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October 21st, 2022
State Regulators Charge NFT Casino Project With Securities Violations
Blockchain Technology Co-Chair Jeremy S. Goldman is quoted in the article, “State Regulators Charge NFT Casino Project With Securities Violations” published by Decrypt. The article discusses the emergency cease-and-desist orders filed against Slotie by state securities regulators from Texas, New Jersey, Kentucky, and Alabama. Jeremy believes it makes perfect sense that an NFT project like Slotie would be one of the first to incur a securities regulator’s wrath. He is quoted saying, “This is low-hanging fruit. [Slotie NFTs] are marketed as giving the holders a passive income in revenue that's generated through the efforts of Slotties and its partners, which is the definition of a security.” One reason these states may have chosen to pursue Slotie for securities violations, Jeremy says, is the fact that the case pertains to gambling, a highly regulated and closely monitored sector of state law enforcement. He says, “I imagine that part of the reason it came from the states is because they started with concern over gambling. And then, I guess, as a matter of litigation strategy and enforcement, they thought that the securities angle was an easier shot.”
Jeremy sees the biggest development from this week’s enforcement action against Slotie to be the indication that there could be even more dogs in that fight than previously anticipated. He says, “The federal agencies are not the only sheriffs in town. I can only speculate, but it does feel to me that there's some jockeying for power and control. And this is a signal that the states still have a role to play when it comes to even securities in the crypto space.”
Read the full article here.
Other Quoted
Data Privacy Roundup
The AdExchanger newsletter quotes Daniel M. Goldberg, highlighting key privacy enforcement trends. He provided an example of how opting in cookie tracking by clicking a bold “Allow All” button contrasted with declining tracing, which required a more involved two-step process. Mr. Goldberg pointed out that regulators saw this process as a “potential dark pattern.” “‘Symmetry of choice is the idea that it should be just as easy to accept as it is to reject,’” Goldberg said. ‘It’s an area regulators are looking very, very closely at.’” He also noted dark pattern fines, especially with the CPPA could become substantially larger. He underscored due diligence in programs, referencing recent privacy enforcement setttlements and fines. “‘All these cases involve vendor solutions that did not work,’ Goldberg said. ‘In almost all of them, the company did have privacy compliance in place; it just wasn’t working.’” View Article
July 25 2025
SHOOT’s 65th Anniversary Reflections: FKKS’ Managing Partner Jeffrey A. Greenbaum
SHOOT Magazine quotes Jeffrey A. Greenbaum in its 65th Anniversary coverage on where the advertising industry has been, is, and is going. Jeff discusses the most significant legal cases during his industry tenure and the accompanying lessons, the most pressing legal issues for the commercial production community, his most meaningful professional accomplishments, and the value he has gained from reading SHOOT. Read more.
July 24 2025
Companies Sought Help From Privacy Vendors. They Still Got Fined
Daniel M. Goldberg is quoted in Bloomberg Law on problems faced by companies who have relied on compliance vendors to help them navigate new privacy laws. The article stated that vendors operating with little oversight, outdated tech have “left businesses with consumer-facing websites open to fines and other enforcement actions.”
Bloomberg Law noted, “For example, giving consumers the option to disable cookies may not turn off all of a company’s tracking technology. So consumer data could still be automatically sent to a third party for advertising.
“Vendors cannot just repurpose tools meant to comply with EU’s data protection law for California’s rules, said Daniel M. Goldberg, chair of the data strategy, privacy & security group at Frankfurt Kurnit Klein & Selz PC.
"‘Many solutions are solutions that are built for one purpose,’ Goldberg said, adding that some vendors’ ‘default configurations often aren’t drafted in a way that is sufficient to address US privacy law.’” View Article.
July 14 2025
