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Tighter SEC Cybersecurity Incident Disclosure ‎Requirements Go into Effect Today

The new SEC cybersecurity rules (Release No. 33-11216), codify and build on earlier SEC guidance on cybersecurity risks and incidents and require specific cybersecurity-related disclosures....more

The Supreme Court’s Ramirez Isn’t Standing in the Way of Standing in Recent Data Breach and Privacy Cases

Despite the much-anticipated impact of TransUnion LLC v. Ramirez (“Ramirez”), the Supreme Court decision has not prevented data breach and privacy class actions from proceeding past the pleading stage in federal courts across...more

"Safe Harbor" Ports in a Cybersecurity Litigation Storm

Every organization with an online presence needs to continuously think about its cybersecurity. The number of cyberattacks spiked significantly during the COVID-19 pandemic with an estimated global loss of nearly $1 trillion....more

Business as Usual – so Far – for Data Breach Cases After TransUnion LLC v. Ramirez

The Supreme Court’s June 2021 decision in TransUnion LLC v. Ramirez led many to believe that data breach plaintiffs were going to have a difficult time establishing standing. After all, the Court suggested that exposure to...more

Firmer Footing for Data Breach Standing, Thanks to the Second Circuit

Instead of identifying traditionally “tangible” injuries, data breach plaintiffs typically point to the fact that they may be the victim of identity theft at some point in the future. Prior to late April 2021, the federal...more

Standing on Thin Ice? New Guidance on Standing for Data Breach Claims

Who has standing to bring claims for alleged statutory violations of privacy and cybersecurity statutes? There is no easy answer to this question. In Spokeo, Inc. v. Robins, the Supreme Court explained that just because a...more

Deletion Completion under the CCPA

The effective date for the California Consumer Privacy Act (CCPA) is January 1, 2020. With fewer than 60 days remaining, covered businesses must be ramping up to meet the requirements of the CCPA. The CCPA affords several...more

CCPA Guide: Does Personal Information Include Employee and Employee Benefit Plan Data?

Beginning on January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) will impose new privacy obligations on certain businesses that collect personal information of California consumers. Employers with employees in...more

Testing the Limits III – Cyber Coverage Litigation Focuses on Computer Fraud Losses

Fraudsters deploy different computer-related techniques but toward the same end – “gaming the system” for their own financial gain. Some victims turn to insurance for recovery. Four recent federal appellate decisions reveal...more

Testing the Limits III – Cyber Coverage Litigation Focuses on Computer Fraud Losses

Fraudsters deploy different computer-related techniques but toward the same end – “gaming the system” for their own financial gain. Some victims turn to insurance for recovery. Four recent federal appellate decisions reveal...more

Follow the Leader: NYDFS Cybersecurity Regulation Leads the Way for Other States and Industries

The New York Department of Financial Services (NYDFS) blazed a cybersecurity trail with its 2017 regulation for the protection of information collected and processed in, and systems used in the operation of, the financial...more

CyberSECurity – The SEC Increases Data and System Protection Work

The U.S. Securities and Exchange Commission is at the center of the current day “cyber storm” of data and system protection, both as a victim and as a regulator. According to an SEC director, “[c]yber-related threats and...more

Equifax Lax About Hacks, Says Shareholder Lawsuit

In early September, Equifax disclosed a now well-known data breach that ultimately affected a reported 146 million customers in the United States. The breach allegedly occurred in May 2017, as a result of an online security...more

“If at First You Don’t Succeed…” - Shareholders Keep Trying to Sue D&Os for Data Security Breaches

Several high-profile lawsuits have been filed in recent years by shareholders seeking to hold corporate officers and directors liable for damage resulting from data security breaches. For example, directors and officers at...more

Privacy & Cybersecurity Newsletter

New York’s Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To Do List - With a compliance date a few months away, licensees of the New York Department of Financial Services (DFS) must start...more

Coverage and the Duped Employee

What role do cyber and other insurance lines play when losses result from an employee’s unwitting participation in spoofed email or password theft schemes? Several recent cases illustrate the evolving coverage implications...more

A Common Standard for Evaluating Cyber Risk – Insurers Walk the Walk

Insurers have struggled to find a common baseline to measure cyber risks. Changes in technology, hacking and other data security risks and the shifting legal landscape concerning liability for data breaches have made the...more

Which Way is the “Wyndham” Blowing? Cyber Regulation After FTC vs. Wyndham

Does the Third Circuit’s recent decision in FTC v. Wyndham Worldwide Corp. usher in a new era of enforcement by the FTC and other federal agencies regarding cybersecurity practices? Regardless of the answer, it is important...more

“Everything Old is New Again” – Issues in Recent Cyber Insurance Litigation

Early days still for coverage litigation about cyber risks – whether under cyber insurance policies or other types of policies. This is not surprising given the relatively short history of cyber risks and even shorter history...more

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