The Federal Trade Commission issued a supplemental notice of proposed rulemaking on February 15, 2024, in which it recommended a trade regulation rule that would (1) impose liability on businesses who provide goods or services (including artificial intelligence technology) with knowledge or reason to know they will be used to engage in unlawful impersonation of individuals, government, or businesses; and (2) prohibit impersonation of individuals.

Read the full Update here.

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Photo of Erin K. Earl Erin K. Earl

Erin Earl defends companies in high-stakes privacy and security litigation and government agency investigations, including inquiries from the Federal Trade Commission (FTC) and state attorneys general.

Photo of Janis Kestenbaum Janis Kestenbaum

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security…

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security, and consumer protection issues.

Photo of Courtney Otto Courtney Otto

Courtney draws upon her experience analyzing complex statutes as a student advocate of Boston University School of Law’s Compliance Policy Clinic and as a Matthew Z. Gomes fellow of the BU/MIT Technology Law Clinic (now known as the BU/MIT Student Innovations Clinic). She…

Courtney draws upon her experience analyzing complex statutes as a student advocate of Boston University School of Law’s Compliance Policy Clinic and as a Matthew Z. Gomes fellow of the BU/MIT Technology Law Clinic (now known as the BU/MIT Student Innovations Clinic). She also has completed the Certified Information Privacy Professional (CIPP/US) program through the International Association of Privacy Professionals (IAPP).