Dan Gilman Quoted in CEI Comments on FTC Personalized Pricing Guidance
The Competitive Enterprise Institute quoted ICLE Senior Scholar Daniel J. Gilman in comments on the FTC’s proposed enforcement policy statement regarding personalized pricing. The comments examine the agency’s authority to require disclosures and how personalized pricing affects consumers and competition. Read the full comments here.
This guidance provides more questions than answers. As Daniel Gilman, senior scholar at the International Center for Law & Economics and former attorney advisor in the FTC’s Office of Policy Planning, observes,
[8] Daniel J. Gilman, “Fine Print for Every Price: The FTC’s One-Size-Fits-All Guidance,” Truth on the Market (blog), August 28, 2026, https://truthonthemarket.com/2026/08/28/fine-print-for-every-price-the-ftcs-one-size-fits-all-guidance/.
[16] “Economists have studied price discrimination—also called ‘price differentiation’ or ‘differential pricing’—at least since the landmark work of A.C. Pigou and Frank Ramsey in the 1920s. More recent contributors include Jean Tirole, Richard Schmalensee, Hal Varian, and Varian and Alessandro Acquisti, among others.” Gilman, “Fine Print for Every Price.”
[26] Federal Trade Commission, “Trade Regulation Rule on Commercial Surveillance and Data Security,” Federal Register, Vol. 87, No. 161 (August 22, 2022), https://www.federalregister.gov/documents/2022/08/22/2022-17752/trade-regulation-rule-on-commercial-surveillance-and-data-security; Gilman, “Fine Print for Every Price.”