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DoD Mandates Preparation for Climate Change

Client Alert | less than 1 min read | 01.18.16

On January 14, 2016, DoD issued Directive 4715.21 (Climate Change Adaptation and Resilience), which establishes a comprehensive framework for agency efforts to (i) address, mitigate, and adapt to climate change risks to U.S. military assets and operations; and (ii) integrate climate change risk considerations into DoD acquisition and mission planning. As described in this post [MAKE THIS A LINK], the DoD Directive does not address several questions that will likely be answered on a piecemeal basis through multiple new or modified regulations, standards, and guidelines, providing the private sector with several opportunities to shape implementation of the directive and to address downstream effects to contracts and corporate policies.

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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....

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