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NIST Keeps IoT Hot with Draft Guidance

Client Alert | 1 min read | 01.22.21

The National Institute of Standards & Technology (NIST) has published three draft addenda to its manufacturer IoT guidance NISTIR 8259, as well as draft guidance for federal agencies, NIST SP 800-213, on integrating IoT devices into their networks. Notably, NIST published the addenda—8259B, 8259C, and 8259D—and 800-213 just days after the enactment of the Internet of Things Cybersecurity Improvement Act of 2020, in which Congress directed NIST to draft and finalize security guidelines for IoT devices procured by the federal government. While neither the 8259 addenda nor 800-213 fall within the Act's purview, they are likely to inform NIST's development of its IoT cybersecurity guidance under the Act. This is particularly true with regard to both 800-213 and addendum 8259D, the latter of which offers a "worked example" of implementing the core 8259 requirements within the specifications of the FISMA process and the NIST SP 800-53 security controls. 

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Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....

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