Author: Mark Sanborn, Senior Product and Regulatory Counsel

Consumer Privacy, Enforcement

What Dealers Can Learn from the FTC’s Recent $15.3 Million Website Tracking Technology Enforcement Action 

The FTC announced in December 2025 that Avast would pay more than $15.3 million to be distributed to over 103,000 consumers affected by Avast’s alleged deceptive and unfair practices.

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Enforcement

Twice in One Year: Alaska Regulators Send Dealers a Clear Message on Advertising Compliance

Alaska Attorney General Stephen Cox announced a sweeping settlement with a prominent dealer group resolving allegations that multiple Alaska dealerships charged document fees that were not included in advertised vehicle prices.

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Enforcement

Recent FTC Action Extends a Growing Enforcement Trend – Individual Management Personal Liability

A recent FTC enforcement action against Seek Capital and its CEO, in his individual capacity, sends yet another unmistakable message to companies and executives nationwide: personal liability is becoming an important element of both federal and state consumer protection enforcement.

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Consumer Privacy

Multi-State Privacy Sweep Sends Clear Warning to Dealerships

Regulators in CA, CO, and CT announced a coordinated sweep of businesses that appear to be ignoring opt out preference signals, including GPC signals. For dealerships, this development is a signal that regulators are looking closely at the way businesses’ websites collect and use consumer data, and whether those practices line up with state privacy laws.

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CA CARS Act, Featured

California Enacts the “CARS Act,” Overhauling Vehicle Sales and Leasing Rules

On October 6, 2025, Governor Gavin Newsom signed into law Senate Bill 766 — the California Combating Auto Retail Scams (CARS) Act. Taking effect on October 1, 2026, this legislation represents one of the most comprehensive reshapings of California’s retail automotive sales and leasing practices in decades.

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Enforcement

Personal Liability Is Real: Joint State and Federal Enforcement Action in Connecticut Sends a Clear Warning to Dealers

Federal and state regulators recently brought an enforcement action against a Connecticut dealership and several of its employees that should serve as a cautionary tale for dealerships nationwide.

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