DE Under 3: Court Held That Workday Was an “Agent” to Employers Licensing its AI Applicant Screening Tools
Business Associates Here, There, and Everywhere: When Does Your Service Provider Really Need to Sign a HIPAA Business Associate Agreement?
In House Counsel: How To Measure the Effectiveness of Your Staffing Strategy
Sitting with the C-Suite: Identifying Opportunities to Leverage Human Capital
The CCPA for the Land Title Industry: Service Providers and Sale of Data Under the CCPA
Podcast - Risk Management: Troubleshooting & Problem Solving
Cybersecurity in the investment management industry
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Special Report: The Hot-ish Swag at LegalTech New York 2015
On August 21, 2025, the Consumer Financial Protection Bureau filed an enforcement action in connection with Chapter 11 bankruptcy proceedings for a fintech (the "Fintech") acting primarily as a third-party service provider...more
On April 25, 2024, the FTC announced that it filed a suit against a Washington-based third-party bill payment company and two of its chief executives for engaging in allegedly deceptive and misleading practices in...more
In the evolving world of lead generation and performance-based customer acquisition, the quest for profits can lead to big legal risks, some of them too large for advertisers that buy leads through third parties. Advertisers...more
On December 19, 2023, the Federal Trade Commission (FTC) announced an enforcement action against the retail pharmacy Rite Aid for unfair practices associated with its use of a facial recognition technology (FRT) surveillance...more
On September 11, the FTC announced that it had reached a settlement with two “people-search” companies which would resolve charges that the companies had engaged in practices that violated the Fair Credit Reporting Act...more
On July 17, 2023, the Innovation, Cybersecurity and Technology (H) Committee of the National Association of Insurance Commissioners (NAIC) released for comment a highly anticipated model bulletin (Model Bulletin) on...more
The use of consumer reviews as a marketing strategy has grown exponentially in recent years, and brands have become increasingly reliant on consumer reviews as a marketing strategy to drive consumer purchase behavior. In...more
Third-Party Review Services are a Focus- On January 25, the Federal Trade Commission announced that Fashion Nova LLC will be prohibited from suppressing customer reviews of its products and required to pay $4.2 million to...more
Turo is an Airbnb service for cars. Technically, it is a peer-to-peer car rental marketplace. It does not control the terms of the car rental. But it does bring owners and renters together....more
The Federal Trade Commission (FTC) recently released updated data security guidance in connection with a proposed settlement with LightYear Dealer Technologies, LLC (dba DealerBuilt), a service provider for the auto dealer...more
In Hansen v. Group Health Cooperative, 2018 U.S. App. LEXIS 25033, (9th Cir. Sep. 4, 2018), two psychotherapists (“Providers”) sued Group Health Cooperative (“GHC”) in Washington state court, alleging GHC engaged in unfair...more
The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more
On June 12, 2017, the Supreme Court decided Henson v. Santander Consumer USA Inc., No. 16–349, holding that a company may collect debts that it purchased for its own account without triggering the statutory definition of...more
The U.S. Supreme Court in Henson v. Santander Consumer USA, Inc., 2017 WL 2507342, ruled that purchasing and then collecting a defaulted debt does not, standing alone, make an entity a “debt collector” as defined by the Fair...more
Yesterday, the Supreme Court of the United States issued its opinion in Henson v. Santander Consumer USA, Inc.—Justice Gorsuch’s first as a Supreme Court Justice. The question presented was whether “individuals and entities...more
In this month's Privacy & Cybersecurity Update, we review an 11th Circuit case involving the longstanding battle between the FTC and medical company LabMD, recent NIST guidelines for securing devices connected to the...more
The Consumer Financial Protection Bureau’s (“CFPB”) lawsuit against payment processor Intercept Corporation remains pending, and recent briefing sheds light on what could result in broad implications for the payment...more
Tucked away in a seeming innocuous paragraph in a complaint, the Consumer Financial Protection Bureau (CFPB) has asserted an extraordinary and potentially far-reaching expansion of its authority. On June 6, 2016, the...more
A federal court recently held that the plaintiff’s claims under state law survived ERISA preemption, and remanded the case to state court to determine the plaintiff’s claims for invasion of privacy and unfair business...more
Today we’re taking a look at the CFPB’s recent enforcement case against Citibank, N.A. (“Citibank”) and two of Citibank’s subsidiaries, Department Stores National Bank (“DSNB”) and Citicorp Credit Services, Inc. (USA) (“CCSI...more