DHS and DOJ Publish Joint Guidelines for Voluntary Sharing Cyber Threat Indicators and Defensive Measures with Federal Government
Client Alert | 1 min read | 06.17.16
On June 15, 2016, the Department of Homeland Security jointly issued with the Department of Justice guidelines and procedures available here for the voluntary sharing and receiving of cyber threat indicators and defensive measures between and among non-federal and federal entities and among private entities for cybersecurity purposes. These guidelines and procedures, which are directed to be published pursuant to the Cybersecurity Information Sharing Act of 2015 (CISA), describe what types of information may be shared, the mechanisms for sharing it (including through the DHS-operated Automated Indicator Sharing platform), and how to safeguard privacy and civil liberties to qualify for the liability and other protections afforded by CISA, which include a limited antitrust exemption; exemption from state and federal disclosure laws; exemption from certain state and federal regulatory uses; no waiver of privilege; protection for commercial, financial and proprietary information; and an ex parte communications waiver.
Insights
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
