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Laura Kim

Laura Kim has a proven track record of successfully resolving clients’ most important consumer protection matters before the FTC, State AGs, and the NAD. She is well-known for her insider knowledge of the FTC as well as her practical approach to accomplishing her clients’ objectives.

As chair of Covington’s Advertising & Consumer Protection Investigations practice group, Laura represents corporate and individual clients in investigations before the FTC and State Attorneys General. She also provides pragmatic compliance advice on a wide range of consumer protection issues, including substantiating claims involving generative artificial intelligence, environmental benefits, and “Made in USA.” She counsels brands on emerging issues involving influencers, consumer reviews, AI-generated content, and subscription autorenewals. Laura regularly represents both challengers and advertisers before the NAD, achieving favorable outcomes in matters involving artificial intelligence, influencers, and claim substantiation.

During her twelve-year tenure at the FTC, Laura served as Assistant Director in two divisions of the Bureau of Consumer Protection, Attorney Advisor to Chairman William E. Kovacic, and Chief of Staff to Bureau Director Jessica Rich. She oversaw major rulemakings—including the Green Guides and the Telemarketing Sales Rule—and supervised dozens of investigations and enforcement actions. As Assistant Director in the Division of Enforcement, Laura also supervised compliance monitoring and enforcement proceedings for companies under federal court or Commission order.

On July 23, 2026, New Jersey Governor Mikie Sherrill signed A4085 (the Fair Price Protection Act) into law, which prohibits companies from charging consumers different prices for groceries based on their personal data. New Jersey will join New York, Connecticut, and Maryland in imposing prohibitions and requirements on the use

Continue Reading New Jersey Enacts Ban on Surveillance Pricing

On June 2, 2026, Colorado Governor Jared Polis vetoed HB 26-1210, a bill that would have imposed requirements for use of “surveillance data” to set individualized prices for consumers or individualized wage setting for workers. The veto is yet another action in a trend of bills focused on regulating “surveillance” or “dynamic” pricing.

Continue Reading Colorado Governor Vetoes Overly Broad Algorithmic Pricing and Wage Setting Bill

On May 27, the Connecticut governor signed into law a comprehensive artificial intelligence (“AI”) bill that regulates safety, transparency, and consumer protection, including subscription marketing (“SB 5”). Alongside key provisions on Employee Reporting Protections, AI Companions, and Automated Employment-Related Decision Technology (discussed in more detail here), SB 5 also sets

Continue Reading Connecticut Extends AI Regulation to Subscriptions

On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.

Continue Reading New York City Adopts ‘Click to Cancel’ Rule

On July 1, 2026, the Federal Trade Commission (“FTC”) issued a proposed policy statement addressing what it describes as the “suppression of accuracy” in artificial intelligence (“AI”) systems and is seeking public comment through July 31, 2026. The proposal was issued pursuant to Executive Order 14365, Ensuring a National Policy Framework for Artificial Intelligence, which directed the FTC to explain how Section 5 of the FTC Act applies when AI developers alter model outputs in response to state law requirements.[1]

Continue Reading FTC Seeks Comment on Proposed Policy Statement Addressing AI Accuracy and Output Steering

On June 29, 2026, in a 6-3 decision, the U.S. Supreme Court held that (1) the Federal Trade Commission’s (FTC) statutory “for‑cause” removal protection for Commissioners violates the Constitution’s separation of powers and (2) President Trump lawfully removed Rebecca Slaughter from the FTC. The Court concluded that because FTC Commissioners exercise executive power, they must be removable by the President at will rather than only for “inefficiency, neglect of duty, or malfeasance in office.”

Continue Reading Supreme Court Holds FTC Removal Protections Unconstitutional

On May 27, the Connecticut governor signed SB 4, an omnibus privacy law, followed a week later by two clean-up bills, HB 2222 and HB 5563 (collectively “SB 4”). SB 4, among other things, amends the Connecticut Data Privacy Act (“CTDPA”), establishes a data broker registry and accessible deletion mechanism, imposes restrictions on surveillance pricing, and creates requirements for direct-to-consumer genetic testing companies.

Continue Reading Connecticut Enacts Omnibus Privacy Law

On May 11, 2026, the Department of Justice, acting on notification from the Federal Trade Commission, and the Illinois Attorney General, filed a complaint against “Premium Home Service” and its owner for alleged violations of Section 5 of the FTC Act, the Consumer Reviews Rule, and the Gramm-Leach-Bliley Act (GLB Act).  The Complaint seeks injunctive relief, monetary relief, and civil penalties.  

Continue Reading FTC and DOJ Continue Focus on Consumer Reviews Rule with Complaint Against Premium Home Service

On May 13, 2026, the Federal Trade Commission (“FTC”) announced that Shutterstock, Inc. had agreed to a $35 million settlement resolving allegations that the company engaged in unfair and deceptive subscription practices. The FTC asserted claims under Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”), alleging that Shutterstock charged consumers who did not understand they were enrolling in a subscription, failed to adequately disclose material subscription terms, and made cancellation unnecessarily difficult. The complaint did not seek civil penalties, and the final settlement requires only consumer redress. 

Continue Reading FTC Settles with Shutterstock Over Subscription Practices

On April 28, 2026, Maryland Governor Moore signed HB 895 (the Protection From Predatory Pricing Act) into law, which will impose limitations on the use of personalized pricing in the food retail and grocery delivery context.  The law will go into effect on October 1, 2026.  As we have detailed in prior blog posts, there has been a wave of personalized pricing proposals at the state level, and the FTC is focusing attention on pricing in the grocery sector.

Continue Reading Maryland Enacts Law on Personalized Food Pricing