[{"url":"https://hdl.handle.net/1866/46704","source":"Faculté de droit Travaux récents","pubDate":"Wed, 14 Oct 2026 08:14:30 +0200","id":3215934,"titre":"State of software diversity in ethereum","description":"dc.contributor.author: Gonzalez Fernandez, Nadia dc.date.issued: 2026-10 dc.description.abstract: La diversité logicielle contribue à améliorer la fiabilité et la sécurité des systèmes depuis les années 1960, notamment gr'ce à des modèles dans lesquels une autorité centrale mandate et certifie des implémentations indépendantes. Au cours de la dernière décennie, Ethereum a déployé la diversité à grande échelle sous une forme nouvelle : 11 clients indépendants y coexistent sans être mandatés ni certifiés par une autorité centrale, tout en bénéficiant de la diversité déjà présente dans l’écosystème open source. Cette thèse étudie Ethereum comme un exemple de ce modèle émergent de diversité logicielle, en examinant son adoption, son étendue dans le code des clients et les défis qu’elle soulève. Nous combinons des entretiens semi-directifs avec sept contributeurs impliqués dans le développement, la coordination et le suivi de la diversité des clients, avec la première analyse statique complète de la chaîne d’approvisionnement logicielle des 11 clients les plus utilisés. Deux principaux résultats se dégagent. Premièrement, la communauté Ethereum veille activement au maintien de cette diversité au moyen d’une spécification commune, d’un suivi continu de la distribution des clients, de financements dédiés et d’interventions visant à limiter leur concentration. Deuxièmement, notre analyse montre que cette diversité s’étend au code : huit moteurs de bases de données indépendants sont utilisés par les 11 clients, tandis que les équipes convergent volontairement vers les composants les plus difficiles à implémenter correctement et privilégient leur audit plutôt que la multiplication d’alternatives non vérifiées. Ainsi, Ethereum constitue un exemple de diversité logicielle étendue et activement entretenue par sa communauté.; Software diversity has improved reliability and security in systems since the 1960s, through models in which a central authority commissions and certifies independent implementations. Over the last decade, Ethereum has deployed diversity at scale in a new form: 11 independent clients coexist without any central authority commissioning or certifying them, while also leveraging the diversity already present in the open-source ecosystem. This thesis studies Ethereum as a case of this emerging software diversity model, asking how such diversity is adopted, how far it reaches into client code, and what challenges it introduces. We combine semi-structured interviews with seven contributors who build, coordinate, and monitor client diversity with the first comprehensive static analysis of the software supply chain of the 11 most widely used clients. Two results follow. First, the Ethereum community actively cares for and sustains its client diversity: interviewees describe coordination through a shared specification, continuous monitoring of client distribution, dedicated funding, and intervention against client concentration. For example, when Prysm exceeded 60% of the consensus layer, the community organized a campaign to redistribute validators away from it. Second, our supply chain analysis confirms that this diversity extends into the codebase: eight independent database engines back the 11 clients, and teams deliberately converge on the components hardest to implement correctly, funding their audit rather than multiplying unverified alternatives. Ethereum exhibits extensive software diversity that its community actively cares for and maintains. This sets an"},{"url":"https://www.ftc.gov/business-guidance/blog/2018/10/ftc-sues-american-immigration-center-claiming-false-government-affiliation","source":"FTC USA Business Blog Posts","pubDate":"Thu, 08 Oct 2026 08:06:59 +0200","id":3203252,"titre":"FTC sues American Immigration Center for claiming false government affiliation","description":"FTC sues American Immigration Center for claiming false government affiliation lfair October 16, 2018 | 12:16PM FTC sues American Immigration Center for claiming false government affiliation By Lesley Fair When the FTC warns consumers about government imposter scams, we’re usually referring to bogus calls that falsely claim to come from the IRS or some other official office. But as a case just announced by the FTC demonstrates, that’s not the only kind of false government affiliation that can deceive consumers. A $2.2 million settlement with American Immigration Center reminds other businesses of the dangers of conveying a misleading connection to a government agency. When consumers wanted to renew their green cards or apply for naturalization, where did they go? Online, of course, where they input terms like “USCIS,” “INS,” or “US Immigration” to search for the proper government site. According to the FTC, that’s how they ran across results with tag lines like “USCIS Forms – Easy Online Forms for Green Card & Citizenship.” A click took them to sites with the outward appearance of official government webpages. First, there were the URLs – usimmigration.us, uscitizenship.info, etc. Then there was the red, white, and blue color scheme, the Statue of Liberty, passports, and pictures of then-President Obama. What’s more, people looking for, say, Green Card Renewal Form I-90, saw links with the exact name of the relevant document. According to the FTC, people paid between $120 to $300 and input a substantial amount of personal information, all under the impression they were filing documents directly with a government agency. Except that they weren’t. Despite the appearance of those pages, consumers were actually on one of many commercial sites the defendants used to sell their “software wizard” to fill out government immigration forms. And the money consumers paid didn’t go toward government filing fees. It went straight into the defendants’ pockets. In addition to the $2.2 million judgment, the defendants have agreed to clearly disclose that: 1) their sites aren’t affiliated with the government; 2) people must separately file immigration applications with the appropriate government agency; and 3) people must separately pay applicable filing fees to the government. The proposed order also bars the defendants – principal Cesare Alessandrini and Forms Direct, Inc., doing business as American Immigration Center – from stating or implying any affiliation with the government. What’s the message for other companies? Avoid an affiliation conflation. Look at your ads and websites from the point of view of your target audience. Could prospective customers be left with the misimpression that your company has an affiliation with a government agency? Steer clear of any purported connection to a local, state, or federal government office. Consider the big picture. The complaint in this case cited the words the defendants used to convey claims to consumers, as well as what their websites looked like. That’s because, according to the FTC Deception Policy Statement , “The Commission will evaluate the entire advertisement, transaction, or course of dealing in determining how reasonable consumers are likely to respond.” That specifically includes visual imagery and the omission of material information. Wise companies bear in mind the FTC’s long-established “net impression” standard and exercise caution in drafting their copy, selecting graphics, and choosing what they say – and what they don’t say – to consumers."},{"url":"https://www.ftc.gov/business-guidance/blog/2020/01/ftc-consumer-protection-year-review-offers-2020-vision-your-business","source":"FTC USA Business Blog Posts","description":"FTC consumer protection year in review offers 2020 vision for your business lfair January 8, 2020 | 9:26AM FTC consumer protection year in review offers 2020 vision for your business By Lesley Fair They say hindsight is 20/20, but what about foresight? We’re not ones to prognosticate, but a look at notable FTC cases and initiatives from the past year suggests some topics likely to be top of mind in months to come. Here is a non-exhaustive list of issues in our 2019 rearview mirror and likely visible through the 2020 windshield. Consumer privacy. The FTC’s $5 billion enforcement action against Facebook made history and headlines, but the other notable part of the case is the monumental change the order mandates to Facebook’s privacy ecosystem. The Commission opinion in Cambridge Analytica reaffirms the proposition that like any other claim, a company’s privacy promises are viewed through the lens of established FTC consumer perception principles. A series of cases demonstrates the agency’s continued commitment to challenging false or misleading representations about businesses’ compliance with the EU-U.S. Privacy Shield Framework. Another important development is the FTC’s proposed settlement with Retina-X . It’s our first action against a marketer of stalking apps – software that allowed purchasers to monitor the mobile devices on which they’re installed, without users’ knowledge. COPPA. Congress passed the Children’s Online Privacy Protection Act to ensure that when it comes to the collection of kids’ personal information online, parents are in the driver’s seat. The FTC settlement with YouTube – brought in conjunction with the New York Attorney General – alleges that the company collected kids’ personal data without parental consent, in violation of the COPPA Rule . The $170 million civil penalty broke the record for the largest remedy in an FTC COPPA case, set months before in our $5.7 million settlement with Musical.ly , now known as TikTok. If you’re a YouTube channel owner, read a special Business Blog post for tips on determining if your content is directed to children. Data security. Is your company honoring its data security promises and taking reasonable steps to safeguard the sensitive information in its possession? The FTC, CFPB, and State AG actions against Equifax illustrate how consumers are injured when companies ignore reasonably foreseeable threats. The settlement, which totals between $575 million and $700 million – also reminds businesses that heeding warnings about known risks is more prudent (and cost-effective) than the alternative. Three threads tie together the FTC’s unrelated actions against LightYear Dealer Technologies and InfoTrax Systems . They both sell management software to specific industries. They both allegedly failed to take reasonable steps to secure their networks, resulting in damaging data breaches. And they’re both covered by similar new orders the FTC has introduced in recent data security cases. If you or your clients are players in the Internet of Things, the settlement of the FTC’s litigation against connected device company D-Link sends an unmistakable message: The future of the IoT marketplace depends on secure software development. Endorsements, certifications, and influencers. Why is the FTC concerned about the accuracy of endorsements and certifications? Because they’re material to consumers. The FTC says Truly Organics’ claim that its personal care products were “certified organic” lathered up a double bubble of deception. First, its merchandise contained ingredients that weren’t organic. Second, the company falsely claimed that its products were certified by USDA’s National Organic Program. Other FTC developments focused on the use of endorsements in social media. The FTC’s action against Devumi alleges the company sold fake followers, phony subscribers, and bogus","pubDate":"Thu, 08 Oct 2026 08:06:58 +0200","id":3203247,"titre":"FTC consumer protection year in review offers 2020 vision for your business"},{"source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2018/09/root-root-root-regions","description":"Root, root root for the regions lfair September 24, 2018 | 2:03PM Root, root root for the regions By Andrew Smith, Director, FTC Bureau of Consumer Protection T his year eight major league baseball teams are celebrating milestone anniversaries – and so are the FTC’s regional offices. In 1918, the Commission opened the first three of its regional offices. Today, eight regional offices continue to knock it out the park on behalf of America’s consumers. So it’s only fitting that on this momentous day we acknowledge the regional offices’ century of pennant-winning performances. According to the Commission’s 1918 Annual Report, “In order to expedite the greatly increased work of the Commission . . . small branch offices were established in New York, Chicago, and San Francisco.” Over time, the FTC has added other locations for a current total of eight offices in seven regions. Regional staff work with the Bureau of Consumer Protection and the Bureau of Competition on investigations and litigation. But they are in a unique position to host roundtables and workshops in their communities; to coordinate with local, state, and cross-border law enforcers; and to build partnerships with consumer groups and small business organizations within their region. According to the scouting report, there isn’t a pitch they can’t hit. Here’s a brief look at each region’s box score with a focus on just a few of their many MVP contributions to the FTC’s consumer protection mission. East Central Region . In 1918, the Cleveland Indians finished just out of pennant contention, but the FTC’s Cleveland-based office works hard to bring home the W for consumers and small businesses. For example, ECR has brought a number of cases over the past two decades to protect small businesses in their area and around the country, including cramming, business directory, and unordered merchandise scams. Recently, ECR played a central role in Operation Main Street, the FTC’s recent initiative against scammers targeting small businesses. Midwest Region . Chicago fans may be divided in their loyalty to the Cubs and the White Sox, but consumers who lost money to scammers who used the services of a major money transfer company are united in their appreciation for the FTC-DOJ settlement that returned $586 million back to them. And just recently, MWR hosted the Commission’s workshop on cryptocurrency scams and took a lead role in Operation Tech Trap, a coordinated state, federal, and international effort to shut down tech support fraudsters. Northeast Region . Given New York’s connection to names like Huggins, Houk, Stengel, Berra, and Torre, it’s no wonder the FTC’s Northeast Region has particular expertise in coaching. But in NER’s case, it’s about companies that make deceptive “coaching” and money-making representations. The New York-based office also has been one of the FTC’s power hitters in addressing misleading practices in the affiliate marketing industry. And from their Big Apple location, NER has been a leader in educating consumers, particularly older Americans and small businesses. Northwest Region . Like their hometown Seattle Mariners, the FTC’s Northwest Region has a proven record of navigating the complexities on the field of play. NWR coordinated Operation Donate with Honor, a nationwide crackdown on fraudulent charities alleged to have conned consumers by falsely promising their contributions will help veterans and servicemembers. In addition, our team in Seattle regularly coordinates with Canadian counterparts to combat cross-border fraud. And they’ve been ahead of the curve on tech issues, bringing one of the FTC’s first internet cases in the 90s and more recently, an early online influencer action. Southeast Region . The Atlanta Braves boast a national fan base – and due to their expertise in fighting fraud, the FTC’s Southeast Region can be proud of its coast-to-coast impact,","titre":"Root, root root for the regions","pubDate":"Wed, 07 Oct 2026 14:05:07 +0200","id":3201877},{"source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2017/10/clothes-look-rn-database-qa-ftc-staff","titre":"A clothes look at the RN database: Q&A with FTC staff","pubDate":"Wed, 07 Oct 2026 14:05:06 +0200","id":3201873,"description":"A clothes look at the RN database: Q&A with FTC staff lfair October 5, 2017 | 11:18AM A clothes look at the RN database: Q&A with FTC staff By Lesley Fair It’s not much bigger than a postage stamp, but the label on many textile, wool, and fur products provides important information, including fiber content, country of origin, and a company name or Registered Identification Number (RN). The FTC administers the RN system and industry members will want to check out recent upgrades to the RN website . With RNs and labels on our mind, we asked some common RN-related questions to attorney Josh Millard, whom we’d label as one of the FTC’s go-to people on the subject. First things first. What’s an RN? JOSH:   A Registered Identification Number (RN) is a numerical designation – the prefix RN followed by a set of digits – that identifies the company responsible for marketing, distributing or otherwise handling a product covered by the Textile, Wool, and Fur Acts.  Because some labels are small and some company names are long, the law allows U.S.-based businesses to use an RN as a “shorthand” identification. We think the upgrades to the RN website will make it even easier for businesses to use. How do I get an RN for my company? JOSH:   Apply online. FTC staff will review your application and email you typically within 1-3 business days. As soon as your application has been approved, you’ll receive your RN.  How much does it cost to get an RN? JOSH:   There’s no charge. Is it mandatory that companies use an RN on labels? JOSH:   No, you don’t have to use an RN. It’s perfectly acceptable to include your company name instead, but many companies prefer to use an RN because it takes up less space. The RN system has other benefits, too. For example, it lets people identify your business easily through the RN Search screen . Consumers or other industry members can type in the number and readily find your business. Our company doesn’t reside in the United States.  Can we get an RN? JOSH:   Only U.S.-based businesses can get an RN. If your foreign company manufactures or is involved in the advertising, distribution, or sale of a product covered by the Textile, Wool, and Fur Acts, put the company name on the label instead of an RN. Alternatively, you can label the product with the RN or business name of a U.S. company directly involved with importing, distributing, or selling the product when that’s the case. Going through our records we found we have multiple RNs.  Is that a problem? JOSH:   It’s not prohibited, but we no longer issue multiple RNs to a single company and encourage companies to cancel any extra RNs to simplify recordkeeping. Our headquarters has moved since we applied for an RN.  Do we need to update our application? JOSH:   Yes. If there has been a change to your business name, address, or legal status, please update the information in your RN registration.  An RN can be cancelled if a business doesn’t keep its information up to date, so it’s wise to check. The good news is that the upgraded RN website makes that easier to do. What if we choose to use a company name on the label, rather than an RN? JOSH:   You must include the full name your company uses to do business – in other words, the name that appears on documents like purchase orders or invoices. It can’t be a trademark, trade name, brand, or designer name unless that’s also the name under which your company does business. What kind of guidance does the FTC have for industry members? JOSH:  Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts is a great place to start, and the FTC’s Clothing and Textiles page includes links to brochures, cases, workshops and other compliance resources."},{"titre":"FTC recaps consumer complaint data for 2017: Who’s on the list?","id":3199077,"pubDate":"Tue, 06 Oct 2026 08:06:24 +0200","description":"FTC recaps consumer complaint data for 2017: Who’s on the list? lfair March 1, 2018 | 5:17PM FTC recaps consumer complaint data for 2017: Who’s on the list? By Lesley Fair Once bitten, twice shy. That fundamental principle of human behavior is why reputable businesses that work hard to earn consumers’ confidence should support the FTC’s ongoing efforts to fight fraud. According to the FTC’s 2017 Consumer Sentinel Data Book , consumers reported losing a total of $905 million to fraud last year. That’s close to a billion bucks people won’t be able to spend on legitimate products and services from credible companies. That figure is up $63 million from last year, although the total number of reports received from consumers is down from 2.98 million in 2016 to 2.68 million in 2017. Topping the list that no industry wants to be on is debt collection, making up 23% of the total number of complaints. But there are two caveats: 1) that number is down from 2016; and 2) the high number of debt collection reports was due in part to reports submitted by a data contributor who collects complaints via a mobile app. Second on the list is identity theft at 14%. The injury to consumers came in two equally unpalatable flavors. Credit card fraud was the most common manifestation. Tax fraud was next, but the glimmer of hope there is that the total number of tax-related identity theft complaints fell by 46%. Winners of the dubious bronze medal were imposter scams , with consumers reporting financial losses of a whopping $328 million. Imposters wear many masks: “I’m with [big-name tech company] and your computer is riddled with viruses,” “Help, Grampa! I’ve been arrested and need bail money,” and “We’re from [government agency] and we’ll arrest you if you don’t pay us today.” Nearly one in five consumers who reported an imposter scam said they lost money to the fraud. For the first time, the Consumer Sentinel Data Book breaks out fraud losses by reported age groups and here’s a result that may surprise you: Consumers in their 20s reported losing money to fraud more often than those over 70. Among 20-somethings who reported fraud, 40% said they lost money. Compare that with the over-70 crowd, only 18% of whom reported a financial loss. But there’s a troubling aspect to that surprising factoid. When older adults did report losing money to a scammer, the loss was much greater. For example, people 80 and older reported median losses of $1,092 compared to $400 for those in their 20s. Wire transfers continue to be scammers’ preferred payment method and in 70% of the complaints we received, the fraudster contacted the consumer by phone. The top states for reporting fraud were Florida, Georgia and Nevada, while Michigan, Florida and California had the most reports about identity theft, per capita. Stats cats tell us that they find our state-by-state data dive helpful, so we’ve created a new webpage to make it easier to evaluate the information. The bottom line for business people: Educate.   Use your status in the community to spread the word to employees, industry colleagues, and friends about the latest forms of fraud. One way to stay in the know: Sign up for scam alerts from the FTC. Cooperate.  If people you know suspect that their identity has been compromised, send them to identitytheft.gov to create a personal recovery plan. (And remember that your company may have a legal obligation to provide identity theft victims and law enforcers with transaction records related to ID theft.) Report.   When you spot a scam, report it to the FTC . We’re talking about fraud directed to consumers and questionable promotions targeting small businesses. Your reports have helped the FTC and other law enforcement agencies put together cases against the con artists behind bogus business directories, office supply flimflams, and other forms of B2B fraud. Consumer Sentinel is an online database available to civil","source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2018/03/ftc-recaps-consumer-complaint-data-2017-whos-list"},{"url":"https://www.ftc.gov/business-guidance/blog/2019/09/ftc-asks-do-consumers-notice-class-action-notices","source":"FTC USA Business Blog Posts","description":"FTC asks “Do consumers notice class action notices?” lfair September 9, 2019 | 11:17AM FTC asks “Do consumers notice class action notices?” By Lesley Fair Do consumers notice consumer class action notices? That’s one of the topics that experts will discuss at an upcoming FTC workshop on issues related to communicating with consumers about class actions . Set for October 29, 2019, in Washington, DC, Consumers and Class Action Notices: An FTC Workshop will feature panelists from a wide range of perspectives exploring what the research suggests about notice methods, claims rates, and redress – and what can be done to improve consumer participation in class action settlements. To enhance our understanding of the issues, FTC staff just released a report summarizing the findings of two studies involving consumer class actions. In the first study, we looked at a sample of more than 140 cases and analyzed how variables like notice methods and compensation amounts affected consumer claims and check-cashing rates. A second staff study explored consumer perceptions of class action notices, including whether people understood their options. Consumer class actions have been an issue of long-standing interest to the FTC. For more than a decade, the agency’s Class Action Fairness Project has worked to ensure that settlements in consumer protection and competition matters provide appropriate benefits to consumers. To that end, the FTC has coordinated with state, federal, and private groups to gather information; looked at the impact of legislative and class action rule changes; and – where appropriate – filed amicus briefs. Free and open to the public, Consumers and Class Action Notices will take place at the FTC’s Constitution Center conference facility, 400 7th Street, S.W., in Washington. We’ll post the agenda soon, but in the meantime, we welcome your comments , including additional consumer perception evidence. We’ll keep the record open until November 22, 2019. Can’t make it to DC on October 29th? The event will be webcast.","pubDate":"Tue, 06 Oct 2026 08:06:23 +0200","id":3199071,"titre":"FTC asks “Do consumers notice class action notices?”"},{"description":"First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim lfair August 6, 2018 | 11:11AM First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim By Lesley Fair T he marketers behind a purported money-making promotion called Sellers Playbook appear to have skipped the chapter about complying with federal and state consumer protection laws. That’s the allegation in a complaint filed by the FTC and the Minnesota Attorney General . In addition, it’s the FTC’s first case charg ing violations of the Consumer Review Fairness Act. The roots of the allegations go back to another venture sued by the FTC earlier this year: FBA Stores, also known as Amazing Wealth System and Amazon Wealth Systems. The defendants in that case ran online ads and in-person workshops that claimed to reveal the secret s of making major money on Amazon. But few, if any, of the consumers who forked over thousands of dollars and implemented their “plug-and-play systems” earn ed the kind of cash the defendants claimed. Which brings us to Sellers Playbook, Exposure Marketing, Jessie Conners Tieva, and Matthew Tieva – Minnesota-based defendants charged with pitching the same kind of “secrets” to making big bucks on Amazon . According to the just-filed lawsuit , the striking similarities should come as no surprise. That ’s because defendant Jessie Tieva was a regular speaker at Amazing Wealth Systems’ workshops. How successful was she in getting consumers to sign up? The complaint charges that Ms. Tieva and her team generated more than $3.4 million in sales for Amazing Wealth Systems. And let’s be clear: We’re not talking about $3.4 million in sales by consumers who successfully implemented the system. We mean $3.4 million that consumers shelled out to the operators of Amazing Wealth Systems for which Tieva was paid a handsome commission. The complaint alleges that the new Sellers Playbook venture is, in effect, a copycat of the now-defunct Amazing Wealth Systems operation. The earning claims certainly have a familiar ring to them. Here’s how Sellers Playbook touted their “opportunity”: “Holy cow, guys. That’s when you start seeing the returns of what we want you to have, $20,000 a month,” “Potential Net Profit: $1,287,463.38,” “Starting with $1000...1 year later over $210,000,” and “How many of you would like to learn how to turn a $5- to $10,000 investment into a $25- to a $1.2 million return with your investment? Yeah. And you’re going to learn those strategies before you leave here today. There are a few other things Amazon Wealth Systems and Sellers Playbook have in common: 1) Neither company has any affiliation with Amazon; and 2) Both companies charged consumers hundreds of dollars – or even hefty five-figure fees – to sign up. Of course, few consumers make the kind of earnings the defendants claimed. According to the complaint, many of the webpages promoting Sellers Playbook contained an inconspicuous earnings disclaimer in grey near the bottom of the page. What’s more, at a live event, the defendants briefly displayed this slide, which one of the presenters downplayed with this statement: “That’s why they have us do this again. It makes the lawyers happy, disclaimers. But you got to do your part. Money’s not going to fall from the sky. But as long as you do a part, it’s going to happen.” T he complaint challenges the defendants’ earning claims as false or unsubstantiated under FTC law and the Minnesota Prevention of Consumer Fraud Act. What’s more, the lawsuit alleges multiple violations of the FTC’s Business Opportunity Rule . The FTC and the AG also charge that provisions in the defendants’ form contracts try to restrict consumers’ ability to post reviews of their products, services, or conduct , in violation of the Consumer Review Fairness","titre":"First Consumer Review Fairness case takes on promoter’s “big bucks on Amazon” claim","pubDate":"Tue, 06 Oct 2026 08:06:23 +0200","id":3199075,"source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2018/08/first-consumer-review-fairness-case-takes-promoters-big-bucks-amazon-claim"},{"description":"First INFORM Consumers Act enforcement case filed against online marketplace Temu kkrown September 5, 2025 | 10:00AM First INFORM Consumers Act enforcement case filed against online marketplace Temu Online marketplaces and third party sellers looking for a refresher on the INFORM Consumers Act should look no further than the recent settlement with Whaleco, Inc., which operates the online marketplace Temu. The complaint alleges the company failed to provide online shoppers with required information and tools. This is the first case brought to enforce the INFORM Act. The INFORM Act, which went into effect in 2023, seeks to make online transactions more transparent. Among other things, the law requires online marketplaces to collect, verify, and disclose certain information about high-volume third party sellers. ( Informing Businesses about the INFORM Consumers Act  has more on how the law defines terms, what’s required of online marketplaces, and the substantial penalties the FTC and state law enforcers may seek if online marketplaces violate the law.) In 2022, Temu launched its online marketplace in the United States, where consumers can view product listings on Temu’s homepage, through search results, and in gamified shopping experiences on the platform. According to the complaint, Temu violated the INFORM Act by failing to offer a mechanism for consumers to report suspicious activity — electronically and by phone — on the gamified product listings of many high-volume third party sellers and by failing to offer a telephonic mechanism on non-gamified product listings. The complaint also alleges that Temu did not post required identifying information about sellers on its gamified product listings or mobile site, and that Temu’s disclosures, when made, were difficult to find. According to the settlement, Temu will pay a $2 million civil penalty, provide a telephonic mechanism for consumers to report suspicious activity on listings, and make other required disclosures. Is your business covered by the INFORM Act? Make sure you:  Review the provisions of the INFORM Act thoroughly . Make sure you fully understand — and have measures in place to comply with — each of its requirements. Make required disclosures easy for consumers to notice . Required disclosures should stand out from any surrounding material and use plain language. Minimize or eliminate steps consumers need to take to reach required disclosures. Ensure required disclosures are available across all iterations of your platform . The INFORM Act mandates disclosures on all interfaces with product listings. And as your platforms evolve, regularly assess and update your compliance efforts. If your business sells through online platforms, check out  What Third Party Sellers Need to Know About the INFORM Consumers Act . This covers what sellers are impacted by the INFORM Act, what you can expect online platforms to require of you, and what information platforms must disclose about you to consumers. It also answers some questions you may have about the law. And if you spot a violation of the INFORM Act, r­eport it to the FTC using this  dedicated link","id":3198178,"pubDate":"Mon, 05 Oct 2026 14:07:45 +0200","titre":"First INFORM Consumers Act enforcement case filed against online marketplace Temu","url":"https://www.ftc.gov/business-guidance/blog/2025/09/first-inform-consumers-act-enforcement-case-filed-against-online-marketplace-temu","source":"FTC USA Business Blog Posts"},{"source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2013/10/made-usa-avoiding-yankee-doodle-dont","description":"Made in USA? Avoiding a Yankee Doodle Don't wfg-adm109 October 21, 2013 | 11:17AM Made in USA? Avoiding a Yankee Doodle Don't By Lesley Fair There are lots of nifty phone accessories, bottle holders, tow straps, pet items, and lanyards out there.  So a label that says the product is Made in the USA may help make the decision for some consumers.  When it bears the American flag and says “TRULY MADE IN THE USA,” that just might seal the deal.  But according to an FTC lawsuit , a lot of the “Made in the USA” merchandise touted by Logan, Utah-based E.K. Ekcessories wasn’t really made in the USA – turning the company’s claims from a Yankee Doodle Do to a Yankee Doodle Don't. E.K. Ekcessories sells a variety of outdoor equipment through popular retailers and on its own site.  In addition to the labels, the company touted its products’ U.S. pedigree with statements like “For 28 years E.K. Ekcessories has been producing superior quality made accessories in our 60,000 sq. ft. facility in Logan, Utah,” and “Our source of pride and satisfaction abounds from a true ‘Made in USA’ product.” To say an item is made in the USA, all or virtually all of it has to be U.S.-made.  In other words, all significant parts and processing must be of U.S. origin, and the product should contain no – or negligible – foreign content. That’s the standard explained in the FTC’s 1997 Enforcement Policy Statement on U.S. Origin Claims.  But according to the complaint, in many cases, E.K. Ekcessories made “Made in USA” representations that were flat-out false.  In other instances, the FTC says the company slapped a label on a product without a reasonable basis for making the claim.  Both courses of conduct violate the FTC Act. Under the proposed order, the company can’t say a product is made in the USA unless all or virtually all of it really is made in the United States.  The order also bans other misleading claims about products’ country of origin. Given that other companies are selling the deceptively labeled merchandise, E.K. Ekcessories has to contact all distributors who bought or received products between January 1, 2010 and May 1, 2013, explaining the FTC’s lawsuit.  The retailers will be asked to pull marketing materials that say all E.K. Ekcessories stuff is U.S.-made or that describe a specific list of products as made in the United States, of U.S.-origin, or “Truly Made in the USA.”  For certain lines of products, they’ll get stickers to cover the inaccurate claims. You can file an online comment about the proposed settlement by November 21, 2013. The message for marketers?  First , it’s a good time to brush up on how to comply with Made in USA standards.  The Business Center has a dedicated Made in USA page to make that easier for you.  Second , given just how important many consumers take a Made in USA claim, companies that make that statement falsely or without a reasonable basis are risking law enforcement action.  Truly.","titre":"Made in USA? Avoiding a Yankee Doodle Don't","id":3196242,"pubDate":"Sun, 04 Oct 2026 08:05:12 +0200"},{"description":"Judge orders $13.4 million in contempt action challenging BlueHippo hype lfair May 2, 2016 | 10:52AM Judge orders $13.4 million in contempt action challenging BlueHippo hype By Lesley Fair Animation fans remember the ballet-dancing pink hippos in Fantasia . In Egyptian mythology, the god of disorder was depicted as a red hippo. And many consumers – especially those already in financial distress – were drawn in by national TV and radio ads for BlueHippo, a company that claimed to finance the purchase of computers and other electronics for people with “less than perfect credit, bad credit, no credit.” A $13.4 million ruling by a United States District Judge in an FTC contempt action sends a message to hippos of all hues (and businesses) about the FTC’s commitment to effective order enforcement. In 2008, the FTC sued BlueHippo Funding and BlueHippo Capital for, among other things, not delivering ordered merchandise, failing to make disclosures required by the Truth in Lending Act and Regulation Z, and illegally conditioning the extension of credit on consumers’ “agreement” to repay by preauthorized electronic debit. One common tactic was that BlueHippo said it would deliver the product once the consumer made 13 weekly payments, but then didn’t make good on that promise. The FTC also alleged that in many instances, BlueHippo debited consumers’ accounts without first disclosing that consumers couldn’t get a refund even if they cancelled before delivery. The defendants settled that case , agreeing to pay up to $5 million in redress and to change how they did business in the future. The FTC went back to court in 2009 , alleging that BlueHippo was flouting the terms of the settlement and continuing to engage in illegal practices. The Court granted the FTC’s contempt motion against the corporate defendants and CEO Joseph Rensin, but entered a remedy of only $609,000. The FTC appealed the financial ruling. Arguing that there should be a presumption that consumers relied on the defendants’ misrepresentations and omissions, the FTC sought a contempt order of $14 million – the gross sales the defendants generated through their illegal conduct. The United States Court of Appeals for the Second Circuit ruled , “We agree with the FTC and join our sister circuits in adopting a presumption of consumer reliance in FTC civil contempt actions.” The appellate court remanded the matter to the trial court to determine “whether the FTC has demonstrated that it is entitled to a presumption of consumer reliance. If so, the court should use defendants’ gross receipts as a baseline for calculating the consumers’ actual loss, and defendants should then be afforded an opportunity to proffer evidence showing that an offset of the baseline is warranted.” What’s the latest development? On remand, the trial court entered a judgment against CEO Rensin for $13.4 million, the financial harm the court determined that consumers suffered as a result of the scheme. The case is another illustration of the FTC’s interest in effective order enforcement. To settle cases and then not follow through to see that defendants live up to their promises would be, well, hippo-critical.","pubDate":"Sat, 03 Oct 2026 14:06:14 +0200","id":3195790,"titre":"Judge orders $13.4 million in contempt action challenging BlueHippo hype","url":"https://www.ftc.gov/business-guidance/blog/2016/05/judge-orders-134-million-contempt-action-challenging-bluehippo-hype","source":"FTC USA Business Blog Posts"},{"titre":"EDPB annual report 2025: supporting stakeholders through guidance and dialogue","pubDate":"Thu, 09 Apr 2026 14:14:02 +0200","id":2816021,"description":"Brussels, 09 April - The European Data Protection Board (EDPB) has published its  2025 Annual Report . The report provides an overview of the EDPB work carried out in 2025 and reflects on important milestones, such as the adoption of the  Helsinki Statement on Enhanced Clarity, Support, and Engagement . “In 2025, we saw the data protection landscape change significantly. The rapid expansion of the EU’s digital regulatory framework has added complexity to the data protection ecosystem. To help organisations navigate this complexity and support compliance, the EDPB focused on enhancing legal certainty, making compliance more achievable in practice, and strengthening cooperation, both among Data Protection Authorities and with other regulators.  We also prioritised meaningful dialogue with stakeholders to ensure our work reflected real-world needs. Our achievements support economic growth while continuing to protect individuals’ fundamental rights to privacy and data protection.” EDPB Chair, Anu Talus   The Helsinki’s statement initiatives leading the way In 2025, the EDPB worked actively to address the demand for regulatory simplification to support innovation and economic growth, while ensuring the protection of individuals’ personal data.  With this in mind, the Board adopted the  Helsinki Statement on Enhanced Clarity, Support, and Engagement , which outlines new initiatives to  make GDPR compliance easier, strengthen consistency, enhance the dialogue and improve transparency with stakeholders and boost cross-regulatory cooperation .   For example, the Board launched a public consultation to ask organisations which templates would be most useful, organised several stakeholder events to consult organisations on upcoming guidelines and systematically published reports on stakeholder input.    Easing compliance for organisations and providing legal advice In the context of ongoing discussions on regulatory simplification at EU level, the EDPB actively contributed to legislative initiatives aimed at reducing administrative burden and streamlining requirements. The Board adopted a  joint opinion with the European Data Protection Supervisor (EDPS) on the Commission’s Proposal for a Regulation amending certain regulations, including the GDPR.  In addition, the Board held important discussions on this matter during plenary meetings, which subsequently informed the  EPDB/EDPS joint opinions on the Commission’s proposals on the  Digital Omnibus and on the  Digital Omnibus on AI adopted at the beginning of 2026. The Board also delivered five adequacy-related opinions concerning United Kingdom, Brazil and the European Patent Organisation (EPO).  In addition, the Board adopted  Recommendations on the legal basis for requiring the creation of user accounts on e-commerce websites , and  Recommendations on the 2027 WADA World Anti-Doping Code  upon request from the Commission.   Strengthening cross-regulatory cooperation Cross-regulatory cooperation was a key focus for the EDPB last year. The EDPB worked together with the European Commission to clarify how data protection and digital laws interact and to address legal and practical challenges in cross-sectoral cases. In 2025, the EDPB adopted its first set of  joint guidelines with the Commission on the interplay between the Digital Markets Act (DMA) and the GDPR . The Board also worked with the Commission on joint guidelines on the interplay between the AI act and EU data protection laws for adoption in 2026.  In addition, the EDPB adopted  guidelines on the interplay between the Digital Services Act (DSA) and the GDPR .   Placing stakeholders at the heart of the EDPB work In 2025, a public consultation was launched on the  joint guidelines with the Commission on the DMA and the GDPR . The Board has also organised public consultations on the EDPB guidelines on  DSA and GDPR","source":"EDPB News","url":"https://www.edpb.europa.eu/news/news/2026/edpb-annual-report-2025-supporting-stakeholders-through-guidance-and-dialogue_en"},{"source":"EDPB News","url":"https://www.edpb.europa.eu/news/news/2026/edpb-conference-cross-regulatory-cooperation-what-we-learned_en","description":"Brussels, 23 March - On 17 March 2026, the EDPB conference “Cross-regulatory interplay and cooperation in the EU: a data protection perspective” took place in Brussels. The event showcased high-level discussions, featuring contributions from representatives of key EU institutions, European Data Protection Authorities, academia and industry.  Key takeaways from the panel discussions Throughout the day, three panels were held, focusing on 1) data protection and competition , 2) the Digital Markets Act (DMA) and the GDPR , and 3) the Digital Services Act (DSA) and the GDPR .  During the first panel , speakers emphasised the critical need for cooperation between regulatory bodies in the fields of data protection and competition and shared views on what regulators in the two fields can learn from each other, especially in the aftermath of the Bundeskartellamt ruling. A speaker emphasized that regulators should align their approaches and recognize synergies between the two fields, such as protecting consumers and data subjects. Others pointed out that fixing harm to end users does not always solve competition issues, and that data protection should be considered in competition analysis only when relevant, on a case-by-case basis. Panellists also highlighted the need to cooperate not just on individual cases, but on broader concepts and legal principles.  In this context, the EDPB has recently agreed to develop joint guidelines with the European Commission to address the interplay between competition law and data protection. The discussions in the second panel centred on the joint guidelines on the DMA and the GDPR , which were developed by the European Commission and the EDPB and recently underwent public consultation. The joint guidelines are an unprecedented work and a good example of regulatory cooperation paving the way for further examples ahead, in line with the  EDPB Strategy 2024-2027 and  Helsinki Statement ’s objectives to strengthen cross-regulatory cooperation. A crucial goal of the guidelines is the development of a coherent and compatible interpretation of the DMA and the GDPR while respecting the regulatory competences. It was emphasised that these guidelines help break silos, strengthen consistency, and provide further clarity and legal certainty. All of this contributes to easier compliance, which is valued by stakeholders and increases trust. At the same time, certain speakers suggested improvements to the final version of the guidelines, bearing in mind the DMA should not be given primacy over the GDPR and that the measures companies have to comply with should be proportionate.  Other examples of cooperation in this domain were also mentioned, such as the participation in the High Level Group for the Digital Markets Act and specific instances of cooperation on concrete cases.  The last panel of the day explored how the Digital Services Act (DSA) and the GDPR interact. Panellists provided the example of the protection of minors: age   verification should be effective yet fully in line with data protection legislation.  They highlighted the growing need for strong coordination between the two frameworks, including the role of the European Board for Digital Services and other ways for the Commission and the EDPB to work together. A speaker also underlined the challenges and ongoing work on cross-regulatory cooperation from the perspective of a national authority. Another speaker urged regulators to work on building a fully coherent interpretation of the two frameworks and more globally of the digital legislation. Panellists also stressed that emerging technologies such as artificial intelligence are reshaping online ecosystems and, as a result, the role of the DSA and the GDPR.  The panel concluded with a clear message: online safety under the DSA and the lawful processing of personal data are two sides of the same coin, both calling for the DSA and the GDPR to be read coherently.  Highlights from the keynote speeches The event also","titre":"EDPB conference on cross-regulatory cooperation: what we learned","pubDate":"Tue, 24 Mar 2026 14:08:47 +0100","id":2780286},{"source":"Federal Trade Commission Concurrence communiqués","url":"https://www.ftc.gov/news-events/news/press-releases/2025/09/federal-trade-commission-chairman-andrew-n-ferguson-appoints-emma-mittelstaedt-burnham-associate","description":"Federal Trade Commission Chairman Andrew N. Ferguson has appointed Emma Mittelstaedt Burnham as Associate Director for Healthcare in the Bureau of Competition. “I am delighted to appoint Emma as Associate Director for Healthcare in the Bureau of Competition. She is a talented attorney with many years of experience at the Department of Justice as a senior antitrust enforcer,” said FTC Chairman Andrew N. Ferguson. “Emma will be an invaluable champion in the FTC’s ongoing fight to protect Americans’ access to affordable, high-quality healthcare.” Emma has significant experience leading the investigation and prosecution of complex antitrust conduct cases, having spent 11 years as a prosecutor at the U.S. Department of Justice Antitrust Division. Most recently, she served as the Director of Criminal Enforcement, supervising the Antitrust Division’s price-fixing matters throughout the United States. She previously held the positions of Trial Attorney, Counsel to the Assistant Attorney General, Assistant Chief, and Acting Chief. Her prior work as a senior DOJ antitrust official included prosecuting antitrust violations in the healthcare sector. She led the Antitrust Division’s investigation into antitrust cartels in the generic pharmaceutical industry, which resulted in significant corporate prosecutions including the largest criminal penalties ever imposed for domestic cartel offenses and the first use of divestiture in a criminal settlement. Before joining the DOJ Antitrust Division, Emma was a criminal defense associate at law firms in Washington, DC, and Los Angeles. She graduated with honors from the University of Chicago Law School and Georgetown University and clerked for the Honorable Robert W. Gettleman in the Northern District of","titre":"Federal Trade Commission Chairman Andrew N. Ferguson Appoints Emma Mittelstaedt Burnham as Associate Director for Healthcare","pubDate":"Wed, 10 Sep 2025 09:48:50 +0200","id":2362099}]