On January 6, 2026, the Federal Communications Commission’s Public Safety and Homeland Security Bureau (the “Bureau”) announced the application window for a new Lead Administrator for the U.S. Cyber Trust Mark Program (the “Program”). The window will be open from January 7, 2026, through January 28, 2026. The previous Lead Administrator, UL LLC (“UL
Continue Reading FCC Opens Application Window for New Cyber Trust Mark Program Lead Administrator
U.S. Tech Legislative & Regulatory Update – 2025 Mid-Year Update
This update highlights key mid-year legislative and regulatory developments and builds on our first quarter update related to artificial intelligence (“AI”), connected and automated vehicles (“CAVs”), Internet of Things (“IoT”), and cryptocurrencies and blockchain developments.
I. Federal AI Legislative Developments
In the first session of the 119th Congress, lawmakers rejected a proposed moratorium on state and local enforcement of AI laws and advanced several AI legislative proposals focused on deepfake-related harms. Specifically, on July 1, after weeks of negotiations, the Senate voted 99-1 to strike a proposed 10-year moratorium on state and local enforcement of AI laws from the budget reconciliation package, the One Big Beautiful Bill Act (H.R. 1), which President Trump signed into law. The vote to strike the moratorium follows the collapse of an agreement on revised language that would have shortened the moratorium to 5 years and allowed states to enforce “generally applicable laws,” including child online safety, digital replica, and CSAM laws, that do not have an “undue or disproportionate effect” on AI. Congress could technically still consider the moratorium during this session, but the chances of that happening are low based on both the political atmosphere and the lack of a must-pass legislative vehicle in which it could be included. See our blog post on this topic for more information.
Additionally, lawmakers continue to focus legislation on deepfakes and intimate imagery. For example, on May 19, President Trump signed the Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks (“TAKE IT DOWN”) Act (H.R. 633 / S. 146) into law, which requires online platforms to establish a notice and takedown process for nonconsensual intimate visual depictions, including certain depictions created using AI. See our blog post on this topic for more information. Meanwhile, members of Congress continued to pursue additional legislation to address deepfake-related harms, such as the STOP CSAM Act of 2025 (S. 1829 / H.R. 3921) and the Disrupt Explicit Forged Images And Non-Consensual Edits (“DEFIANCE”) Act (H.R. 3562 / S. 1837).Continue Reading U.S. Tech Legislative & Regulatory Update – 2025 Mid-Year Update
FCC Seeks Public Input on Adding Connected Vehicle Technology to the Covered List
On Friday, May 23, the Federal Communications Commission (the “FCC”) released a Public Notice requesting public input on whether certain CAV-related communications equipment and services with connections to Russia and the People’s Republic of China should be added to the “Covered List” – a list maintained by the FCC of communications equipment and services found
Continue Reading FCC Seeks Public Input on Adding Connected Vehicle Technology to the Covered ListU.S. Tech Legislative & Regulatory Update – First Quarter 2025
This quarterly update highlights key legislative, regulatory, and litigation developments in the first quarter of 2025 related to artificial intelligence (“AI”), connected and automated vehicles (“CAVs”), and cryptocurrencies and blockchain.
I. Artificial Intelligence
A. Federal Legislative Developments
In the first quarter, members of Congress introduced several AI bills addressing national security, including bills that would encourage the use of AI for border security and drug enforcement purposes. Other AI legislative proposes focused on workforce skills, international investment in critical industries, U.S. AI supply chain resilience, and AI-enabled fraud. Notably, members of Congress from both parties advanced legislation to regulate AI deepfakes and codify the National AI Research Resource, as discussed below.
- Deepfake Regulation: In February, the Senate passed the Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks (“TAKE IT DOWN”) Act (S. 146), following its unanimous passage by the Senate in 2024. The Act would prohibit the nonconsensual disclosure of AI-generated intimate imagery and require platforms to remove such content published on the platform. The House version of the TAKE IT DOWN Act (H.R. 633) has been referred to the House Energy & Commerce Committee.
- CREATE AI Act: In March, Reps. Jay Obernolte (R-CA) and Don Beyer (D-VA) re-introduced the Creating Resources for Every American To Experiment with Artificial Intelligence (“CREATE AI”) Act (H.R. 2385), following its introduction and near passage in the Senate last year. The CREATE AI Act would codify the National AI Research Resource (“NAIRR”), with the goal of advancing AI development and innovation by offering AI computational resources, common datasets and repositories, educational tools and services, and AI testbeds to individuals, private entities, and federal agencies. The CREATE AI Act builds on the work of the NAIRR Task Force, established by the National AI Initiative Act of 2020, which issued a final report in January 2023 recommending the establishment of NAIRR.
Continue Reading U.S. Tech Legislative & Regulatory Update – First Quarter 2025
Senate Commerce Committee Questions Trump Tech Nominees
On March 12, the U.S. Senate Committee on Commerce, Science, and Transportation advanced two nominations key to the Trump Administration’s technology policy: Mark Meador as a Commissioner for the Federal Trade Commission (“FTC”), and Michael Kratsios as Director of the White House Office of Science and Technology Policy (“OSTP”). Both nominees previously had their nomination hearings in front of the Committee on February 25, described below.
Mark Meador
Meador started his career in the healthcare division of the FTC. In his opening statement, he discussed the importance of the FTC in protecting consumers and free market competition. He specifically referenced the need to protect children in the digital environment and stated that the FTC should use its consumer protection powers to safeguard families.
During the nomination hearing, Meador faced questions about consumer protection enforcement mechanisms, “Big Tech” regulation, pharmacracy benefit managers (“PBMs”), antitrust concerns, and the agency’s direction under the new administration.Continue Reading Senate Commerce Committee Questions Trump Tech Nominees
FCC Takes Next Steps Towards U.S. Cyber Trust Mark
Updated December 12, 2024. Originally Posted December 10, 2024.
On December 4, 2024, the Federal Communications Commission (the “Commission”) announced that it had selected UL Solutions to serve as the Lead Administrator for its Internet of Things Cybersecurity Labeling Program (the “IoT Labeling Program”). The Commission also conditionally approved UL Solutions as a Cybersecurity
Continue Reading FCC Takes Next Steps Towards U.S. Cyber Trust MarkFCC Issues Filing Guidelines for Supplemental Coverage from Space (SCS) Applications; Authorizes SpaceX and T-Mobile to Premiere SCS Deployment
On December 5, 2024, the Federal Communications Commission (FCC) announced that its filing requirements were now in place for parties seeking to deploy Supplemental Coverage from Space, finalizing a new regulatory regime that enables satellite operators to work with wireless provider partners to provide ubiquitous coverage to hard-to-reach users. This step establishes the administrative requirements for FCC approval of SCS deployments and follows on the heels of a November 26th authorization of the first-ever SCS partnership, a collaboration between SpaceX and T-Mobile.Continue Reading FCC Issues Filing Guidelines for Supplemental Coverage from Space (SCS) Applications; Authorizes SpaceX and T-Mobile to Premiere SCS Deployment
FCC Adopts Rules Facilitating the Transition to C-V2X Technology for the Connected Vehicle Ecosystem
On November 20, 2024, the Federal Communications Commission (the “Commission”) issued a Second Report and Order in which it adopted rules (“the Order”) to facilitate the transition to from Dedicated Short Range Communications (“DSRC”) technology to Cellular-Vehicle-to-Everything (“C-V2X”) technology for the Intelligent Transportation System (“ITS” also referred to as the “connected vehicle ecosystem”). Notably, the Order was adopted by a unanimous, bipartisan vote. In a press release, the Commission said that the Order will “accelerate the automotive industry and federal government plans for transitioning from dated technology to the more advanced C-V2X automobile safety technology.”
The Order follows a 2020 Order in which the Commission retained the upper 30 megahertz of the 5.9 GHz band for ITS operations and required the ITS service to transition from DSRC-based technology to C-V2X-based technology. The Order expands on that transition by addressing the transition timeline, communications prioritization, channel bandwidth, communication zones, C-V2X standards, and additional matters.Continue Reading FCC Adopts Rules Facilitating the Transition to C-V2X Technology for the Connected Vehicle Ecosystem
U.S. Tech Legislative, Regulatory & Litigation Update – Third Quarter 2024
This quarterly update highlights key legislative, regulatory, and litigation developments in the third quarter of 2024 related to artificial intelligence (“AI”) and connected and automated vehicles (“CAVs”). As noted below, some of these developments provide industry with the opportunity for participation and comment.
I. Artificial Intelligence
Federal Legislative Developments
There continued to be strong bipartisan
Continue Reading U.S. Tech Legislative, Regulatory & Litigation Update – Third Quarter 2024Pennsylvania Court Finds Promotion Program During Presidential Campaign Not a Lottery
On November 12, 2024, the Court of Common Pleas of Philadelphia County (the “court”) released is decision holding that the promotional effort to award $1 million to persons who indicated their support for the U.S. Constitution did not constitute a lottery under Pennsylvania law. This decision marks a rare instance in which a court has ruled upon whether the key elements of a “lottery” or similar gambling scheme were present in a consumer-facing promotional effort. In this case the court held that the key elements of a lottery (prize, chance, and consideration) were not present.
Background
On October 19, 2024, the founder of America PAC (Mr. Elon Musk) stated at a Pennsylvania rally that he would award $1 million per day for the next two weeks to a registered voter who signed America PAC’s petition pledging support for the U.S. Constitution and the First and Second Amendments. America PAC also announced this promotional program on the website X with a post that stated the PAC “will be randomly awarding one million dollars every day from now until election day, to registered Pennsylvania voters who sign America PAC’s petition, and a surprise member of the audience as the first winner.” This post also included a video that stated the money would be awarded “randomly” to people who signed the petition and agreed to be a spokesperson for the petition. Subsequent posts promoting the program mentioned signing the petition for a chance to win $1 million.Continue Reading Pennsylvania Court Finds Promotion Program During Presidential Campaign Not a Lottery