Ann-Marie Luciano

Member

Ann-Marie brings her unique and varied litigation, investigation, and policy background to bear in successfully counseling clients facing litigation and government investigations brought by state attorneys general (AGs), the Federal Trade Commission (FTC), and the U.S. Department of Justice (DOJ), as well as in negotiating resolutions on cybersecurity, data privacy, antitrust, and consumer protection matters. Additionally, based on her years of experience negotiating with state and federal regulators, Ann-Marie regularly counsels clients on best practices in data security, privacy, marketing and advertising claims, and consumer practices to minimize regulatory risk.

Ann-Marie’s clients range from startups, to technology-driven disruptors, to Fortune 100 companies in a variety of industries including technology, consumer products, pharmaceuticals, energy, retail, hospitality, and software.

With an in-depth knowledge of state AGs’ priorities built over many years in practice, Ann-Marie is often engaged by clients to work with AGs strategically to resolve investigations quickly and without litigation. She advises clients preemptively on how to avoid becoming the target of investigations — and should an investigation be launched, she is able to use her insight into state AG priorities, goals, and areas of flexibility to help achieve expeditious (and ideally non-public) resolutions. Ann-Marie’s familiarity with state AGs and their staff also allows her to advocate effectively for clients in their dealings with state departments of revenue, commerce departments, and other state agencies. Ann-Marie also represents clients facing FTC regulatory scrutiny, often in coordinated investigations with AGs, into issues involving the evaluation and substantiation of advertising, health, safety, and scientific claims, and other consumer practices.  

In addition, Ann-Marie has substantial experience in the area of complex antitrust and financial services investigations and litigation, representing both plaintiffs and defendants in Section 1 and Section 2 matters. She has successfully represented plaintiffs asserting monopolization and exclusive dealing claims and has been involved in defending numerous antitrust cases related to the credit card industry. She also advises clients on the antitrust, state AG, and regulatory issues associated with potential acquisitions. She advises companies through all stages of the Hart-Scott-Rodino premerger notification process.

Ann-Marie has defended corporations and individuals in a variety of matters. She has successfully defended a large government contractor in an E.D.V.A. action, resulting in the plaintiffs withdrawing their damages expert before trial after the submission of her Daubert motion and subsequently entering into a favorable settlement. She also represented corporate employees of a large accounting firm in connection with a grand jury investigation related to a tax shelter scandal, and defended a major pharmaceutical company in an investigation into an Anti-Kickback Statute and health care fraud scheme.

Ann-Marie has performed a substantial amount of pro bono litigation work relating to constitutional, habeas corpus and death penalty issues, including successfully drafting an amicus brief on behalf of The Innocence Project, Inc. in Holmes v. South Carolina (2006), as well as an amicus brief on behalf of habeas scholars in Day v. McDonough (2006).

She is an active member of the American Bar Association and is a founding member of the State Attorneys General and Department of Justice Issues Committee of the ABA.

Experience

News

Recent AG and FTC Enforcement Actions Provide Guidance on Data Security Best Practices

January 08, 2020

Ann-Marie Luciano and Jawaria Gilani published an article in the January 8 edition of CyberSecurity Law Report setting out practical steps companies can take to reduce the likelihood of a data breach.

Cozen O’Connor Launches New State Attorneys General Practice with Addition of Nationally Acclaimed State AG Practice

May 05, 2015

On the heels of its recent announcement of the addition of 60 lawyers in Chicago, Cozen O’Connor is proud to announce the addition of ten attorneys and government professionals and the formation of the firm’s State Attorneys General Practice.

Publications

Considerations As State AGs Step Up Privacy Enforcement

August 15, 2024

In this Law360 article Ann-Marie Luciano and Meghan Stoppel discuss the rapid expansion of state privacy laws and what businesses need to do to adapt.

Expect Turbulence Ahead as State AGs and DOT Join Forces to Investigate Airlines and Travel Agencies [Alert]

April 25, 2024

Ann-Marie Luciano, Meghan Stoppel, Jonathon Foglia, and Patrick Rizzi discuss the DOT's recent announcement of an Airline Passenger Protection partnership with State AGs to empower AGs to more effectively investigate complaints and enforce state laws.

Proposed Expansion of New York’s Business Law Could Have Significant Detrimental Effects [Alert]

June 28, 2023

The Consumer and Small Business Protection Act could result in a vast expansion of legal liability for businesses operating in the Empire State.

State AG Pulse | Vermont: Small Is Mighty

June 12, 2023

Elected in November 2022, Vermont AG Charity Clark has hit the ground running, applying herself across a broad range of issues in the state from consumer protection, the environment, and privacy rights to domestic violence and women’s reproductive health.

Don’t ignore state antitrust risks, competition specialists say

May 03, 2023

Legal Dive listened to our podcast The Broad Sweep of State AGs’ Antitrust Authority and warns consumer goods companies of the risks of ignoring state AGs’ independent antitrust authority.

State AG Pulse | The Broad Sweep of State AGs’ Antitrust Authority

May 01, 2023

State AGs have a wide range of tools they can use to hold companies accountable. Milton Marquis, Jerry Kilgore and Ann-Marie Luciano explore AGs’ power to prevent anticompetitive business conduct ranging from no-poach agreements and illegal non-competes to collusion and price-fixing.

State AG Pulse | Illinois: Getting Stronger Through Adversity

February 21, 2023

State AG Pulse S2E3 now available: Illinois: Getting Stronger Through Adversity w/ State AG team member Lori Kalani + Ann-Marie Luciano.

Web Design Do's And Don'ts Amid Dark Pattern Enforcement

November 09, 2022

In Law360, Ann-Marie Luciano and Emily Yu offer practical guidance to help businesses minimize the risk of regulatory enforcement arising from “dark pattern” marketing practices.

Countdown to Decision 2022 – Election Perspectives from Our Team

October 06, 2022

As election day 2022 approaches, members of the Cozen O’Connor State AG Group share their thoughts on some of the trends and themes that have emerged over the course of the primary season.

State AG Pulse | Local Job, National Impact

June 13, 2022

In this week’s episode, Lori gets together with fellow State AG Group members Maria Colsey Heard and Ann-Marie Luciano to talk about the evolution of the DC Office of the Attorney General into a national powerhouse, Karl Racine’s legacy as its first elected AG, and this year’s contentious race.

Dark Patterns: The Next UDAP Frontier | 2022 NAAG Spring Consumer Protection Conference (Part 2 of 4)

June 06, 2022

The second panel of the day was hosted by Iowa’s Deputy AG for Public Protection, Jessica Whitney, and focused on the emerging issues involving so-called “dark patterns,” and whether they constitute deceptive or unfair trade practices.

A View from the Top: AGs on Their Consumer Protection Role | 2022 NAAG Spring Consumer Protection Conference (Part 1 of 4)

June 06, 2022

In this first of four panel discussions held at the 2022 NAAG Spring Conference, three sitting AGs discussed the most pressing and cutting-edge consumer protection issues they are confronting.

Counting Down the Hits – Top Consumer Complaints | 2022 NAAG Spring Consumer Protection Conference (Part 3 of 4)

June 06, 2022

The third panel was comprised of consumer protection chiefs from Florida, Illinois, North Carolina, Ohio and Vermont. It provided a brief glimpse into the most common complaints received by their respective offices, and how those complaints are mediated by their staff.

Meeting of the Minds – Negotiating State AG Settlements | 2022 NAAG Spring Consumer Protection Conference (Part 4 of 4)

June 06, 2022

The fourth panel of the day examined the complexities of negotiating resolutions to state AG investigations and litigation, and featured panelists with extensive experience resolving multistate AG investigations and litigation.

Recent Trends and Insights in State Attorney General Antitrust Enforcement

August 31, 2021

Milton Marquis, Ann-Marie Luciano and Gianna Puccinelli analyze recent state AG antitrust enforcement trends, provide insight into targeted industries and consider future roles for state AGs.

State AGs Share Breach Notification Tips and Latest Enforcement Concerns

June 09, 2021

State AG Group co-chair, Lori Kalani, and members Ann-Marie Luciano and Meghan Stoppel, offer best practice advice for companies whose security has been breached and comment on trends in AG enforcement.

State AGs Intensify Focus on Employee Rights in the Pandemic

February 16, 2021

The Covid-19 pandemic has caused state attorneys general to accelerate their workplace enforcement efforts and is reshaping the issues businesses must consider to avoid regulatory risk. Cozen O’Connor State AG Group partners Maria Colsey Heard and Ann-Marie Luciano explain what steps businesses should take to respond. Read the Bloomberg Law piece here or here.

Demand for Information-Sharing Platforms Has Soared, Raising Privacy Concerns With Regulators [Alert]

April 22, 2020

Lori Kalani and Ann-Marie Luciano discuss privacy and data security issues state AGs are investigating and what technology companies can do to prevent these issues.

Recent AG and FTC Enforcement Actions Provide Guidance on Data Security Best Practices [Infographic]

February 10, 2020

More and more companies are experiencing crippling data breaches. We analyzed recent state Attorney General and FTC enforcement actions to identify eight data security best practices that companies can adopt to mitigate the likelihood of a breach which can be found in this infographic.

State Attorney Activism and Enforcement Trends

February 03, 2020

Ann-Marie Luciano, Chris Allen, and Bryan Mosca published an article in Bloomberg Law on February 3, 2020, sharing their observations on trends in state Attorney General activity in 2019, and the enforcement priorities they expect to see AGs focus on in 2020.

Education

  • Cornell Law School, J.D., 2001
  • Allegheny College, B.A., magna cum laude, 1998
  • District of Columbia
  • New York
  • U.S. District Court -- Western District of New York
  • U.S. District Court -- Southern District of New York
  • U.S. District Court -- Northern District of New York
  • U.S. District Court -- District of Columbia
  • U.S. Supreme Court