On August 11, 2022, the Federal Trade Commission (FTC) voted 3-2 on partisan lines to file an Advance Notice of Proposed Rulemaking (ANPR) that would regulate the protection of consumers’ privacy and data security in a rulemaking titled “Trade Regulation Rule on Commercial Surveillance and Data Security.”

The release of this ANPR—in the midst of

On May 11, 2022, the Senate confirmed President Biden’s appointment of Alvaro Bedoya to fill the vacant Democratic seat on the Federal Trade Commission (FTC). Commissioner Bedoya’s confirmation gives the Democratic commissioners a voting majority on the Commission, and we expect the FTC will pursue actions previewed by Chair Lina Khan. In this Legal Update,