AI Chat Bot_Ifrah FTC Blog (1)

Thinking about adding an AI Chatbot? Some key considerations.

Thinking about adding an AI Chatbot? Some key considerations.

February 17, 2026

Thinking about adding an AI Chatbot? Some key considerations.

By: Steven Hess

Many companies are thinking about how to deploy new AI systems to automate routine work and to improve their product. For many businesses, adding an AI chatbot is a valuable way to enhance the customer experience by automating routine conversations,[1] and by alerting customers to new deals and offerings that are relevant to them.[2] Coupled with the rising ubiquity of AI chatbots in modern life,[3] these AI agents can be integrated into existing consumer platforms to provide faster, more adaptive services. As with any new innovation, there are also concerns with integrating AI chatbots into existing products.  Because these products are new, so too are the risks, and it is not possible to identify every concern that may arise from…

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Is Scrolling the New Smoking?

January 21, 2026

Is Scrolling the New Smoking?

By: Lauren Scribner

In the final weeks of 2025, New York passed a law requiring social media platforms with “certain predatory features” to display warning labels about “the dangerous impact” those features pose to the mental health of users under the age of eighteen.[1] These so-called “predatory features” include continuous and infinite scrolling, displaying addictive feeds, and automatically playing video content.[2]  Warning labels will be displayed upon the…

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Influencer Liability: Will New-Age Litigation Net Celebrity Spokespeople?

December 12, 2025

Influencer Liability: Will New-Age Litigation Net Celebrity Spokespeople?

By: Lauren Scribner

The “influencer economy,” in which so-called “content creators” share user-generated content such as livestreams or short-form film, is showing no signs of slowing down.  Currently valued north of $250 billion, it is projected to reach nearly $500 billion by 2027.[1] “Creators earn income primarily through direct branding deals to pitch products as an influencer; via a share of advertising revenues with the host platform; and…

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CFPB Scare Tactics: The New Arbitration Rules

May 5, 2016

CFPB Scare Tactics: The New Arbitration Rules

By: George Calhoun

Recently, I wrote about the CFPB’s plans to issue new regulations restricting arbitration clauses in certain consumer contracts.  Today, the agency announced those new rules and CFPB Director Richard Cordray is expected to discuss them at the agency’s field hearing in Albuquerque, New Mexico.  As expected, the new rules eliminate the use of class action waivers and otherwise restrict the availability of arbitration in consumer…

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Judge Flunks Case Against LabMD, FTC Appeals

April 20, 2016

Judge Flunks Case Against LabMD, FTC Appeals

By: Jeffrey Hamlin

In March 2015, I wrote about the ongoing dispute between the FTC and LabMD, an Atlanta-based cancer screening laboratory, and looked at whether the FTC has the authority to take enforcement action over data-security practices alleged to be insufficient and therefore “unfair” under section 5(n) of the Federal Trade Commission Act (“FTCA”). On November 13, 2015, an administrative law judge ruled that the FTC had…

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Wells Fargo Learns That Recording Calls In California Can Be Costly

April 5, 2016

Wells Fargo Learns That Recording Calls In California Can Be Costly

By: Michelle Cohen

In the past few years, many organizations such as Capital One, Bass Pro Outdoor, and the Cosmopolitan Hotel have faced class actions alleging violations of California’s call recording law.  This week, California’s Attorney General demonstrated that her office, working with state prosecutors, will also vigorously enforce the law under the state’s criminal statutes.  Attorney General Harris announced an $8.5 million dollar settlement with Wells Fargo…

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Arbitration Under Fire: Brace Your Company for Less Contract Freedom and More Class Actions

March 31, 2016

Arbitration Under Fire: Brace Your Company for Less Contract Freedom and More Class Actions

By: George Calhoun

Since the Federal Arbitration Act (FAA) of 1925, the United States has had a policy preference for arbitration, even when an arbitration provision includes language barring class action litigation.  We saw this most recently in December 2015 when the Supreme Court reversed a decision by a California Court of Appeal to invalidate a class-arbitration waiver within a service agreement between DirecTV and its customers.[1]  But…

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To Refer, Or Not To Refer? OIG’s Outdated Health Care Referral Restrictions

March 21, 2016

To Refer, Or Not To Refer? OIG’s Outdated Health Care Referral Restrictions

By: Drew Barnholtz

The Office of the Inspector General, which enforces Health and Human Services, has long been averse to referral services that don’t meet certain criteria.  To get protection against a possible enforcement action, the referral service can’t exclude anyone from participating in the service, and payments for referrals have to be reasonable and cannot be tied to the volume or value of the referrals that are…

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Articles and Presentations by Our Firm Attorneys

Thinking about adding an AI Chatbot? Some key considerations.

Thinking about adding an AI Chatbot? Some key considerations.
By: Steven Hess

Is Scrolling the New Smoking?

Is Scrolling the New Smoking?
By: Lauren Scribner

Influencer Liability: Will New-Age Litigation Net Celebrity Spokespeople?

Influencer Liability: Will New-Age Litigation Net Celebrity Spokespeople?
By: Lauren Scribner

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