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Sara Pullen

Sara Pullen

About Sara Pullen

Sara’s practice focuses on privacy compliance, technology transactions, and intellectual property, with a strong focus on health care and medical technology and is recognized for her ability to bridge legal, technical, and clinical domains. Drawing on her background as an ICU nurse and her MBA, she brings a unique, practical perspective to advising clients across industries.

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To Delete or Not to Delete: Can 23andMe Really Sell Genetic Data Via Bankruptcy?

April 7, 2025 By Daniel Felz, Joyce Gresko, William Sugden, Kennedy Bodnarek, Anna von Spakovsky and Sara Pullen

On March 23, 2025, 23andMe Holding Co. (“23andMe”) filed for bankruptcy in the Eastern District of Missouri, potentially setting in motion the sale of genetic data collected from more than 15 million people.  This has led to news outlets and state Attorneys General encouraging consumers to delete their 23andMe data before it is sold as […]

Filed Under: Bankruptcy, FTC, Genetic Privacy, Health Privacy, Privacy, Privacy Policy

California Joins the Neural Data Bandwagon

September 12, 2024 By Sara Pullen

On August 31, the California assembly passed SB1223, which amends the CCPA/CPRA to include “neural data” as a type of sensitive data.  SB1223, which is likely to become law, defines “neural data” as “information that is generated by measuring the activity of a consumer’s central or peripheral nervous system, and that is not inferred from […]

Filed Under: AI, Artificial Intelligence, CCPA, CPRA, Health Privacy, Neuroprivacy, Privacy, Privacy Policy, Uncategorized

Making (Brain) Waves: New Colorado Legislation Poised to Protect Privacy of Neural Data

January 19, 2024 By Sara Pullen

Neurotechnology, like wearable EEG headbands and invasive brain implants, collects information from electrical nerve impulses and brain waves derived from your brain, spinal cord, or nervous system.  This information, or neurodata, is valuable, unique, potentially individually identifiable, and has the potential to provide access to a person’s memories, biases, and intentions.  (For more information, see […]

Filed Under: Artificial Intelligence, Health Privacy, Privacy

HHS and FTC Fire a Warning Shot at Healthcare Companies Using Online Tracking Technologies

July 20, 2023 By Kathleen Benway, Daniel Felz and Sara Pullen

On July 20, 2023, the Office for Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”), and the Federal Trade Commission (“FTC”) published a joint letter sent to approximately 130 hospital systems and telehealth providers. The FTC/OCR letter warns that certain online tracking technologies that “may be present” on the recipients’ […]

Filed Under: Data Protection, FTC, Health Privacy, HHS, Online Privacy, Privacy

HHS and FTC Expanding Technology, Privacy, and Cybersecurity Divisions

March 23, 2023 By Sara Pullen

In recent weeks, FTC and HHS have announced expansion of the operational areas of their organizations that are dedicated to enforcement of laws and regulations related to technology, privacy, and cybersecurity. On February 17, 2023, the FTC announced the creation of a new Office of Technology in order to “strengthen the FTC’s ability to keep […]

Filed Under: ePrivacy, FTC, Health Privacy, HHS, Online Privacy, Privacy, Regulation

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