On June 29, 2026, in a 6-3 decision, the U.S. Supreme Court held that (1) the Federal Trade Commission’s (FTC) statutory “for‑cause” removal protection for Commissioners violates the Constitution’s separation of powers and (2) President Trump lawfully removed Rebecca Slaughter from the FTC. The Court concluded that because FTC Commissioners exercise executive power, they must be removable by the President at will rather than only for “inefficiency, neglect of duty, or malfeasance in office.”
Continue Reading Supreme Court Holds FTC Removal Protections UnconstitutionalConsumer
Washington Anti-Spam Law Decision Addresses Article III Standing in CEMA Cases
By Jehan Patterson & Irene Kim on
A federal court recently addressed whether plaintiffs alleging misleading commercial email practices in violation of Washington’s Commercial Electronic Mail Act (“CEMA”) have Article III standing to pursue claims. The ruling suggests that alleged violations of CEMA, standing alone, could constitute a concrete injury for Article III standing, where the asserted harm aligns with the statute’s purpose.
Continue Reading Washington Anti-Spam Law Decision Addresses Article III Standing in CEMA CasesConnecticut Enacts Omnibus Privacy Law
By Lindsey Tonsager, Laura Kim, Bryan Ramirez & Clare Mathias on
On May 27, 2026, the Connecticut governor signed SB 4, an omnibus privacy law, which among other things, amends the Connecticut Data Privacy Act (“CTDPA”), establishes a data broker registry and accessible deletion mechanism, imposes restrictions on the use of price setting devices and surveillance pricing, and creates requirements for direct-to-consumer genetic testing companies.
Continue Reading Connecticut Enacts Omnibus Privacy LawFTC and DOJ Continue Focus on Consumer Reviews Rule with Complaint Against Premium Home Service
By Laura Kim, Andrew Siegel & Alexandra Remick on
On May 11, 2026, the Department of Justice, acting on notification from the Federal Trade Commission, and the Illinois Attorney General, filed a complaint against “Premium Home Service” and its owner for alleged violations of Section 5 of the FTC Act, the Consumer Reviews Rule, and the Gramm-Leach-Bliley Act (GLB Act). The Complaint seeks injunctive relief, monetary relief, and civil penalties.
Continue Reading FTC and DOJ Continue Focus on Consumer Reviews Rule with Complaint Against Premium Home ServiceMaryland Enacts Law on Personalized Food Pricing
By Laura Kim, Lindsey Tonsager, Jayne Ponder & Natalie Maas on
Posted in Artificial Intelligence (AI), Consumer
On April 28, 2026, Maryland Governor Moore signed HB 895 (the Protection From Predatory Pricing Act) into law, which will impose limitations on the use of personalized pricing in the food retail and grocery delivery context. The law will go into effect on October 1, 2026. As we have detailed in prior blog posts, there has been a wave of personalized pricing proposals at the state level, and the FTC is focusing attention on pricing in the grocery sector.
Continue Reading Maryland Enacts Law on Personalized Food PricingColorado Officials Push to Repeal and Replace the Colorado AI Act
On March 17, Colorado Governor Jared Polis released a draft bill that would substantially overhaul the Colorado AI Act, replacing its core requirements with a narrower regime focused on disclosure, recordkeeping, and consumer notice requirements for “automated decision-making technology” (“ADMT”). The proposal, which is still in draft form and…
Continue Reading Colorado Officials Push to Repeal and Replace the Colorado AI ActFTC Restarts Negative Option Rulemaking Process
By Terrell McSweeny, Laura Kim & Carter McCants on
Posted in Consumer
The Federal Trade Commission (FTC) is poised to re-start a rulemaking process regarding disclosures and requirements for subscription and auto-renewing products and services. On January 30, 2026, the FTC submitted a draft Advance Notice of Proposed Rulemaking (ANPRM) on the Rule Concerning the Use of Prenotification Negative Option Plans (the Rule), commonly known as the Negative Option Rule, to the Office of Information and Regulatory Affairs (OIRA) for review.
Continue Reading FTC Restarts Negative Option Rulemaking ProcessWhat to Watch in 2026: Key Developments in EMEA Consumer Protection
Consumer protection law across EMEA continues to evolve rapidly in response to digitalization, emerging technologies (particularly AI) and the continued expansion of online commerce. As we move into 2026, regulators are preparing significant reforms that will reshape business obligations and strengthen consumer‑protection enforcement. Below is an overview of the most important developments to watch this year.
Continue Reading What to Watch in 2026: Key Developments in EMEA Consumer ProtectionGreystar’s $24 Million Settlement Signals FTC Crackdown on Hidden Rental Fee
By Laura Kim, Jehan Patterson & Analese Bridges on
On December 2, Greystar agreed to a $24 million settlement over allegations it misled renters by omitting mandatory fees from advertised monthly rents. This settlement underscores the FTC’s continuing scrutiny of “junk fees” and signals that the FTC may pursue rulemaking requiring greater transparency in rental fee advertising.
Continue Reading Greystar’s $24 Million Settlement Signals FTC Crackdown on Hidden Rental FeeEuropean Commission Announces 2030 Consumer Policy Strategy
On November 19, 2025, the European Commission unveiled its 2030 Consumer Agenda, setting out priorities for EU consumer policy over the next five years. Below is an overview of the six key measures most relevant to industry.
Continue Reading European Commission Announces 2030 Consumer Policy Strategy