As part of the Trump Administration’s Revolutionary FAR Overhaul[1] (“RFO”), the FAR Council has released a model deviation for FAR Part 33 – Protests, Disputes, and Appeals, which includes changes that seem intended to make agency-level protests more appealing to disappointed offerors. It remains to be seen whether these proposed changes will have the
2025
Italy Adopts Artificial Intelligence Law
On September 23, 2025, the Italian law on artificial intelligence (hereinafter, “Italian AI Law”) was signed into law, after receiving final approval by the Italian Senate on September 17, 2025.
The law consists of varied provisions, including general principles and targeted sectoral rules in certain areas not covered by the EU AI Act. The Italian…
Congressional Ethics Investigations: An Overview of Processes, Challenges, and Implications for Private Actors
Following a string of high-profile investigations targeting Members of Congress on both sides of the aisle, congressional ethics investigations are more visible than ever. Indeed, as we recently explored, the House Ethics Committee in particular may be moving toward a more active and transparent enforcement posture, with its most recent actions potentially signaling…
Cybersecurity Information Sharing Act of 2015 Allowed to Sunset
The Cybersecurity Information Sharing Act of 2015 (“CISA 2015”), which provided protections for sharing cybersecurity threat information with the federal government and others, officially sunset on September 30, 2025 pursuant to the law’s original sunset date after efforts to re-authorize it did not succeed. The law created a cybersecurity information sharing framework and established certain…
Post-Cantero, First Circuit Sets Demanding National Bank Act Preemption Test
Lenders often require borrowers to keep money in a mortgage escrow account, and those funds are used to pay taxes, mortgage insurance, and other costs throughout the year. At least 12 states require lenders to pay the borrower interest on the money held in these escrow accounts. And for more than a decade, certain national…
District Court Requires Specific Testing Allegations in Dismissing PFAS Class Action
A court in the Southern District of New York recently dismissed a proposed class action alleging that consumers paid a premium for juice products advertised as “made simply” with “all natural ingredients,” reasoning that the plaintiff lacked standing in light of flaws in his testing allegations. See Lurenz v. Coca-Cola Co., 2025 WL 2773188 (S.D.N.Y.…
Federal Court Fries Data Breach Class Action for Lack of Standing
A federal court in North Carolina dismissed a putative data breach class action against Bojangles because the plaintiffs failed to show that there was an actual or imminent misuse of their personal information as a result of the breach. Dougherty v. Bojangles’ Restaurants, Inc., 2025 WL 2810673 (W.D.N.C. Sept. 30, 2025).…
Flo Health, Google Settle Class Action Privacy Lawsuit for $56 Million
In late September, plaintiffs announced details regarding Google LLC’s (“Google”) and women’s health app developer, Flo Health Inc.’s (“Flo”) proposed settlements to resolve a class action lawsuit stemming from the Flo app’s allegedly unlawful sharing of health data with Google and others through online tracking technologies.
As part of the proposed settlements, Google agreed to…
California Governor Signs Landmark AI Safety Legislation
On September 29, California Governor Gavin Newsom (D) signed into law SB 53, the Transparency in Frontier Artificial Intelligence Act (“TFAIA”), establishing public safety regulations for developers of “frontier models,” or large foundation AI models trained using massive amounts of computing power. TFAIA is the first frontier model safety legislation in the country to…
FDA Requests Public Comment on Real-World Evaluation of AI-Enabled Medical Devices
On September 30, 2025, the U.S. Food and Drug Administration (FDA) issued a Request for Public Comment seeking input on “practical approaches to measuring and evaluating the performance of AI-enabled medical devices in the real-world,” including strategies for detecting, assessing, and mitigating performance changes over time (the “Request”).
The Request acknowledges the opportunities for AI,…