On May 26, the FDA issued warning letters to four companies alleging that the companies sold unapproved animal drugs containing cannabidiol (CBD). Specifically, these products were intended for use in food-producing animals. In announcing the warning letters, the agency stated
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SEC Enforcement Affirms Aggressive Approach
This client alert authored by Kathryn Campbell, Gina Buschatzke and Emily Craven covers what some senior SEC Enforcement officials discussed at a recent conference. The bottom line is that the SEC’s intention is clear – to continue to pursue enforcement…
Could It Be Easier to Convict a Doctor Than a Cartel Member? Why the Impending SCOTUS “Pill Mill” Ruling Makes Some Observers Nervous

The U.S. Supreme Court is poised to issue what could be a monumental decision in the Court’s Controlled Substances Act (“CSA”) jurisprudence as applied to the nation’s opioid epidemic. At issue in Ruan v. United States is the requisite intent…
CFPB’s May 2022 Mortgage Servicers Metrics Report
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB) published its second metrics report as part of its ongoing supervisory monitoring of mortgage servicers’ COVID-19 pandemic response. The data collected is part of the Bureau’s metrics requests to sixteen…
In-House Corner: Climate Teamwork
This feature of our blog is where our in-house readers share tips, anecdotes and thoughts about things that come up in their daily practice. This particular batch of thoughts is about handling a company’s climate transition as a team [feel…
Tomorrow’s Webcast: “The SEC’s Climate/Cyber Rulemakings – Your Action Items Now”
Tune in tomorrow, Tuesday, May 24th (from 3:00-4:00 pm eastern) for a video program – “The SEC’s Climate/Cyber Rulemakings: Your Action Items Now” – that will cover the practical side of the SEC’s recent climate and cybersecurity disclosure rule proposals.…
Ninth Circuit Rules on Legality of Delta-8 THC Products
On May 19, 2022, the U.S. Circuit Court of Appeals for the Ninth Circuit issued an opinion holding that Delta-8 THC products are legal at the federal level and eligible for intellectual property protection. The Ninth Circuit held that the…
FDA Issues Public Warning Regarding Accidental Ingestion of THC Food Products
On May 13, the FDA issued a public warning regarding reports of accidental ingestion of food products containing tetrahydrocannabinol (THC) by children. The FDA warned that edible products containing THC “can be easily mistaken for commonly consumed foods such as…
Climate Disclosure: Getting a Handle on Your Largest Risks

This “Pulse Survey” entitled “Steps Toward Building More Sustainable Organizations” from the Harvard Business Review is invaluable. It’s helpful in a number of ways. One way in which it’s helpful is discussing issues to consider when trying to…
California Court Strikes Board Gender Law on Constitutional Grounds
Last week, a California Superior Court in Los Angeles County delivered this Crest v. Padilla decision that found that the California law requiring that California-headquartered companies have a minimum number of women directors – known as “SB 826” – violates…