FTC Joins States in Taking Aim at Personalized Pricing, Corporate Counsel

Partner Joshua Goodman spoke with Corporate Counsel about the US Federal Trade Commission’s (FTC’s) proposed approach to personalized pricing and the growing patchwork of federal and state requirements governing the practice.

Josh said he expects FTC enforcement to focus on situations where consumers are charged higher prices based on personal data, particularly where there is “an element of exploitation of vulnerability.” 

As states adopt varying restrictions and disclosure requirements, Josh noted that the regulatory landscape remains unsettled. “We’ll have to see how it evolves over time, whether states gravitate towards the same standards as the FTC,” he said.

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