Author Archives: Bhavishya Ravi

Bhavishya Ravi
Bhavishya Ravi is a senior attorney with Alston & Bird’s Technology & Privacy Team.Bhavishya focuses her practice on counseling clients on data privacy and security issues arising from their technology products and services.  Read More

Smart Television Manufacturer Settles by Paying $ 2.2 Million to the FTC and the State of New Jersey

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The FTC and the State of New Jersey recently announced a settlement with Vizio, Inc., in the amount of $2.2 million for tracking consumer behavior using its smart television devices. The complaint alleged that Vizio acted unfairly by collecting, storing (indefinitely) and sharing consumer data with third parties without consent and in an unexpected manner. Further, the complaint alleged that Vizio had misrepresented the functionality of the feature in their smart televisions that collected such data (also known as “Smart Interactivity”). It was also alleged that these practices were an unconscionable [...] Read more

FTC Staff Releases Report on Cross-Device Tracking

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The Federal Trade Commission (FTC) recently released its staff report on Cross-Device Tracking. Cross-device tracking refers to the tracking of consumer activity across multiple devices such as smartphones, desktops, tablets and other connected devices. It helps companies understand consumer behavior better. The tracking can be deterministic (where a user logs into multiple devices affirmatively identifying the device as his/hers) or probabilistic (companies infer cross-device activity using factors like common IP address). Benefits include account security, fraud detection, targeted advertising [...] Read more

Center for Cyber & Homeland Security Issues Report on How the Private Sector Can Actively Defend Against Cyber Threats

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Earlier this year, the Center for Cyber & Homeland Security at the George Washington University (“Center”) announced a new project on active defense against cyber threats. The Center  established a high-level task force to examine these issues.  The task force included prominent cybersecurity and industry experts, including Alston & Bird partner Michael Zweiback. The Task Force successfully released its final report in October. It is available here. The report comes at a time when cyber vulnerabilities have been exploited by hostile state and non-state actors in cyberspace [...] Read more

Bank Regulators Issue Advanced Notice of Proposed Rulemaking on Cyber Risk Governance and Management Regulations

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More regulators (apart from the FTC) are now taking note of cybersecurity issues in the financial services industry and are taking steps to protect the industry and its consumers. Earlier this year, the Consumer Financial Protection Bureau (“CFPB”) issued its first enforcement action on data security against an online payment system.   In June, the Federal Financial Institutions Examination Council (“FFIEC”), an interagency body, issued a press release advising financial institutions to review their risk-management practices.  Last month, the New York State Department of Financial [...] Read more