parens

The FTC published guidance warning companies that “[i]t may be unfair or deceptive for a company to adopt more permissive data practices—for example, to start sharing consumers’ data with third parties or using that data for AI training—and only inform consumers of this change through a surreptitious, retroactive amendment to its terms of service or

On February 1, 2024, the Connecticut Office of the Attorney General (“OAG”) submitted to the Connecticut General Assembly its report on the first six months of the Connecticut Data Privacy Act (“CTDPA”).  While the report includes important information about its enforcement efforts to date, the most noteworthy aspect may be its recommendation to the legislature

On November 14, 2023, the Colorado Division of Insurance’s AI insurance regulations went into effect.  Colorado is now the first state in the nation to adopt regulations specifically aimed at insurance algorithms.

Colorado’s regulation requires life insurance companies to report how they review AI models and use External Consumer Data and Information Sources (ECDIS), which