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Karim Alhassan

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Witnessing the race to harness the power of Artificial Intelligence (“AI”) by markets and businesses, the Federal Trade Commission (“FTC”), recently issued a warning over the emerging technology and its ever-widening use cases. Citing its authority under Section 6(b) of the FTC Act, the Commissioners voted 5-0 on July 19 in favor of issuing investigative…

In the latest of a recent string of judicial rebukes, the Supreme Court’s unanimous decision in Axon Enterprise, Inc. v. FTC  offers the targets of Federal Trade Commission (“FTC”) and other agencies’ administrative proceedings a path to quicker judicial relief.  Historically, courts have been reluctant to permit immediate challenges to investigations and adjudications without forcing the targets to wait for the resolution of all agency proceedings.  While aptly referred to as the doctrine of “exhaustion,” the result, as Justice Gorsuch observed, is that “agencies sometimes use this as leverage to extract settlement terms they could not lawfully obtain any other way.”  The Court’s decision in Axon not only deprives the FTC of a potential source of leverage, but it also increases the likelihood that companies faced with investigations may turn to the courts for relief at an earlier stage.  The decision comes at a time when the FTC’s powers and attempts to exercise those powers have been called into question by the bar, members of Congress, and by courts.Continue Reading Unanimous Supreme Court limits FTC and other agencies’ investigative power

Almost 20 million Americans — 8 percent of the U.S. population — are blind or have visual impairments. Accordingly, organizations and businesses in nearly every industry stand to benefit from the use of vision related accessibility tools, which can increase employee productivity and provide a more inclusive user experience. To address this need, M365 incorporates a slew of tools and features – such as screen readers, text-to-speech, and color filters – that make it easier for end users with visual impairments to access, use, and benefit from M365 products. However, because these tools may collect and store user data in ways that may not be immediately apparent, businesses employing them must remain cognizant of the potential downstream risks associated with their use. Listen to our latest Tech Law Talks podcast episode, M365 accessibility: Vision-specific tools, as we discuss.Continue Reading M365 Accessibility: Considerations and Risks Associated with Vision Related Tools

With increased digitization of business processes and services affecting all industries and enterprises, the need for accessible digital tools continues to grow. Indeed, 26% of adults living in the United States have some type of disability, highlighting the crucial role accessibility tools serve in ensuring an inclusive digital environment.  Furthermore, in certain instances, the implementation of accessibility best practices may be legally required. We discuss these issues in our most recent Tech Law Talks podcast.Continue Reading Digital Accessibility: Legal & Practical Issues to Consider

With the continued rapid growth of both technological innovations and the market power of the companies spurring these innovations, calls for greater regulation and enforcement of companies in the technology sector are only growing louder. However, the same question continues to be asked – “how can governments regulate businesses they don’t fully understand?”Continue Reading Only Sheriff in Town? Not so fast: National Association of Attorneys General announces the formation of the Center on Cyber and Technology.

The Federal Trade Commission (FTC or Commission) has issued a final rule clarifying its data security requirements for certain covered financial institutions. The new rule, which amends the Safeguards Rule originally promulgated in 2002 under the Gramm-Leach-Bliley Act (GLBA), outlines specific criteria to be incorporated as part of GLBA-covered financial institutions’ information security programs. The primary changes include:

  • A requirement to designate a single qualified individual responsible for overseeing the information security program and periodically reporting to the board (or other governing body)
  • Identification of specific security risk assessment criteria and a requirement that such assessments be documented in writing
  • Specific required safeguards, including access controls, encryption, data disposal procedures, continuous monitoring, and penetration testing
  • Service provider selection criteria and a related requirement to periodically assess service providers based on perceived risk
  • Expansion of the definition of “financial institution” to clarify that it includes entities providing “finder” services incidental to financial activities

The updated rule takes effect 30 days after publication in the Federal Register, but some of the more significant new requirements will not take effect for another year.Continue Reading FTC significantly amends GLBA Safeguards Rule