Christopher Olsen

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On November 6, 2025, the California, Connecticut, and New York Attorneys General (collectively, the “Attorneys General”) announced a settlement with Illuminate Education, Inc. to resolve allegations that the company violated state privacy laws following a student data breach. The settlement marks the first enforcement actions under the California K-12 Pupil Online Personal Information Protection Act (KOPIPA, formerly known as SOPIPA) and Connecticut’s Student Data Privacy Law, and also constitutes the second major enforcement action under New York Education Law § 2-d.Continue Reading EdTech Provider Agrees to $5.1 Million Settlement with Three State Attorneys General over Student Data Breach

On July 14, 2025, the European Commission (EC) published its guidelines (the Guidelines) on the protection of minors online. These Guidelines, which were initially released for consultation in May 2025, provide direction for online platforms on the steps they can take to comply with their duties to protect the privacy, safety, and security of minors under the EU’s Digital Services Act (DSA). They focus on assessing and mitigating platform risks, the appropriate use of age assurance, and measures that should be taken to protect minors from manipulative commercial practices.Continue Reading European Commission Publishes DSA Guidelines on the Protection of Minors Online

Nebraska and Vermont are the latest U.S. states to join the growing landscape of children’s online safety laws that have swelled in state chambers in recent years. On May 30, 2025, Nebraska Governor Jim Pillen signed the Age-Appropriate Online Design Code Act (the Nebraska AADC). On June 12, 2025, Vermont Governor Phil Scott signed the Vermont Age-Appropriate Design Code Act (the Vermont AADC). In doing so, Nebraska and Vermont join California and Maryland, which in 2022 and 2024, respectively, enacted age-appropriate design code laws of their own. Notably, the ongoing legal challenges1 to the California and Maryland AADCs do not appear to have dissuaded state legislators from enacting AADC-style and other children’s online safety laws. The Nebraska AADC takes effect January 1, 2026 (though the state Attorney General (AG) must wait until July 1, 2026, to seek civil penalties). The Vermont AADC takes effect January 1, 2027.Continue Reading Nebraska and Vermont Pass Age-Appropriate Design Codes

On February 4, 2025, the European Commission (EC) issued draft guidelines clarifying the AI practices that are prohibited under the European Union’s (EU) Artificial Intelligence (AI) Act. While non-binding, the guidelines offer valuable clarifications and practical examples to help businesses navigate their obligations under the AI Act. The EC has approved the draft guidelines, but is still to formally adopt them, which is expected in the near term.Continue Reading EU Commission Issues Guidelines on Prohibited AI Practices Under EU AI Act

We are less than a month into the new Trump administration and are seeing an unprecedented wave of activity and major changes at federal agencies. These changes promise to bring significant disruption to the staff and negatively impact the typical activities of numerous agencies, including the nation’s consumer protection watchdog, the Federal Trade Commission (FTC). As discussed below, we expect the impact on the FTC to be significant given the rapid and aggressive moves by the new administration. And we expect state Attorneys General (AGs) to step in to fill the gap.Continue Reading Consumer Protection Update: With Disruption at the Federal Level, State Attorneys General Are Likely to Loom Large

With Inauguration Day just around the corner, we are likely to see a host of new legislative and enforcement initiatives at the federal level. The Federal Trade Commission (FTC) will shift certain priorities under incoming Chairman Andrew Ferguson’s direction. And at the state level, legislatures and state attorneys general (state AGs) will continue to be active, enacting and enforcing a slate of new laws. As we ring in the new year, companies should be mindful of the new laws, regulations, and enforcement priorities that will likely impact them. Below are the top 10 U.S. privacy, cybersecurity, and consumer protection developments to watch out for in 2025:Continue Reading New Year, New Developments: 2025 U.S. Privacy, Cybersecurity, and Consumer Protection Predictions