Gov't Scrutiny of Higher Education Institutions Continues
Client Alert | less than 1 min read | 09.12.12
On September 5, following a string of recent cases involving government scrutiny of academic institutions, the Second Circuit affirmed that Cornell University and a professor at the school had violated the FCA by submitting false claims in applications for federal grants. In a decision that should raise eyebrows in the higher education community, the court held that, because the research grant at issue "did not produce a tangible benefit" to the government and because "the government has entirely lost its opportunity to award the grant money to a recipient who would have used the money as the government intended," the proper measure of damages is the full amount of the grant.
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Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
