Cicero Intelligent Minds

DROPLETS

AmLaw 100 Legal Intelligence — Distilled
Friday, August 14, 202614 featured11 also noted8 firms11 practice areasgrade 3–5
Quick Scan — Why It Matters
Paul HastingsCorporate / M&A+ Expand
UK Supreme Court Rules Director Good Faith Duty Extends to Conduct, Not Just Mindset

UK company directors and in-house counsel advising corporate boards must revise governance protocols, as the UK Supreme Court has held that the statutory director good faith duty covers actual conduct, not just internal thought process, creating personal liability for covert or disloyal actions even if directors genuinely believed those actions benefited the company.

The UK Supreme Court unanimously ruled in Saxon Woods Investments Ltd v Costa [2026] UKSC 21 that the section 172(1) Companies Act 2006 requirement for directors to act in good faith applies to both internal decision-making and external conduct, overturning the lower court’s finding that a director’s genuine belief they were acting in the company’s best interests was sufficient to avoid liability. The court held that covert, deceptive, or disloyal conduct by a director, even if motivated by a belief it would benefit the company, breaches the statutory good faith duty. In-house counsel should work with boards to clarify delegated authority limits, implement mandatory board reporting for high-stakes decisions, require collective approval for deviations from agreed strategies, and provide regular director training on statutory fiduciary duties to mitigate personal liability risk.

Read the full dispatch →
Troutman Pepper LockeInternational Trade / Tariffs+ Expand
IEEPA Tariff Refunds: Litigating Strategy After Supreme Court Loss

Importers who paid IEEPA tariffs must decide whether to sue in the Court of International Trade or pursue administrative refunds before the 180-day deadline lapses.

The Supreme Court's decision in Learning Resources v. Trump invalidated tariffs imposed under IEEPA, opening the door for importers to recover duties already paid. Two procedural paths exist: filing suit in the Court of International Trade under 28 U.S.C. § 1581(i), or seeking administrative reliquidation through CBP. Each carries distinct risks—litigation offers broader remedies but requires timely filing, while administrative channels may be faster but offer narrower relief. Importers should immediately inventory IEEPA tariff payments, assess statute-of-limitations exposure, and weigh forum selection carefully. Companies that delayed filing protests or suits now face compressed decision windows, and the choice of forum will shape refund scope, interest recovery, and the ability to challenge future tariff actions.

Read the full dispatch →
Arnold & PorterSanctions / Export Controls+ Expand
Supreme Court Holds Helms-Burton Act Abrogates Cuban State Entity Sovereign Immunity

U.S. nationals holding FCSC-certified Cuban confiscated property claims and counsel for Cuban state-owned entities with U.S. exposure must evaluate new litigation risk after the Supreme Court eliminated a core jurisdictional barrier to Title III suits.

On June 23, 2026, the Supreme Court issued a 6-3 ruling in Exxon Mobil Corp. v. Corporación CIMEX, S.A. holding that the Helms-Burton Act’s Title III abrogates foreign sovereign immunity for Cuban state-owned agencies and instrumentalities, eliminating the requirement for plaintiffs to satisfy a separate Foreign Sovereign Immunities Act (FSIA) exception to establish jurisdiction over these entities. The decision overturns lower court precedent that had blocked nearly all Title III suits against Cuban state entities, as the longstanding U.S. embargo on Cuba made it nearly impossible for plaintiffs to meet the FSIA’s commercial or expropriation activity exceptions. U.S. nationals with FCSC-certified Cuban property confiscation claims should evaluate filing or reviving Title III suits, while counsel for Cuban state-owned entities with U.S. exposure should assess litigation risk and defenses, noting post-judgment asset execution remains subject to separate FSIA execution immunity rules.

Read the full dispatch →
Arnold & PorterFDA / Life Sciences Regulatory+ Expand
FDA Proposes Mandatory GRAS Notification for Food Ingredients

Food ingredient manufacturers, food producers, and suppliers of substances used in interstate food commerce must act because the proposed rule would end the decades-long voluntary GRAS notification system, requiring mandatory FDA notification for all self-determined GRAS substances and creating new public disclosure and compliance risks.

On August 11, 2026, FDA published a proposed rule converting the decades-long voluntary GRAS notification program to a mandatory requirement for all substances introduced into interstate commerce under a self-determined GRAS conclusion, covering both food ingredients and food contact substances. Unlike premarket approval, companies may continue marketing GRAS substances while awaiting FDA review of their notification, but filed notices and FDA response letters will be publicly available, increasing exposure to adverse public or regulatory scrutiny. The rule includes exceptions for substances with existing FDA 'no questions' letters, codified GRAS listings, and pre-1958 natural biological substances, plus a time-limited streamlined submission option for already-marketed substances. Comments are due December 9, 2026, and companies should immediately audit their GRAS portfolios to identify substances requiring notification, confirm whether existing FDA clearances cover their specific ingredients and use conditions, and update supplier contracts to clarify GRAS compliance responsibilitie

Read the full dispatch →
Troutman Pepper LockeEnergy / Renewables+ Expand
Appellate Ruling Revives Pending US Offshore Wind Permit Approvals

In-house counsel for U.S. offshore wind developers, utility off-takers, and project financiers must track this ruling, as it reopens the approval pathway for stalled multi-billion dollar projects previously blocked on environmental review grounds.

The U.S. Court of Appeals for the D.C. Circuit issued a ruling in the Atlantic Shores offshore wind case that vacated prior lower-court blocks on final federal permits for the project and other pending U.S. offshore wind developments. The decision reverses earlier findings that federal environmental reviews for the projects violated the National Environmental Policy Act, clearing the way for the Bureau of Ocean Energy Management to issue final construction and operation permits for stalled projects. In-house counsel for affected developers, off-takers, and financiers should review pending permit applications for alignment with the ruling’s reasoning, update project timelines to reflect the revived approval process, and prepare for potential new legal challenges from coastal stakeholder groups.

Read the full dispatch →
Troutman Pepper LockeRegulatory / Government+ Expand
State AGs Boost AI, Privacy, Pricing Enforcement; NJ Implements Surveillance Pricing Ban

In-house counsel at U.S. companies using AI, processing consumer data, or deploying dynamic pricing models face rising compliance risk from intensifying state AG enforcement and New Jersey’s new surveillance pricing ban.

State attorneys general across multiple U.S. jurisdictions have announced stepped-up enforcement initiatives targeting AI development and deployment, consumer data privacy practices, and anti-competitive pricing strategies. New Jersey has recently enacted a ban on surveillance pricing, which prohibits using consumer behavioral data to set individualized prices for goods and services. The 2026 midterm election cycle and key state AG races will shape 2027 enforcement priorities, with potential for expanded regulatory focus across additional states. In-house counsel should audit current AI, data privacy, and pricing practices for compliance with existing state rules and the new New Jersey ban, monitor pending AG enforcement actions in their operating jurisdictions, and update internal compliance programs to address emerging state-level regulatory requirements.

Read the full dispatch →
Lathrop GPMPrivacy / Data Security+ Expand
Courts and States Move to Curb Website Tracking and ADA Suit Abuse

In-house counsel at companies operating consumer-facing websites and apps face a shifting landscape as federal courts, Missouri, and California push back on serial website litigation.

Three converging developments are reshaping exposure under website privacy and accessibility theories. A federal court in the Central District of California has declared serial CIPA plaintiff Vivek Shah a vexatious litigant, requiring pre-approval for further filings after 29 suits since 2021, though coordinated plaintiff firms continue to drive most CIPA docket volume. Missouri's Act Against Abusive Website Access Litigation, effective August 28, 2026, lets defendants and the state AG countersue for 'abusive litigation' and shields good-faith remediation efforts, making documentation of accessibility work critical. California SB 690 would bar private Section 638.51 'trap-and-trace' claims against website and app operators, reserving enforcement to the AG and applying retroactively two years, but plaintiffs are expected to reframe conduct as wiretapping under unaffected CIPA provisions. Companies should audit tracking technologies, preserve accessibility remediation records, and reassess CIPA exposure assumptions.

Read the full dispatch →
Mayer BrownBankruptcy / Restructuring+ Expand
Court of Appeal revives improper-purpose challenge to out-of-court administrator appointment

Lenders and distressed-debt acquirers pursuing loan-to-own strategies face a revived equitable challenge where the sole purpose of enforcement is acquiring the target rather than recovering debt.

The Court of Appeal in Glint Pay Ltd v Baker partially reversed the High Court, holding there is a realistic prospect that an out-of-court administrator appointment under Schedule B1 of the Insolvency Act 1986 was invalid because the chargee's sole subjective purpose was to acquire the company's business, not to recover the debt. The court confirmed that no broad Braganza-style rationality duty constrains a chargee's core enforcement rights, but accepted a narrower implied term that ancillary powers (such as information requests) must be exercised for the security holder's legitimate commercial aims. The decision distinguishes mixed motives (permissible under Cukurova) from a sole improper purpose (potentially fatal). Practitioners structuring loan-to-own or debt-acquisition transactions should document a genuine debt-recovery rationale, anticipate evidentiary scrutiny of timing and sequencing, and expect further guidance when the case proceeds to trial.

Read the full dispatch →
Troutman Pepper LockeEnergy / Renewables+ Expand
ERCOT Pauses Texas Data Center Grid Connections Amid Overloaded 1,800-Project Queue

Companies planning new AI and large data center projects in Texas, plus energy developers with pending ERCOT interconnection requests, face significant build delays as the grid operator pauses new connections to address an overloaded 1,800-project queue.

ERCOT, Texas’s primary grid operator, has paused all new grid connection requests for data centers and other large load projects after its interconnection queue swelled to 1,800 projects totaling 474GW of requested capacity, far exceeding current grid expansion capabilities. The indefinite pause blocks all new data center and large load interconnection requests submitted after the effective date, and will remain in place until ERCOT implements new queue management and grid upgrade rules, a process expected to take months. Affected companies should evaluate alternative power sourcing options, including on-site generation and power purchase agreements with existing interconnected facilities, and track ERCOT rulemaking updates to adjust project timelines.

Read the full dispatch →
Lathrop GPMIP / Patent+ Expand
USPTO Appeals Panel Narrows Allergan OTDP Ruling, Proposes New Framework

In-house patent counsel and IP portfolio managers must adjust continuation prosecution and licensing strategies, as the USPTO's precedential decision preserves broad anti-harassment obviousness-type double patenting rejections and limits the scope of the recent Allergan ruling.

The USPTO's precedential Appeals Review Panel (ARP) decision in Ex Parte Baurin narrows the 2024 Federal Circuit Allergan ruling to its specific date-related facts, meaning most patent applicants cannot use Allergan to avoid obviousness-type double patenting (OTDP) rejections. The ARP also affirmed OTDP rejections may be issued based on an anti-harassment rationale even without a patent term extension, and proposed a new framework limiting OTDP analysis to unjustified patent term extensions, though it lacks authority to implement the framework without Federal Circuit guidance. Applicants should evaluate consolidating commercially valuable claims into single patents where rapid grant is a priority, and monitor pending Federal Circuit appeals including In re Ablynx for further clarity on OTDP doctrine.

Read the full dispatch →
LittlerEmployment / Labor+ Expand
New Jersey finalizes ABC test rules with October 1 compliance deadline

New Jersey employers using independent contractors must reassess classifications before October 1 under finalized ABC test rules that tighten the path to independent status.

The New Jersey Department of Labor and Workforce Development has finalized regulations implementing the state's ABC test for worker classification, with an October 1, 2026 effective date. Under the ABC test, a worker is presumed to be an employee unless the hiring entity can satisfy all three prongs: the worker is free from control, performs work outside the usual course of the business, and is engaged in an independently established trade. The new rules provide additional guidance on each prong and on documentation expectations. Misclassification can trigger back wages, unemployment contributions, penalties, and joint-and-several liability for contractors under state wage payment law. Employers should audit current contractor arrangements, update agreements, and prepare for potential reclassification or restructured engagement models before the deadline.

Read the full dispatch →
Arnold & PorterInternational Trade / Tariffs+ Expand
Consumer Tariff Refund Class Actions Face Steep Causation Hurdles Post-IEEPA Ruling

Consumer-facing manufacturers and retailers named in post-IEEPA refund class actions should expect aggressive causation challenges, as plaintiffs struggle to isolate tariff-driven price increases from broader market forces.

Following the U.S. Supreme Court's decision striking down tariffs imposed under the International Emergency Economic Powers Act, billions in refunds are flowing through shippers and retailers, and a wave of consumer class actions has followed seeking to recover amounts consumers paid directly or indirectly. Practitioners note that plaintiffs in these cases face significant evidentiary hurdles: tracing any specific price increase to tariffs alone is difficult given that most companies set prices based on multiple inputs, including labor, materials, freight, and demand. Defendants should leverage this multifactorial pricing reality in motions to dismiss and class certification challenges, focusing on the absence of common, tariff-specific injury. Companies should also audit refund pass-through practices and document pricing methodologies now to support defenses and potential indemnification claims against upstream parties receiving IEEPA refunds.

Read the full dispatch →
BakerHostetlerTechnology / AI+ Expand
U.S. vs. E.U. AI Regulation: Cross-Border Business Compliance Guidance

In-house counsel for companies operating across the U.S. and EU must align AI compliance programs with divergent regional regulatory requirements to mitigate enforcement risk and avoid unnecessary operational constraints.

Published in the 2026 Issue 5 of the Computer and Telecommunications Law Review, the article provides a side-by-side analysis of U.S. and EU AI regulatory structures. It explains that U.S. AI rules are anchored in consumer protection principles with fragmented, sector-specific mandates, while the EU’s multi-dimensional framework combines product safety standards, fundamental rights protections, and internal market harmonization requirements. For cross-border businesses operating on both sides of the Atlantic, the analysis recommends selecting a consistent global AI governance baseline, calibrating compliance investment to actual regional risk exposure, and building flexibility into governance structures to adapt to ongoing regulatory evolution in both jurisdictions.

Read the full dispatch →
Jones DayInternational Trade / Tariffs+ Expand
Updated Foreign Direct Investment Compliance Guidance Released for Cross-Border Transactions

In-house counsel overseeing cross-border corporate investments and acquisitions must review updated foreign direct investment regulatory requirements to avoid compliance penalties and deal delays.

A new Jones Day client alert details recent changes to foreign direct investment regulatory requirements across major global jurisdictions. The guidance covers revised transaction screening processes, updated ownership disclosure mandates, and adjusted national security review thresholds for both inbound and outbound cross-border deals. In-house counsel should use the alert to update their organization’s due diligence checklists and post-closing compliance frameworks, mitigating risk of transaction delays, deal blockage, or enforcement penalties for non-compliance with current rules.

Read the full dispatch →
DIG DEEPER
MOST CONSEQUENTIALFDA Proposes Mandatory GRAS Notification for Food Ingredients

Food ingredient manufacturers, food producers, and suppliers of substances used in interstate food commerce must act because the proposed rule would end the decades-long voluntary GRAS notification system, requiring mandatory FDA notification for all self-determined GRAS substances and creating new public disclosure and compliance risks.

On August 11, 2026, FDA published a proposed rule converting the decades-long voluntary GRAS notification program to a mandatory requirement for all substances introduced into interstate commerce under a self-determined GRAS conclusion, covering both food ingredients and food contact substances. Unlike premarket approval, companies may continue marketing GRAS substances while awaiting FDA review of their notification, but filed notices and FDA response letters will be publicly available, increasing exposure to adverse public or regulatory scrutiny. The rule includes exceptions for substances with existing FDA 'no questions' letters, codified GRAS listings, and pre-1958 natural biological substances, plus a time-limited streamlined submission option for already-marketed substances. Comments are due December 9, 2026, and companies should immediately audit their GRAS portfolios to identify substances requiring notification, confirm whether existing FDA clearances cover their specific ingredients and use conditions, and update supplier contracts to clarify GRAS compliance responsibilitie

Arnold & PorterFDA / Life Sciences Regulatory
fda-grasfood-ingredient-regulationgrans-mandatefood-compliance
AR
Today's Curator
Arthur Rodrigues. Corporate Counsel & Corporate Secretary at Teachable, Inc. Founder of Cicero Intelligent Minds. Former BigLaw (O'Melveny, Weil, Hughes Hubbard). JD/LLM Michigan Law.
Full Analysis — The Details
01 — BANKRUPTCY / RESTRUCTURING1
Mayer Brown+ Expand
Court of Appeal revives improper-purpose challenge to out-of-court administrator appointment

Lenders and distressed-debt acquirers pursuing loan-to-own strategies face a revived equitable challenge where the sole purpose of enforcement is acquiring the target rather than recovering debt.

The Court of Appeal in Glint Pay Ltd v Baker partially reversed the High Court, holding there is a realistic prospect that an out-of-court administrator appointment under Schedule B1 of the Insolvency Act 1986 was invalid because the chargee's sole subjective purpose was to acquire the company's business, not to recover the debt. The court confirmed that no broad Braganza-style rationality duty constrains a chargee's core enforcement rights, but accepted a narrower implied term that ancillary powers (such as information requests) must be exercised for the security holder's legitimate commercial aims. The decision distinguishes mixed motives (permissible under Cukurova) from a sole improper purpose (potentially fatal). Practitioners structuring loan-to-own or debt-acquisition transactions should document a genuine debt-recovery rationale, anticipate evidentiary scrutiny of timing and sequencing, and expect further guidance when the case proceeds to trial.

improper-purposeloan-to-ownadministrator-appointmentschedule-b1chargee-enforcement
Read the full dispatch →
02 — CORPORATE / M&A1
Paul Hastings+ Expand
UK Supreme Court Rules Director Good Faith Duty Extends to Conduct, Not Just Mindset

UK company directors and in-house counsel advising corporate boards must revise governance protocols, as the UK Supreme Court has held that the statutory director good faith duty covers actual conduct, not just internal thought process, creating personal liability for covert or disloyal actions even if directors genuinely believed those actions benefited the company.

The UK Supreme Court unanimously ruled in Saxon Woods Investments Ltd v Costa [2026] UKSC 21 that the section 172(1) Companies Act 2006 requirement for directors to act in good faith applies to both internal decision-making and external conduct, overturning the lower court’s finding that a director’s genuine belief they were acting in the company’s best interests was sufficient to avoid liability. The court held that covert, deceptive, or disloyal conduct by a director, even if motivated by a belief it would benefit the company, breaches the statutory good faith duty. In-house counsel should work with boards to clarify delegated authority limits, implement mandatory board reporting for high-stakes decisions, require collective approval for deviations from agreed strategies, and provide regular director training on statutory fiduciary duties to mitigate personal liability risk.

uk-corporate-lawdirector-dutiesgood-faithcorporate-governancefiduciary-duty
Read the full dispatch →
03 — EMPLOYMENT / LABOR1
Littler+ Expand
New Jersey finalizes ABC test rules with October 1 compliance deadline

New Jersey employers using independent contractors must reassess classifications before October 1 under finalized ABC test rules that tighten the path to independent status.

The New Jersey Department of Labor and Workforce Development has finalized regulations implementing the state's ABC test for worker classification, with an October 1, 2026 effective date. Under the ABC test, a worker is presumed to be an employee unless the hiring entity can satisfy all three prongs: the worker is free from control, performs work outside the usual course of the business, and is engaged in an independently established trade. The new rules provide additional guidance on each prong and on documentation expectations. Misclassification can trigger back wages, unemployment contributions, penalties, and joint-and-several liability for contractors under state wage payment law. Employers should audit current contractor arrangements, update agreements, and prepare for potential reclassification or restructured engagement models before the deadline.

nj-abc-testworker-classificationindependent-contractorwage-and-hourcompliance-deadline
Read the full dispatch →
04 — ENERGY / RENEWABLES2
Troutman Pepper Locke+ Expand
Appellate Ruling Revives Pending US Offshore Wind Permit Approvals

In-house counsel for U.S. offshore wind developers, utility off-takers, and project financiers must track this ruling, as it reopens the approval pathway for stalled multi-billion dollar projects previously blocked on environmental review grounds.

The U.S. Court of Appeals for the D.C. Circuit issued a ruling in the Atlantic Shores offshore wind case that vacated prior lower-court blocks on final federal permits for the project and other pending U.S. offshore wind developments. The decision reverses earlier findings that federal environmental reviews for the projects violated the National Environmental Policy Act, clearing the way for the Bureau of Ocean Energy Management to issue final construction and operation permits for stalled projects. In-house counsel for affected developers, off-takers, and financiers should review pending permit applications for alignment with the ruling’s reasoning, update project timelines to reflect the revived approval process, and prepare for potential new legal challenges from coastal stakeholder groups.

offshore-windfederal-permitsenergy-regulatoryenvironmental-review
Read the full dispatch →
Troutman Pepper Locke+ Expand
ERCOT Pauses Texas Data Center Grid Connections Amid Overloaded 1,800-Project Queue

Companies planning new AI and large data center projects in Texas, plus energy developers with pending ERCOT interconnection requests, face significant build delays as the grid operator pauses new connections to address an overloaded 1,800-project queue.

ERCOT, Texas’s primary grid operator, has paused all new grid connection requests for data centers and other large load projects after its interconnection queue swelled to 1,800 projects totaling 474GW of requested capacity, far exceeding current grid expansion capabilities. The indefinite pause blocks all new data center and large load interconnection requests submitted after the effective date, and will remain in place until ERCOT implements new queue management and grid upgrade rules, a process expected to take months. Affected companies should evaluate alternative power sourcing options, including on-site generation and power purchase agreements with existing interconnected facilities, and track ERCOT rulemaking updates to adjust project timelines.

ercottexas-data-centersai-infrastructuregrid-interconnectionenergy-regulation
Read the full dispatch →
05 — FDA / LIFE SCIENCES REGULATORY1
Arnold & Porter+ Expand
FDA Proposes Mandatory GRAS Notification for Food Ingredients

Food ingredient manufacturers, food producers, and suppliers of substances used in interstate food commerce must act because the proposed rule would end the decades-long voluntary GRAS notification system, requiring mandatory FDA notification for all self-determined GRAS substances and creating new public disclosure and compliance risks.

On August 11, 2026, FDA published a proposed rule converting the decades-long voluntary GRAS notification program to a mandatory requirement for all substances introduced into interstate commerce under a self-determined GRAS conclusion, covering both food ingredients and food contact substances. Unlike premarket approval, companies may continue marketing GRAS substances while awaiting FDA review of their notification, but filed notices and FDA response letters will be publicly available, increasing exposure to adverse public or regulatory scrutiny. The rule includes exceptions for substances with existing FDA 'no questions' letters, codified GRAS listings, and pre-1958 natural biological substances, plus a time-limited streamlined submission option for already-marketed substances. Comments are due December 9, 2026, and companies should immediately audit their GRAS portfolios to identify substances requiring notification, confirm whether existing FDA clearances cover their specific ingredients and use conditions, and update supplier contracts to clarify GRAS compliance responsibilitie

fda-grasfood-ingredient-regulationgrans-mandatefood-compliance
Read the full dispatch →
06 — INTERNATIONAL TRADE / TARIFFS3
Troutman Pepper Locke+ Expand
IEEPA Tariff Refunds: Litigating Strategy After Supreme Court Loss

Importers who paid IEEPA tariffs must decide whether to sue in the Court of International Trade or pursue administrative refunds before the 180-day deadline lapses.

The Supreme Court's decision in Learning Resources v. Trump invalidated tariffs imposed under IEEPA, opening the door for importers to recover duties already paid. Two procedural paths exist: filing suit in the Court of International Trade under 28 U.S.C. § 1581(i), or seeking administrative reliquidation through CBP. Each carries distinct risks—litigation offers broader remedies but requires timely filing, while administrative channels may be faster but offer narrower relief. Importers should immediately inventory IEEPA tariff payments, assess statute-of-limitations exposure, and weigh forum selection carefully. Companies that delayed filing protests or suits now face compressed decision windows, and the choice of forum will shape refund scope, interest recovery, and the ability to challenge future tariff actions.

ieepa-tariffstariff-refundscourt-of-international-tradesupreme-courtimport-compliance
Read the full dispatch →
Arnold & Porter+ Expand
Consumer Tariff Refund Class Actions Face Steep Causation Hurdles Post-IEEPA Ruling

Consumer-facing manufacturers and retailers named in post-IEEPA refund class actions should expect aggressive causation challenges, as plaintiffs struggle to isolate tariff-driven price increases from broader market forces.

Following the U.S. Supreme Court's decision striking down tariffs imposed under the International Emergency Economic Powers Act, billions in refunds are flowing through shippers and retailers, and a wave of consumer class actions has followed seeking to recover amounts consumers paid directly or indirectly. Practitioners note that plaintiffs in these cases face significant evidentiary hurdles: tracing any specific price increase to tariffs alone is difficult given that most companies set prices based on multiple inputs, including labor, materials, freight, and demand. Defendants should leverage this multifactorial pricing reality in motions to dismiss and class certification challenges, focusing on the absence of common, tariff-specific injury. Companies should also audit refund pass-through practices and document pricing methodologies now to support defenses and potential indemnification claims against upstream parties receiving IEEPA refunds.

tariff-refundsieepaconsumer-class-actionscausationpricing
Read the full dispatch →
Jones Day+ Expand
Updated Foreign Direct Investment Compliance Guidance Released for Cross-Border Transactions

In-house counsel overseeing cross-border corporate investments and acquisitions must review updated foreign direct investment regulatory requirements to avoid compliance penalties and deal delays.

A new Jones Day client alert details recent changes to foreign direct investment regulatory requirements across major global jurisdictions. The guidance covers revised transaction screening processes, updated ownership disclosure mandates, and adjusted national security review thresholds for both inbound and outbound cross-border deals. In-house counsel should use the alert to update their organization’s due diligence checklists and post-closing compliance frameworks, mitigating risk of transaction delays, deal blockage, or enforcement penalties for non-compliance with current rules.

foreign-direct-investmentcross-border-complianceinvestment-screeningnational-security-review
Read the full dispatch →
07 — IP / PATENT1
Lathrop GPM+ Expand
USPTO Appeals Panel Narrows Allergan OTDP Ruling, Proposes New Framework

In-house patent counsel and IP portfolio managers must adjust continuation prosecution and licensing strategies, as the USPTO's precedential decision preserves broad anti-harassment obviousness-type double patenting rejections and limits the scope of the recent Allergan ruling.

The USPTO's precedential Appeals Review Panel (ARP) decision in Ex Parte Baurin narrows the 2024 Federal Circuit Allergan ruling to its specific date-related facts, meaning most patent applicants cannot use Allergan to avoid obviousness-type double patenting (OTDP) rejections. The ARP also affirmed OTDP rejections may be issued based on an anti-harassment rationale even without a patent term extension, and proposed a new framework limiting OTDP analysis to unjustified patent term extensions, though it lacks authority to implement the framework without Federal Circuit guidance. Applicants should evaluate consolidating commercially valuable claims into single patents where rapid grant is a priority, and monitor pending Federal Circuit appeals including In re Ablynx for further clarity on OTDP doctrine.

uspto-otdppatent-prosecutionobviousness-type-double-patentingpatent-licensingpatent-portfolio
Read the full dispatch →
08 — PRIVACY / DATA SECURITY1
Lathrop GPM+ Expand
Courts and States Move to Curb Website Tracking and ADA Suit Abuse

In-house counsel at companies operating consumer-facing websites and apps face a shifting landscape as federal courts, Missouri, and California push back on serial website litigation.

Three converging developments are reshaping exposure under website privacy and accessibility theories. A federal court in the Central District of California has declared serial CIPA plaintiff Vivek Shah a vexatious litigant, requiring pre-approval for further filings after 29 suits since 2021, though coordinated plaintiff firms continue to drive most CIPA docket volume. Missouri's Act Against Abusive Website Access Litigation, effective August 28, 2026, lets defendants and the state AG countersue for 'abusive litigation' and shields good-faith remediation efforts, making documentation of accessibility work critical. California SB 690 would bar private Section 638.51 'trap-and-trace' claims against website and app operators, reserving enforcement to the AG and applying retroactively two years, but plaintiffs are expected to reframe conduct as wiretapping under unaffected CIPA provisions. Companies should audit tracking technologies, preserve accessibility remediation records, and reassess CIPA exposure assumptions.

cipa-trap-and-tracewebsite-accessibilityada-litigationvexatious-litigantsb-690
Read the full dispatch →
09 — REGULATORY / GOVERNMENT1
Troutman Pepper Locke+ Expand
State AGs Boost AI, Privacy, Pricing Enforcement; NJ Implements Surveillance Pricing Ban

In-house counsel at U.S. companies using AI, processing consumer data, or deploying dynamic pricing models face rising compliance risk from intensifying state AG enforcement and New Jersey’s new surveillance pricing ban.

State attorneys general across multiple U.S. jurisdictions have announced stepped-up enforcement initiatives targeting AI development and deployment, consumer data privacy practices, and anti-competitive pricing strategies. New Jersey has recently enacted a ban on surveillance pricing, which prohibits using consumer behavioral data to set individualized prices for goods and services. The 2026 midterm election cycle and key state AG races will shape 2027 enforcement priorities, with potential for expanded regulatory focus across additional states. In-house counsel should audit current AI, data privacy, and pricing practices for compliance with existing state rules and the new New Jersey ban, monitor pending AG enforcement actions in their operating jurisdictions, and update internal compliance programs to address emerging state-level regulatory requirements.

state-ag-enforcementai-regulationconsumer-privacysurveillance-pricingpricing-compliance
Read the full dispatch →
10 — SANCTIONS / EXPORT CONTROLS1
Arnold & Porter+ Expand
Supreme Court Holds Helms-Burton Act Abrogates Cuban State Entity Sovereign Immunity

U.S. nationals holding FCSC-certified Cuban confiscated property claims and counsel for Cuban state-owned entities with U.S. exposure must evaluate new litigation risk after the Supreme Court eliminated a core jurisdictional barrier to Title III suits.

On June 23, 2026, the Supreme Court issued a 6-3 ruling in Exxon Mobil Corp. v. Corporación CIMEX, S.A. holding that the Helms-Burton Act’s Title III abrogates foreign sovereign immunity for Cuban state-owned agencies and instrumentalities, eliminating the requirement for plaintiffs to satisfy a separate Foreign Sovereign Immunities Act (FSIA) exception to establish jurisdiction over these entities. The decision overturns lower court precedent that had blocked nearly all Title III suits against Cuban state entities, as the longstanding U.S. embargo on Cuba made it nearly impossible for plaintiffs to meet the FSIA’s commercial or expropriation activity exceptions. U.S. nationals with FCSC-certified Cuban property confiscation claims should evaluate filing or reviving Title III suits, while counsel for Cuban state-owned entities with U.S. exposure should assess litigation risk and defenses, noting post-judgment asset execution remains subject to separate FSIA execution immunity rules.

helms-burton-actcuban-sovereign-immunitytitle-iii-litigationfsiaconfiscated-property-claims
Read the full dispatch →
11 — TECHNOLOGY / AI1
BakerHostetler+ Expand
U.S. vs. E.U. AI Regulation: Cross-Border Business Compliance Guidance

In-house counsel for companies operating across the U.S. and EU must align AI compliance programs with divergent regional regulatory requirements to mitigate enforcement risk and avoid unnecessary operational constraints.

Published in the 2026 Issue 5 of the Computer and Telecommunications Law Review, the article provides a side-by-side analysis of U.S. and EU AI regulatory structures. It explains that U.S. AI rules are anchored in consumer protection principles with fragmented, sector-specific mandates, while the EU’s multi-dimensional framework combines product safety standards, fundamental rights protections, and internal market harmonization requirements. For cross-border businesses operating on both sides of the Atlantic, the analysis recommends selecting a consistent global AI governance baseline, calibrating compliance investment to actual regional risk exposure, and building flexibility into governance structures to adapt to ongoing regulatory evolution in both jurisdictions.

ai-regulationcross-border-complianceeu-ai-actus-ai-policycompliance-governance
Read the full dispatch →
Also noted

Grade 3 — worth a glance, not the full analysis.

Stay ahead

Join the digest.

One email when the daily AmLaw 100 briefing ships. No noise, no pitch decks — just the grade 4–5 signal.