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Articles by Stacey Gray
Defining “Agentic”: Why We Need a Shared Taxonomy for AI Agents
The authors would like to thank Alex Rosenberger and Justine Gluck for their feedback and contributions. This summer, lawmakers in the United States released two of the first legislative proposals for regulating “AI agents”: the federal AI AGENT Act and California SB 1106. The proposals offer significantly different legal definitions of agentic AI, tailored to their different purposes.
How UK's Competition Law Could Impact Netflix's Proposed Acquisition Of Warner Bros Discovery
Square One are most popular: within Government, Public Sector, Strategy and Law Department Performance topic(s) in United Kingdom with readers working within the Business & Consumer Services, Healthcare and Law Firm industries The deal has turned into a tense saga reminiscent of HBO's Succession, as Paramount Skydance lodged a hostile takeover bid and left the acquisition in the balance.
The GBE Scheme And The Evolution Of UK Offshore Wind Subsidies & Funding
Square One are most popular: within Environment, Law Department Performance and Real Estate and Construction topic(s) with readers working within the Business & Consumer Services industries The UK's offshore wind sector continues to play a central role in achieving net zero targets.
Don't Look Back In Anger: Ticketmaster Promises Transparency After CMA Investigation Into Oasis Tour Sales
Stacey Gray’s articles from Square One are most popular: in United Kingdom with readers working within the Business & Consumer Services industries Square One are most popular: within Corporate/Commercial Law, Environment and Real Estate and Construction topic(s) In its press release on 25 September 2025, the CMA announced that it has secured formal commitments (also known as undertakings) from Ticketmaster to improve transparency around ticket pricing and descriptions.
EU's €2.95 Billion Fine On Google Highlights Growing Global Action Against Adtech Dominance
The European Commission has fined Google €2.95 billion for violating EU antitrust rules by distorting competition in the advertising‑technology industry ('adtech') in its decision published on 5 September 2025. Investigators found that Google favoured its own online display advertising technology services, disadvantaging competing adtech providers, advertisers, and online publishers.
Competition Appeal Tribunal Dismisses Second Subsidy Control Act Challenge
The claim concerned loans of £70.8 million to Trinity Developments (Manchester) Limited ("Trinity"), and £69.2 million to New Jackson (Contour) Investments Limited ("Jackson"). The loans were made under the Greater Manchester Housing Investment Loans Fund by GMCA. Trinity and Jackson are special purpose vehicles engaged in developing high-rise residential towers and are both are part of the broader "Renaker Group." Trinity and Jackson are ultimately owned and operated by Mr. Daren Whitaker.
Flight Mode: Bristol Airport Challenges Cardiff Airport Subsidy
On 20 June 2025, Bristol Airport Limited ("Bristol Airport") submitted an appeal under section 70 of the Subsidy Control Act 2022 (the "Act"), challenging the Welsh Government's decision to grant a subsidy package of up to £205.2 million on a phased basis over ten years to Cardiff International Airport Limited ("CIAL").
En Route: A New UK-EU Competition Cooperation Agreement
A new UK-EU competition cooperation agreement is on the horizon. On 29 October 2024, the UK Competition and Markets Authority (CMA) and the European Commission formally concluded the technical negotiations on a new future competition cooperation agreement between the UK and EU following the opening of negotiations in May this year.
Navigating Subsidy Control Principles
DBT has published two new guides outlining the main components of the subsidy control framework. Before deciding to give a subsidy or making a subsidy scheme, public authorities must ensure they are compliant with the Subsidy Control Act 2022 (the Act). Section 12 of the Act states that authorities must consider the subsidy control principles and be of the view that their subsidy or subsidy scheme is consistent with those principles.
Subsidy Control Consultation: Time To Refine!
There is a new consultation on the UK subsidy control regime for businesses to have their say. On 26 November 2024 the UK Department for Business and Trade ('DBT') published details of a new consultation which is now live on the UK subsidy control regime: "Refining the UK subsidy control regime". This latest consultation focuses on refining 2 key areas: Changing the thresholds for the referral of subsidies to the Competition and Markets Authority ('CMA').
No Time To Nap - Consumer Protection Law Issues With Urgency Tactics And Price Reduction Claims
SO Square One More We will protect and help your business as if it were our own. We do this by providing a clear way forward and by giving you an opinion rather than just a list of legal options. People, environment, and community are important to us and by protecting and helping our clients’ businesses to grow we can in turn effect change in the communities in which we live and work.
Growth Mission Is Possible? Reflections On Subsidy Control And Competition Law
Last week, the UK Government published a Green Paper titled "Invest 2035: The UK's Modern Industrial Strategy" which sets out its approach and asks for views and evidence to help develop its new Industrial Strategy which is set to be launched in Spring 2025. The key mission of this Industrial Strategy: the "Growth Mission". Net zero, regional growth, and economic security and resilience are further areas that the UK Government is seeking to support.
The Bipartisan House Privacy Bill Would Surpass State Protections
After decades of negotiations, federal efforts toward a comprehensive data privacy law progressed significantly this week with the House Energy and Commerce Committee approving the American Data Privacy and Protection Act (H.R. 8152) (ADPPA). Although many proposals have been introduced in recent years, the ADPPA represents the first bipartisan, bicameral compromise on a federal privacy law that practitioners and advocates agree is long overdue.
What the Biden Executive Order Means for Data Protection
Stacey Gray Senior Counsel Gabriela Zanfir-Fortuna Director for Global Privacy Last week, President Biden signed an Executive Order on “Promoting Competition in the American Economy” (“the Order” or “the EO”), published together with an explanatory Fact Sheet. The Order outlines a sweeping agenda for a “whole of government” approach to enforcement of antitrust laws in nearly every sector of the economy.
Inside Privacy Law: The Regulation Of Personal Data (Podcast)
United States: Inside Privacy Law: The Regulation Of Personal Data (Podcast) 21 June 2021 by Kirk J. Nahra and Stacey Gray WilmerHale Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Preemption in US Federal Privacy Laws
This post is the first in an ongoing series on federal preemption and enforcement in United States federal privacy legislation. As federal lawmakers consider proposals for a federal baseline privacy law in the United States, one of the most complex challenges is federal preemption, or the extent to which a federal law should nullify the state laws on the books and the emerging laws addressing the collection and use of personal information.
California’s Prop 24, the “California Privacy Rights Act,” Passed. What’s Next?
Authors: Stacey Gray, Senior Counsel, Katelyn Ringrose, Christopher Wolf Diversity Law Fellow at FPF, Polly Sanderson, Policy Counsel, and Veronica Alix, FPF Legal Intern Despite a day of election uncertainty, November 3, 2020 produced an important moment for privacy legislation: California voters approved Proposition 24 (the California Privacy Rights Act) (CPRA) (full text here).
Off to the Races for Enforcement of California’s Privacy Law
Yesterday, the California Attorney General’s office confirmed that it has begun sending a “swath” of enforcement notices to companies across sectors who are allegedly violating the California Consumer Privacy Act (CCPA), swiftly beginning enforcement right on the July 1st enforcement date. The law came into effect in January, after years of debate and amendment in the California Legislature.
Future of Privacy Forum
Infographics July 9, 2020 | Alyssa Benton Strong Data Encryption Protects Everyone: FPF Infographic Details Crypto Benefits for Individuals, Enterprises, and Government Officials Today, the Future of Privacy Forum released a new tool: the interactive visual guide “Strong Data Encryption Protects Everyone.” The infographic illustrates how strong encryption protects individuals,enterprises, and the government.
Endgame Issues: New Brookings Report on Paths to Federal Privacy Legislation
Authors: Stacey Gray, Senior Counsel (US Legislation and Policymaker Education), Polly Sanderson, Policy Counsel This afternoon, The Brookings Institution released a new report, Bridging the gaps: A path forward to federal privacy legislation, a comprehensive analysis of the most challenging obstacles to Congress passing a comprehensive federal privacy law.
Understanding the “World of Geolocation Data”
How is location data generated from mobile devices, who gets access to it, and how? As debates over companies and public health authorities using device data to address the current global pandemic continue, it is more important than ever for policymakers and regulators to understand the practical basics of how mobile operating systems work, how apps request access to information, and how location datasets can be more or less risky or revealing for individuals and groups.
Newly Released COVID-19 Privacy Bills Would Regulate Pandemic-Related Data
By Pollyanna Sanderson (Policy Counsel), Stacey Gray (Senior Policy Counsel) & Katelyn Ringrose (Christopher Wolf Diversity Law Fellow) Yesterday afternoon, leading House and Senate Democrats introduced the Public Health Emergency Privacy Act. The Democratic-led bill, which was introduced by Senators Blumenthal and Warner, as well as Representatives Eshoo, Schakowsky and DelBene, follows the May 10th introduction of a similar COVID-19 data protection bill by leading Senate Republicans.
A Closer Look at Location Data: Privacy and Pandemics
March 25, 2020 | Stacey Gray In this series, Privacy and Pandemics, the Future of Privacy Forum explores the challenges posed by the COVID-19 crisis to existing ethical, privacy, and data protection frameworks, and will seek to provide information and guidance to companies and researchers interested in responsible data sharing to support public health response. Future posts will examine pandemic-tracking mobile apps, regulatory guidance across the world, and more.
It’s Raining Privacy Bills: An Overview of the Washington State Privacy Act and other Introduced Bills
By Pollyanna Sanderson (Policy Counsel), Katelyn Ringrose (Christopher Wolf Diversity Law Fellow) & Stacey Gray (Senior Policy Counsel) Today, on the first day of a rapid-fire 2020 legislative session in the state of Washington, State Senator Carlyle has introduced a new version of the Washington Privacy Act (WPA). Legislators revealed the Act during a live press conference on January 13, 2020 at 2:00pm PST.
Comparing Privacy Laws: GDPR v. CCPA
In November 2018, OneTrust DataGuidance and FPF partnered to publish a guide to the key differences between the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA). Since then, a series of bills, signed by the California Governor on 11 October 2019, amended the CCPA to exempt from its application certain categories of data and to provide different requirements for submission of consumer requests, among other things.
Closer than Apart: Comparing Senate Commerce Committee Bills
December 2, 2019 | FPF Staff Post By: Stacey Gray, Senior Counsel, and Polly Sanderson, Policy Counsel, Future of Privacy Forum Over the Thanksgiving holiday, we saw for the first time a public Staff Discussion Draft of a federal comprehensive privacy law from the office of Senator Wicker (R-MS), the Chairman of the Senate Commerce Committee.
Key Findings From the Latest ‘Right To Be Forgotten’ Cases
September 27, 2019 | Gabriela Zanfir-Fortuna Case C-136/17 GC et al v CNIL – right to be forgotten; lawful grounds for processing of sensitive data Link to judgment: http://curia.europa.eu/juris/document/document.jsf?text=&docid=218106&pageInd ex=0&doclang=EN&mode=req&dir=&occ=first&part=1&cid=335023 Main issue: Four erasure requests not linked to each other and all having to do with de-linking news articles from Google search results pages, some of which contained sensitive data, were...
COPYRIGHTS AND PRIVACY: What is the Irrevocable License and is it Really a Privacy Concern?
“By submitting a Posting, you hereby authorize [us] to use, and authorize others to use, your Postings and User Names in whole or in part, on a royalty-free basis, throughout the universe in perpetuity in any and all media, now known or hereafter devised, alone, or together or as part of other material of any kind or nature, including without limitation commercial use on and advertising and promotion of the Site.
New FPF Study Documents More Than 150 European Companies Participating in the EU-US Data Transfer Mechanism
New FPF Study Documents More Than 150 European Companies Participating in the EU-US Data Transfer Mechanism EU Companies’ Participation Grew by One Third Over the Past Year By Jeremy Greenberg Yesterday, the European Commission published its second annual review of the EU-U.S. Privacy Shield, finding that “the U.S. continues to ensure an adequate level of protection for personal data transferred under the Privacy Shield from the EU to participating companies in the U.S.” The decision...
Privacy Best Practices for Consumer Genetic Testing Services
The Future of Privacy Forum, along with leading consumer genetic and personal genomic testing companies 23andMe, Ancestry, Helix, MyHeritage, and Habit, released Privacy Best Practices for Consumer Genetic Testing Services. These companies have been joined by African Ancestry, FamilyTreeDNA,* and Living DNA in supporting the Best Practices as a clear articulation of how leading firms can build trust with consumers.
iOS 10 to Feature Stronger "Limit Ad Tracking" Control - Future of Privacy Forum
The release of iOS 10, the newest version of Apple’s mobile operating system (coming this Fall), will bring an array of new features and upgrades, and a change to the functionality of the “Limit Ad Tracking” privacy setting. The iPhone operating system allows app developers to target advertisements to app users by using a unique ID number called “Identifier for Advertising” (IDFA or IFA).
Always on: Privacy implications of microphone-enabled devices
Is your smart TV listening to your conversations? Are your children’s toys spying on your family? These questions are being raised as the next generation of Internet-connected devices enters the market. Such devices, often dubbed “always on,” include televisions, cars, toys and home personal assistants, many of which now include microphones and speech-recognition capabilities. Voice is an increasingly useful interface to engage with our devices.
What Privacy Papers Should Policymakers be Reading in 2016?
Each year, FPF invites privacy scholars and authors to submit articles and papers to be considered by members of our Advisory Board, with an aim toward showcasing those articles that should inform any conversation about privacy among policymakers in Congress, as well as at the Federal Trade Commission and in other government agencies. For our sixth annual Privacy Papers for Policymakers, we received submissions on topics ranging from mobile app privacy, to location tracking, to drone policy.
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