News & Analysis as of

Federal Trade Commission (FTC) Data Brokers Enforcement Actions

Morrison & Foerster LLP

FTC Looks to Leverage PADFAA Enforcement to Help Limit Exposure of Consumer Data

In recent comments, Commissioner Holyoak signaled that the Federal Trade Commission will prioritize enforcement of the Protecting Americans’ Data from Foreign Adversaries Act (PADFAA), a law that empowers the FTC to police...more

Holland & Knight LLP

Religious Institutions Update: May 2025

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Federal Trade Commission Protects Worship Location Data Shannon Britton Hartsfield and Bess Hinson-Greenspan Recent Federal Trade Commission (FTC) enforcement activity signals that companies need to protect consumer location...more

Wiley Rein LLP

Wiley Consumer Protection Download (February 26, 2025)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Lowenstein Sandler LLP

Privacy Implications of Real-Time Bidding – Lessons From the Mobilewalla Enforcement Action

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With advances in digital technology and consumers’ insatiable appetite for “free” content, the advertising technology industry (AdTech) has played a crucial role in delivering highly personalized ad campaigns to consumers...more

Wiley Rein LLP

Wiley Consumer Protection Download (February 12, 2025)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

White & Case LLP

Data Privacy Update

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California Bills, Rulemaking, and Enforcement Update - CPPA automated decision-making technology - On November 22, 2024, the California Privacy Protection Agency (CPPA) opened the formal public comment period on its...more

Wiley Rein LLP

10 Key Privacy Developments and Trends to Watch in 2025

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As we enter the New Year, Wiley is looking ahead to the top privacy developments and trends to watch in 2025. On the state side, 2025 kicked off with several new privacy laws going into effect in January, and states continue...more

WilmerHale

FTC Continues to Bring Enforcement Actions Against Data Brokers

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On December 3, 2024, the Federal Trade Commission (FTC) announced two enforcement actions against large data aggregator companies, Mobilewalla, Inc. (“Mobilewalla”) and Gravy Analytics Inc. (“Gravy Analytics”), for alleged...more

Holland & Knight LLP

New Proposed CFPB Consumer Data Regulation Would Significantly Expand FCRA Obligations

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The Consumer Financial Protection Bureau (CFPB) on Dec. 3, 2024, issued its long-awaited proposed rule to amend Regulation V (Proposed Rule), which implements the Fair Credit Reporting Act (FCRA). If enacted, the CFPB's...more

Holland & Knight LLP

FTC Cracks Down on Selling Sensitive Location Info, Restricts Use of Consumer Data for 1st Time

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The Federal Trade Commission (FTC) announced two significant enforcement actions last week – one against data broker Mobilewalla, Inc. and the other against data analytics provider Gravy Analytics, Inc. (and its subsidiary...more

Proskauer - New Media & Technology

Data At Issue: FTC Focus on Browsing Information and Location Data

Since the start of the year, the Federal Trade Commission (FTC) has brought actions against – and reached proposed settlements with – three business ventures engaged in the collection, use and sharing of certain consumer...more

WilmerHale

Recent Enforcement Actions Signal FTC Focus on Protecting Location Data

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On January 9, 2024, the Federal Trade Commission (FTC) issued its first ever prohibition on the use, sale and disclosure of sensitive location data against X- Mode Social and Outlogic (“X-Mode”), a location data broker. Only...more

Wyrick Robbins Yates & Ponton LLP

FTC Gives it to X-Mode: 5 Lessons from the Agency’s Latest Consumer Location Data Case

The FTC announced an action last week against location data broker X-Mode Social and its corporate successor Outlogic (collectively, “X-Mode”) based on several alleged violations of Section 5 of the FTC Act. According to FTC...more

Proskauer - New Media & Technology

In Amended Complaint, FTC Alleges Kochava, a Data Broker, Is Collecting, Using and Disclosing “Massive Amounts” of Precise...

The Federal Trade Commission (FTC) has long expressed a concern about the potential misuse of location data. For example, in a 2022 blog post, “Location, health, and other sensitive information: FTC committed to fully...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Orrick, Herrington & Sutcliffe LLP

District Court dismisses FTC’s privacy claims against data broker with leave to amend

On May 4, the U.S. District Court for the District of Ohio issued two separate rulings in a pair of related disputes between the FTC and a data broker. The disputes center around accusations made by the FTC last August that...more

Robinson+Cole Data Privacy + Security Insider

FTC Sues Data Broker for Selling Data from Reproductive Clinics and Places of Worship

In a complaint filed this week, the Federal Trade Commission (FTC) alleges that a data broker sold geolocation data from individuals showing their movements to and from sensitive locations, including reproductive health...more

Alston & Bird

California Attorney General’s Open Data Initiative – The Latest in State and Federal Government Efforts to Harness the Power of...

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Early this month, California Attorney General Kamala D. Harris announced a unique data initiative to expand the public’s access to key criminal justice information that has been, to date, largely blocked from public...more

King & Spalding

FTC Charges Data Broker With Facilitating Theft Of Millions From Consumer Accounts

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On December 23, 2014, the Federal Trade Commission ("FTC") announced the filing of a complaint charging a data broker with selling the sensitive personal information of hundreds of thousands of consumers to third parties that...more

Ballard Spahr LLP

FTC Continues Aggressive FCRA Enforcement against Data Brokers

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The Federal Trade Commission continues to aggressively enforce the Fair Credit Reporting Act (FCRA) against data brokers, as shown by its recent settlement with TeleCheck Services, Inc. The settlement requires TeleCheck to...more

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