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In December 2022, the Modernization of Cosmetics Regulation Act (“MoCRA”)—the most significant expansion of the U.S. Food and Drug Administration’s authority to regulate cosmetics in nearly 85 years—was signed into law. Among other things, MoCRA gives the FDA authority to require facility registration and reporting of serious adverse events, impose certain record-keeping obligations, recall cosmetic products, and establish good manufacturing practices. With many of MoCRA’s provisions going into effect at the end of this year, cosmetics companies need to prepare to address these requirements and regulations, which may also have a considerable impact on the litigation landscape.

Crowell’s Product Risk Management team has written two publications to help cosmetics companies prepare for the big changes ahead.Continue Reading Modernization of Cosmetics Regulation Act (“MoCRA”) White Paper

The word “bot” is a double-entendre. It refers both to the larval stage of the bot-fly, a rather gruesome internal parasite (warning, link not for the squeamish) and to a software application that runs automated scripts on the internet in highly repetitive fashion—also with parasitic effects. Internet bots can be programmed for good or evil. This post refers to the latter kind.

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Use of Bots for Ad Fraud

The dominant model of compensation for digital advertising remains the CPM, or cost per thousand impressions. Impressions are simply ad views, that is, the successful delivery of a specific advertisement to a consumer’s web browser. (We adopt the fiction that it has been “viewed” so long as it appears for some period of time on the consumer’s screen.) There is robust debate on what an impression actually means with respect to non-static ads, such as videos, for which compensation may flow even if the consumer sees only a few seconds of the entire video. A publisher, such as a website, will offer advertisers a sliver of their online real-estate at a given CPM rate, and will thereafter be compensated by advertisers at that rate for how many impressions have been generated.

Continue Reading Subverting Democracy, Advertising, and the Economy Through Bots