Both the administrative law judge’s decision in LabMD and the Third Circuit’s recent decision in Wyndham, which we previously blogged about, put the FTC on notice that it cannot assume that in the wake of a security breach,...more
The Third Circuit interlocutory decision in Federal Trade Commission v. Wyndham Worldwide Corporation was widely reported as a big win for the Federal Trade Commission (“FTC”). But on closer examination, it was a split...more
11/5/2015
/ Consent Order ,
Cybersecurity ,
Data Security ,
Federal Trade Commission (FTC) ,
FTC Act ,
FTC v Wyndham ,
Interlocutory Orders ,
Motion to Dismiss ,
Popular ,
Regulatory Standards ,
Unfair or Deceptive Trade Practices ,
Wyndham
Echoing guidance previously given to a nonprofit organization looking to exchange certain cybersecurity information, including exchanging actual real-time cyber threat and attack information, and others planning to exchange...more
In a March 20, 2014 closing letter sent to fashion company Cole Haan, the FTC warned that use of the hashtag #WanderingSole in conjunction with a recent Pinterest contest did not adequately communicate the “material...more