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The very acronym evokes head scratches and sighs of angst and frustration among many lawyers in the retail industry. But what is it and why has virtually every retailer been hit with a TCCWNA class action demand letter or lawsuit in the past few months? You have probably heard about it. You may have even been warned about it.
On March 20, 2009, the Federal Trade Commission (“FTC”) published its long-awaited guide to the Red Flags Rule (the “Rule”), entitled “Fighting Fraud with Red Flags Rule: A How-To Guide for Business.” For entities subject to the FTC’s jurisdiction, the relevant compliance deadline is May 1, 2009.
Reasoning agents that book your travel, negotiate your insurance bills, or manage your calendar simply will not work if they are beholden to the same business models currently driving Big Tech. Retail media will consolidate. Question: How many “retail media exchanges” are there today? Answer: Way too many !
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