On August 24, 2015, the Third Circuit affirmed U.S. District Court Judge Esther Salas’ April 2014 ruling in FTC v. Wyndham Worldwide Corp., et al. (“Wyndham”) that the FTC has the authority to regulate private companies’ cybersecurity practices under Section 5 of the FTC Act. (Prior blog posts on this case can be found here […]
Regulatory Enforcement
FTC Looks “More Favorably” Upon Companies That Report Data Breaches to Law Enforcement
The Federal Trade Commission recently announced that it views companies that report data breaches to appropriate law enforcers “more favorably” than those companies that are less cooperative. Mark Eichorn, Assistant Director in the Bureau of Consumer Protection’s Division of Privacy and Identity Protection, included the announcement in a May 20, 2015 blog post, describing a […]
Alston & Bird Privacy Program: Thinking Outside the Cookie Jar
On April 29, Alston & Bird’s Los Angeles office hosted a Privacy Program on Mobile Behavioral Tracking. Dominique Shelton of Alston & Bird moderated a panel that consisted of Alston & Bird attorneys Peter Swire and David Keating and industry professionals from the Office of the Attorney General, California Department of Justice, Ghostery Inc. and […]
DOJ to Host Cybersecurity Roundtable on Data Breaches
On April 29, 2015, the Department of Justice’s Criminal Division will host a cybersecurity industry roundtable on data breaches. The event, which will include audience question and answer sessions, will focus on a range of recent industry developments. The event will feature a discussion of cybersecurity from the national security perspective by John P. Carlin, […]
SEC Confirms Plans To Issue New Cybersecurity Disclosure Rules
According to Smeeta Ramarathnam, Chief of Staff to SEC Commissioner Luis Aguilar, the SEC is currently engaging in a comprehensive re-work of its investor disclosure rules, including with respect to rules bearing on cybersecurity incident disclosure. The SEC, which is formally tasked with overseeing issues that concern market integrity and disclosure of material information, revealed […]