With Attorney Generals actively investigating solar companies nationwide, Troutman Pepper has been monitoring and cultivating key activity. To date, there has been one key settlement. In May 2021, the New Jersey Attorney General’s Office announced a settlement with Princeton-based solar company NRG Residential Solar Solutions LLC (NRG) for $69,000 to resolve the state AG’s investigation
Creation of CyTech. On May 9, the National Association of Attorneys General (NAAG) announced the creation of the NAAG Center on Cyber and Technology (CyTech), joining a number of other centers focused upon key issues for state attorneys general and the public, including tobacco and public health, ethics and public integrity, and consumer protection.
Purpose:
On April 18, the Ninth Circuit issued its opinion in hiQ Labs, Inc. v. LinkedIn Corporation[1] in which the court clarified its position on an important topic: whether the common practice of data “web scraping” can create criminal liability under the Computer Fraud and Abuse Act (CFAA). To be clear, the Ninth Circuit was
On February 28, the U.S. Department of Justice (DOJ) agreed to a $930,000 settlement with Comprehensive Health Services (CHS) to resolve False Claims Act allegations. The resolution represents the department’s first settlement under the False Claims Act since instituting its Civil Cyber Fraud Initiative in October 2021.[1] This is a watershed moment in the
Last year we reported that Vermont Attorney General T.J. Donovan’s office settled with several online sellers over alleged violations of the state’s delivery sales ban of electronic nicotine delivery systems (ENDS) (the Delivery Sale Ban) and that we expected Vermont’s scrutiny to continue. As predicted, Attorney General Donovan’s office recently announced two more settlements with
On March 25, the Illinois State Attorney General Kwame Raoul, along with 18 other state attorneys general (state AGs),[1] provided comments to the Consumer Financial Protection Bureau (CFPB) related to the CFPB’s inquiry into companies that offer consumers the opportunity to divide the cost of their purchases into multiple installments, also referred to as
Risk and compliance teams are familiar with potential enforcement from federal regulators. But action from state attorneys general (acting alone or in coalition) can take the unsuspecting business completely by surprise. And in recent years, those actions have grown more frequent, and the penalties more severe.
In this article published in Corporate Compliance Insights,
On February 8, a Northern District of California judge ruled on cross motions for summary judgment filed by the states of California, Illinois, and New York (plaintiffs) and the Office of the Comptroller of the Currency and Michael Hsu in his capacity as acting comptroller of the currency (collectively, the OCC) on the validity of
On February 8, Governor Doug Burgum appointed Drew Wrigley as the new North Dakota attorney general. Wrigley was sworn in on February 9, and will serve out the remainder of the four-year term of North Dakota attorney general Wayne Stenehjem, who unexpectedly passed away on January 28. Wayne Stenehjem was a widely respected attorney general
On January 28, California Attorney General Rob Bonta announced that his office was beginning an “investigative sweep” of businesses operating consumer loyalty programs in California. The California AG’s press release stated that letters were sent to “major corporations in the retail, home improvement, travel, and food service industries” and allege the recipients’ potential noncompliance with