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These Are a Few of Our Favorite IoT: NIST Finalizes Internet of Things Cyber Guidance

Client Alert | 1 min read | 07.02.19

NIST has finalized Internet of Things (IoT) risk management guidance, which derived from a draft publication.  The guidance informs government agencies how to understand and manage IoT risks throughout device lifecycles.  Industry can anticipate government focus on three high-level goals:

  1. Device security;
  2. Data security; and
  3. Individual privacy.

The publication highlights three differences between managing risks for IoT devices and conventional information technology devices:

  1. IoT devices interact with the physical world differently than conventional devices;
  2. IoT devices cannot be accessed and monitored the same as conventional devices; and
  3. The availability and effectiveness of cybersecurity and privacy capabilities are different for IoT devices than conventional devices.

While not mandatory, the guidance provides useful considerations for IoT cybersecurity and privacy risk management.

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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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