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ARTICLE · 02 JANUARY 2026

FTC Sets Aside Rytr LLC Final Order, Citing The Trump Administration's AI Action Plan

Wiggin and Dana LLP
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On December 22, 2025, the FTC reopened and set aside the FTC's 2024 consent order against the AI company Rytr LLC.

United StatesAntitrust/Competition Law
Gabriella Bensur
Gabriella Bensur
Benjamin Diessel
Benjamin Diessel
Robert M. Langer
Robert M. Langer

On December 22, 2025, the FTC reopened and set aside the FTC's 2024 consent order against the AI company Rytr LLC.1 This move was made by the two active members, Chair Andrew Ferguson and Commissioner Mark Meador, leading the normally five-member agency. These members ordered the Rytr consent decree to be set aside because the initial complaint against Rytr "failed to satisfy the legal requirements of the FTC Act" and the order "unduly burdens" AI innovation in violation of the Trump Administration's Executive Order on AI and AI Action Plan.2

The consent order, issued under former Chair Lina Khan, had settled allegations that Rytr's AI "Testimonial & Review" service allowed users to generate false and deceptive online reviews.3 The FTC had also alleged that Rytr "engaged in an unfair business practice by offering a service that is likely to pollute the marketplace with a glut of fake reviews."4 Rytr was prohibited from engaging in similar illegal conduct in the

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