Clay helps companies tackle their most complex regulatory challenges. Drawing upon 35+ years of experience with state AGs and other regulatory bodies, such as the FTC, clients seek his practical and straightforward guidance as they navigate a variety of regulatory matters, including marketing, advertising, unfair or deceptive practices, and related concerns.

Overview
Representative Matters
Insights
Awards

Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.

Clay is experienced in industries such as energy, mass media, telecommunications, and technology, as well as other highly scrutinized sectors such as consumer finance and fintech. Companies facing matters involving advertising, marketing, unfair or deceptive practices, and privacy concerns view him as a go-to advisor, drawing upon his 35-year track record of experience with these and related regulatory issues.

Clay regularly leads national defense teams before all 50 state attorneys general in singular and multistate regulatory actions, and in actions before the Federal Trade Commission, the Consumer Financial Protection Bureau, and other local, state, and federal agencies. He draws from this experience to provide clients with a clear-cut roadmap in situations that are often fraught with uncertainty.

Clients such as publicly traded companies and their boards also seek Clay’s advice for day-to-day issues at the intersection of regulatory compliance and corporate governance. His approach incorporates battle-tested strategies and well-informed insights gained from years of resolving bet-the-company challenges. Clay works closely with clients to provide strategies on how to approach — and avoid — enforcement actions.

Before entering private practice, Clay held senior positions in the Office of the Attorney General, State of Missouri, including as assistant deputy attorney general, director of multistate litigation, and Kansas City regional office manager. As lead counsel in several multistate enforcement actions, he handled national settlements with major automotive repair and manufacturing corporations, credit reporting agencies, and national retailers. Clay, a recipient of the prestigious NAAG Staff Member of the Year Award for his leadership and contributions to the National Association of Attorneys General (NAAG), has also served as the NAAG’s chief counsel and director of business regulation. He is a regular speaker at NAAG’s complex consumer protection trainings.

  • Represented a major automotive manufacturer in a large multistate matter involving the manufacturing of certain parts.
  • Represented a telecom company in connection with a multistate enforcement investigation into an entire industry segment.
  • Represented an online clothing and shoe retailer in connection with a large multistate investigation into advertising, pricing, and related issues.
  • Represented an international manufacturing company in a multistate investigation involving safety and advertising issues.
  • Represented a publishing company in connection with a state investigation into its subscription sales.
  • Represented a leading online gaming retailer in connection with an FTC mail-order rule investigation. The issue related to technical operational issues resulting in delays. The matter was complicated by priority issues provided to influencers.
  • Represented an international media company concerning a state investigation into its door-to-door sales structure.
  • Represented a broadcast satellite service provider in a two-year, nationwide attorney general consumer protection investigation brought against the client and other satellite TV providers in connection with their advertising and related practices. Through aggressive litigation, the case was settled on virtually identical terms as the multistate settlement with the other 49 states.
  • Chambers USA: State Attorneys General, Band 1 (2020-2025)
  • Best Lawyers in America®: Advertising Law (2016-2023)
  • Legal 500 United States: Government: State Attorneys General, Leading Lawyer (2023-2025)

Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.

Clay is experienced in industries such as energy, mass media, telecommunications, and technology, as well as other highly scrutinized sectors such as consumer finance and fintech. Companies facing matters involving advertising, marketing, unfair or deceptive practices, and privacy concerns view him as a go-to advisor, drawing upon his 35-year track record of experience with these and related regulatory issues.

Clay regularly leads national defense teams before all 50 state attorneys general in singular and multistate regulatory actions, and in actions before the Federal Trade Commission, the Consumer Financial Protection Bureau, and other local, state, and federal agencies. He draws from this experience to provide clients with a clear-cut roadmap in situations that are often fraught with uncertainty.

Clients such as publicly traded companies and their boards also seek Clay’s advice for day-to-day issues at the intersection of regulatory compliance and corporate governance. His approach incorporates battle-tested strategies and well-informed insights gained from years of resolving bet-the-company challenges. Clay works closely with clients to provide strategies on how to approach — and avoid — enforcement actions.

Before entering private practice, Clay held senior positions in the Office of the Attorney General, State of Missouri, including as assistant deputy attorney general, director of multistate litigation, and Kansas City regional office manager. As lead counsel in several multistate enforcement actions, he handled national settlements with major automotive repair and manufacturing corporations, credit reporting agencies, and national retailers. Clay, a recipient of the prestigious NAAG Staff Member of the Year Award for his leadership and contributions to the National Association of Attorneys General (NAAG), has also served as the NAAG’s chief counsel and director of business regulation. He is a regular speaker at NAAG’s complex consumer protection trainings.

  • Represented a major automotive manufacturer in a large multistate matter involving the manufacturing of certain parts.
  • Represented a telecom company in connection with a multistate enforcement investigation into an entire industry segment.
  • Represented an online clothing and shoe retailer in connection with a large multistate investigation into advertising, pricing, and related issues.
  • Represented an international manufacturing company in a multistate investigation involving safety and advertising issues.
  • Represented a publishing company in connection with a state investigation into its subscription sales.
  • Represented a leading online gaming retailer in connection with an FTC mail-order rule investigation. The issue related to technical operational issues resulting in delays. The matter was complicated by priority issues provided to influencers.
  • Represented an international media company concerning a state investigation into its door-to-door sales structure.
  • Represented a broadcast satellite service provider in a two-year, nationwide attorney general consumer protection investigation brought against the client and other satellite TV providers in connection with their advertising and related practices. Through aggressive litigation, the case was settled on virtually identical terms as the multistate settlement with the other 49 states.
  • Chambers USA: State Attorneys General, Band 1 (2020-2025)
  • Best Lawyers in America®: Advertising Law (2016-2023)
  • Legal 500 United States: Government: State Attorneys General, Leading Lawyer (2023-2025)
  • American Bar Association
  • Chief counsel and director of business regulation, National Association of Attorneys General (1994-1995)
  • Director of multistate consumer protection enforcement/assistant deputy attorney general, Missouri Office of the Attorney General (1984-1993)

Education

  • Saint Louis University School of Law, J.D., cum laude, 1984
  • State University of New York at Buffalo, B.A., cum laude, 1981

Bar Admissions

  • Missouri
  • Illinois
  • California