Last year, the D.C. Circuit issued its opinion in Mozilla v. Federal Communications Commission in which the court largely upheld the Commission’s Restoring Internet Freedom Order that reversed the Obama Administration’s 2015 decision to apply common carrier regulation to the Internet. While the court upheld the bulk of the agency’s actions as reasonable under the Supreme Court’s rulings in Chevron and Brand X , the Court also remanded three discrete issues for further consideration by the Commission: 1.) public safety; 2.) pole attachments; and 3.) the Lifeline program. These comments seek to address the implications of reclassification and of the Commission’s light-touch regulatory approach for public safety.
The Committee for Justice filed comments with the Office of Management and Budget (OMB) regarding the draft memorandum to federal agencies, “Guidance for Regulation of Artificial Intelligence Applications.” The aim of our comments is to assist the executive branch in creating policies that will continue and advance America's leadership in artificial intelligence technology and innovation while also promoting America's values. Specifically, our comments address two of the "Principles for the Stewardship of AI Applications" discussed in the draft memo: 1) fairness and non-discrimination, and 2) disclosure and transparency.
The Committee for Justice filed comments to the SEC regarding the Proposed Amendments to Exemptions from the Proxy Rules for Proxy Voting Advice. We believe that Securities and Exchange Commission’s proposed rule change regarding proxy advisory firms is a positive step towards implementing much-needed reforms. The rules governing the proxy system need to be clarified and modernized for the benefit of investors, public companies, and the U.S. financial services industry as a whole. Therefore, the SEC should implement the proposed rule.
In considering revisions to COPPA, the FTC should carefully weigh these unintended effects, especially if the FTC is considering more detailed regulations that will impose additional compliance costs on sites targeted towards children. Such additional costs of regulation can readily be absorbed by large entities, such as Google and YouTube, but may put a smaller site out of business or give it an incentive to arrange their content to avoid being regulatorily labeled as a site directed to children. The results of more extensive regulation, including more complex processes and procedures for tracking and reporting on all use of children’s personal information, may reduce the quality and variety of child-appropriate content available.
We argue that digital advertising is both a substitute for and a complement to television advertising. In other words, the rampant ascent of digital marketing was made possible by TV advertising and its ability to influence consumer behavior. In that way it is a useful complement. The convergence of the two forms of advertising allowed marketers to measure efficacy and observe trends, which diverted attention to digital ads. Television and online ads no longer exist in separate silos; the two are inexplicably intertwined and functional distinctions have collapsed.
The original small dollar loan rule is one of the most detrimental regulations ever issued by the CFPB, an unaccountable and unconstitutional regulator established by the Dodd-Frank Act. Put forward under the guise of consumer protection, the rule would have stripped valued financial services away from some of the most vulnerable people in society.
As calls for data privacy in the United States echo those heard in Europe, it is important to remember the fate of the European Union’s digital economy at the hands of a strict regulatory regime. Our recommendations emphasize the need to prioritize economic prosperity and preserve the United States' role as leader in technological innovation instead of making America more like Europe.
Similar to how the Gutenberg press transformed how knowledge was disseminated in the Middle Ages, so has the Internet allowed for an endless amount of information to be accessible at our finger tips, as well as the ability to spread a message at the click of a button. The Internet is the information tool that has equalized the ability for anyone and everyone to engage in politics. It has lowered barriers to entry in the marketplace of ideas in ways that have fundamentally transformed the United States. Technologies that allow for more speech should be encouraged, not stifled. The answer to speech that is distasteful or offensive is more speech, not less...