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Customs 10+2 Initiative

Client Alert | 1 min read | 02.11.08

Importers face a new filing obligation arising before the entry documents are filed, and indeed before merchandise is even loaded into a container: a recent Customs proposal would mandate the submission of an Importer Security Filing ("ISF") 24 hours prior to container loading. The ISF would require ten data fields, including:

(1) Manufacturer (or supplier) name and address
(2) Seller (by owner) name and address
(3) Buyer (or owner) name and address
(4) Ship-to name and address
(5) Container stuffing location
(6) Consolidator (stuffer) name and address
(7) Importer of record number/foreign trade zone applicant identification number
(8) Consignee number(s)
(9) Country of origin
(10) Commodity Harmonized Tariff Schedule number

Customs is accepting comments on the proposal, known as the "10 + 2 Rule," until March 18, 2008. To date, the trade has been critical of the proposal because compliance with the ISF filing requirements will alter the way many companies do business. Creating new data gathering systems will be a significant burden, and many transactions (particularly CIF sales, which would make compliance with the rule difficult) now will require entirely new commercial arrangements.

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Client Alert | 13 min read | 10.30.25

Federal and State Regulators Target AI Chatbots and Intimate Imagery

In the first few years following the public launch of generative artificial intelligence (AI) in the autumn of 2022, litigation related to AI focused primarily on claims of copyright infringement. Suits revolved around allegations that the data on which AI models train, and/or the output they produce, infringe upon the intellectual property rights of others. (While some of these cases have settled or reached preliminary judgments, many remain ongoing.)...