Lawmakers and regulators at both the state and federal levels are increasingly focusing on consumer protection considerations relating to algorithmic pricing. On September 25, the Federal Trade Commission (“FTC”) closed the comment period on a proposed enforcement policy statement on personalized pricing. The proposed statement is the FTC’s preliminary view on whether personalized pricing practices could be deceptive or unfair, and on when the agency would expect an affirmative disclosure when personalized pricing is used. The FTC’s proposed policy statement drew more than 4,500 comments from a variety of perspectives, such as small businesses, food, and technology. Many commenters raised concerns about the statement’s current broad scope, including whether the FTC would distinguish between use cases involving personal data to provide individualized price increases on the one hand and discounts or other savings or promotions that lower prices for consumers on the other. Commenters also urged the agency to preserve loyalty programs and other long-standing practices in which companies provide tailored pricing to certain customer segments.

Continue Reading Algorithmic Pricing Laws: A Growing State Patchwork and What Businesses Should Know

Yesterday, the Federal Communications Commission (“FCC”) voted to adopt new rules that are expected to significantly narrow the agency’s recognition of certain test labs, telecommunication certification bodies (“TCBs”), and laboratory accreditation bodies (collectively, “Test Labs”) that are located outside of the U.S. and used for equipment authorizations. 

The new rules build on previous FCC actions prohibiting recognition of so-called “Bad Labs” and will permit reliance only on Test Labs that are located in a “reciprocal economy” (i.e., jurisdictions that afford U.S. Test Labs reciprocal recognition).  The new rules will establish a transition period ending December 1, 2028, after which all foreign Test Labs located in non-reciprocal countries will be barred from issuing FCC equipment authorizations and conducting related testing. 

Continue Reading FCC Adopts New Rules Limiting the Use of Certain Foreign Test Labs in Equipment Authorizations

On November 4, 2026, the UK Government published a statement announcing the outcome of its responsible business conduct review (“RBC Review”), which it launched in its Trade Strategy 2025 (for background, please refer to our previous blog post here).

The Government found in the RBC Review that the UK’s…

Continue Reading UK Government Commits to Mandatory Human Rights Due Diligence Law: Outcome of the Responsible Business Conduct Review

On October 22, 2026, the Federal Communications Commission (“FCC”) announced its first enforcement action under new rules that prohibit FCC authorization of certain devices incorporating “logic-bearing hardware components” produced by entities identified on the FCC’s Covered List.  The rules took effect less than two weeks earlier on October 13, with the prompt action signaling the FCC’s willingness to enforce the new component-level restrictions. This action is only the latest in the FCC’s series of actions to enforce the Covered List and its national-security rules, underscoring that space as a continued enforcement priority.

Continue Reading FCC Takes First Covered List Enforcement Action Under New Ban on Devices Incorporating Prohibited “Logic-Bearing Hardware Components”

As the established world order to which we have become so accustomed since its creation out of the ashes of the Second World War begins to crumble before our eyes, pulled apart by right-wing nativist populism and the inability of the political mainstream to answer the cries for help from…

Continue Reading Critical Raw Materials and Geopolitics

On September 30, California Governor Gavin Newsom signed three laws that will regulate the use of AI in the employment context, starting in the new year. Below, we briefly summarize these developments, which we discuss in greater detail in our prior blog post. These laws join an existing body…

Continue Reading New California AI Employment Laws: Key Requirements for Employers

On September 9, 2026, the U.S. Federal Bureau of Investigation (“FBI”) announced the publication of the FBI Cyber Strategy (the “Strategy”).  The Strategy, which “provides a roadmap for defending the American people and the nation’s critical infrastructure in cyberspace,” is broken into four pillars:

  1. Investigate, Disrupt, and Impose Cost on Cyber Adversaries;
  2. Support Victims;
  3. Increase Impact Through Partnerships; and
  4. Enhance FBI’s Cyber Capabilities.

The Strategy may be of interest to organizations as they develop and assess their own threat monitoring and incident response programs, particularly because of the Strategy’s emphasis on the FBI’s continued cooperation and information sharing with the private sector.  For purposes of this blog post, we have focused on the first three pillars, as the fourth pillar primarily focuses on the FBI’s internal capabilities.

Continue Reading Key Takeaways for Private Sector Entities from the FBI’s New Cyber Strategy

Hot off the press, yesterday evening, 29 September 2026, the German Government’s expert committee presented the eagerly awaited proposal for a new “location clause” (Standortklausel) to incentivize pharmaceutical R&D and manufacturing in Germany. Under this proposal, pharmaceutical companies can apply for a reduction or complete waiver of the just recently enacted 8.5% additional “manufacturer markdown” (Herstellerabschlag). So, what does this newly proposed German location clause mean for pharmaceutical companies?

This blog outlines the proposed location clause and summarizes initial stakeholder reactions. We also discuss whether the proposal would really be an improvement for pharmaceutical companies or rather a bureaucratic worsening compared to the currently applicable exemption.

Continue Reading Germany Reviews a New Pharma “Location Clause” (Standortklausel) for Pricing & Reimbursement Incentives – Improvement or Worsening for the Pharmaceutical Industry?

On 29 September, the European Commission launched a call for feedback on its plans for new trade tools that would strengthen the EU’s trade diversification and economic resilience. The initiative is intended to address situations where a high level of strategic dependence on a single supplier country creates a risk to the EU’s security of supply. The consultation is open until 27 October 2026.

Continue Reading EU Commission launches consultation on new legislative instrument for trade diversification

Driverless and autonomous vehicles (“AVs”) are moving from test tracks and pilot schemes to commercial deployment around the world. In the U.S. and China, robotaxi fleets and autonomous trucking services are proliferating. Similar developments are happening in the EU and UK. In London, the first commercial autonomous ride-hailing service launched in early September 2026, with a supervised fleet carrying paying passengers. In Germany, regulators have granted the first nationwide authorisations for Level 4 urban testing and cab-less Level 4 autonomous trucks. At the international level, UNECE has adopted the first global rules for fully driverless vehicles, as discussed in our earlier blog post here.

As AV technology matures, the regulatory and liability frameworks that will govern it are starting to emerge. This article provides an overview of the key developments that will affect autonomous vehicle manufacturers, and technology companies and mobility-service providers operating in this sector.

Continue Reading Overview of EU and UK Regulatory Developments relating to Autonomous Vehicles