On April 22, 2025, the EU Commission’s AI Office published draft guidelines to clarify the obligations in the EU AI Act for providers of general-purpose AI models (guidelines). These obligations will be applicable to AI models released in the EU market after August 2, 2025. The guidelines are currently open for public consultation, and the
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FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices
On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the FTC alleges in its complaint that Uber violated Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence…
The UK’s Online Child Safety Duties Are Coming into Force: Steps to Take Now
On April 24, 2025, the UK’s Office of Communications, commonly known as Ofcom—the regulator responsible for enforcing the UK’s Online Safety Act (OSA)—issued its Protecting Children from Harm Online Statement. The statement requires online services to conduct and document a children’s risk assessment in accordance with the OSA by July 24, 2025. Services will be required to…
CPPA Board Grapples with Public Concerns: Key Updates on Upcoming AI, Risk Assessment, and Cybersecurity Regulations
On April 4, 2025, the California Privacy Protection Agency (CPPA) Board met to discuss the latest draft California Consumer Privacy Act (CCPA) regulations related to cybersecurity audits, risk assessments, automated decision-making technology (ADMT), and an assortment of other updates to existing regulations. These revisions come after the CPPA first released draft regulations on these topics…
Utah Enacts Mental Health Chatbot Law
On March 25, 2025, Utah Governor Spencer Cox signed HB 452, which establishes new rules for the use of artificial intelligence (AI) mental health chatbots accessible to any “Utah user,” defined as, “an individual located in the state at the time the individual accesses or uses a mental health chatbot.” Digital health companies and…
UK Regulator Issues Three Million GBP Monetary Penalty in Connection with Ransomware Attack
On March 27, 2025, the Information Commissioner’s Office (ICO) announced a fine of 3 million GBP (3.9 million USD) against a software provider (the company) for security deficiencies following a ransomware incident (e.g., lack of multi-factor authentication (MFA)). This is the first time the ICO has fined a processor under the UK’s General Data Protection…
EU Data Act Imposes New Data Sharing Obligations
As of September 12, 2025, the EU Data Act will impose new obligations concerning the sharing of, and access to, data generated by certain products and services offered in the EU. This alert highlights the data sharing obligations for providers of connected devices and related services.…
Lessons from the CPPA’s $632,500 Settlement with Connected Vehicle Manufacturer
On March 12, 2025, the California Privacy Protection Agency (CPPA) announced a settlement with American Honda Motor Co. (Honda) over alleged violations of the California Consumer Privacy Act (CCPA). The CPPA investigated Honda as part of its investigative sweep into the data privacy practices of connected vehicles and related technologies, announced in July 2023.…
CPPA Votes Out Proposed Delete Request and Opt-Out Platform (DROP) Data Broker Regulations
On March 7, 2025, the California Privacy Protection Agency (CPPA) Board met to discuss its proposed data broker regulations concerning the Delete Request and Opt-Out Platform (DROP) and voted to authorize CPPA staff to advance the regulations to formal rulemaking. As mandated by the Delete Act (discussed in a previous alert), the DROP will…
European Privacy Regulators Issue Guidance on Age Assurance
On February 11, 2025, the European Data Protection Board (EDPB) adopted a statement (Statement) on age assurance. The Statement comes at a formative time in the development of age assurance practices, as EU and UK regulatory frameworks increasingly require companies to take steps to identify and protect child users of online services. The Statement outlines…