FTC Reverses Rytr Consent Order

The Federal Trade Commission set aside its 2024 consent order against Rytr on December 22, 2025. The agency concluded that the original complaint failed to satisfy the legal requirements of the FTC Act and that the order unduly burdened AI innovation in violation of the Trump Administration's January 2025 AI Executive Order and America's AI Action Plan. In September 2024, the FTC brought an administrative complaint against Rytr as part of its Operation AI Comply enforcement sweep. The complaint alleged that Rytr's Testimonial and Review tool generated false and deceptive online reviews by allowing end users to use AI to draft and pre-populate product reviews which the user could edit. Rytr agreed to the consent order without admitting liability. The order prohibited the company from offering any AI service dedicated to consumer reviews or testimonials. Then-Commissioner Andrew Ferguson dissented from issuing the complaint. Following the January 2025 AI Executive Order, now-Chair Andrew Ferguson and Commissioner Mark Meador determined that the original complaint failed to meet the tests for an unfair business practice and means and instrumentalities liability under Section 5 of the FTC Act. The FTC emphasized that technology with both lawful and unlawful uses is not inherently illegal simply because it could be misused. Potential misuse without evidence of fraud or tangible consumer harm does not justify sweeping prohibitions. FTC Bureau of Consumer Protection Director Christopher Mufarrige stated that condemning a technology or service simply because it potentially could be used in a problematic manner is inconsistent with the law and ordered liberty. Rytr consented to vacating the order and waived any further rights under Rule 3.72(b).