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The New Consumer Data Privacy Trap: How to Avoid Pitfalls of Dark Patterns

Growing regulatory action to combat so-called “dark patterns” used in web design to influence consumer choice has resulted in hundreds of millions of dollars in fines, and promises to continue to be an area of enforcement in...more

Second Circuit Weighs in on Article III Standing in Data Breach Lawsuits, Denying Existence of a Circuit Split

While some states have enacted privacy laws granting consumers the right to bring a private right of action in a data breach context, federal courts have struggled to fit data breach injury into traditional Article III...more

Department of Labor’s Cybersecurity Guidance for Benefit Plans Signals Increased Scrutiny

On April 14, 2021, the Department of Labor (DOL) issued its first set of guidance documents related to the cybersecurity of retirement benefit plans covered by the Employee Retirement Income Security Act (ERISA). The...more

Update: Protecting Privilege: Top 10 Checklist for Cybersecurity Forensic Investigation Reports

In ongoing multidistrict litigation concerning Capital One’s 2019 data breach, Capital One succeeded in defeating a motion to compel disclosure of a privileged root cause analysis conducted by PwC. In contrast to an earlier...more

Massachusetts Voters Approve Vehicle Data Access Initiative

Voters in Massachusetts overwhelmingly approved a ballot initiative that gives independent mechanics greater access to vehicle data, a move that vehicle manufacturers have foreshadowed could have significant cyber and privacy...more

CPRA Rivals GDPR’s Privacy Protections While Emphasizing Consumer Choice

The newly passed Proposition 24, the California Privacy Rights Act (CPRA), represents the second time in two years that California has instituted a comprehensive privacy statute that fundamentally changes data privacy...more

Vermont Attorney General Provides Guidance on Security Breach Notice Act

On March 5, 2020, Gov. Phil Scott (VT-R) signed into law amendments to the Security Breach Notice Act (the “Act”). The amendments, which originated in the State Senate as part of an initiative addressing a number of data...more

SEC’s Examination Function Warns Its Registrants of Risks Associated with Dangerous Malware

- In the age of broad corporate teleworking brought on by COVID-19, OCIE of the SEC has observed during recent examinations that investment advisers, broker-dealers and investment companies are subject to an increased threat...more

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