Antony Kim

Antony Kim

Orrick, Herrington & Sutcliffe LLP

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Don’t Ignore Ransomware Vulnerabilities; You Could Be Violating FTC Act

Last week, the Federal Trade Commission convened a ransomware workshop to discuss the rising epidemic of attacks against U.S. businesses and individuals. In a ransomware attack, a malicious actor tricks a user into...more

9/15/2016 - Cyber Attacks Cybersecurity Data Breach DHS FTC FTC Act Hackers HHS Malware OCR PHI Popular Ransomware

FTC Makes Clear that NIST Cyber Framework is Not a Cure-All

Last week, the FTC published a blog post titled The NIST Cybersecurity Framework and the FTC, in which the agency issued a nuanced answer to an oft-asked question: “If I comply with the NIST Cybersecurity Framework, am I...more

9/12/2016 - Cybersecurity Cybersecurity Framework Data Protection Data Security Encryption FTC NIST Popular Risk Management Section 5

Biometrics: A Fingerprint for Privacy Compliance, Part I

In just the last week, the New York State DMV announced an upgrade to facial recognition software to catch identity thieves trying to obtain fraudulent driver’s licenses, and the Scottish Professional Football League was...more

3/4/2016 - Biometric Information Data Collection Data Protection Facial Recognition Technology FTC

EU-U.S. Privacy Shield is Go…nearly

On 29 February 2016 the European Commission issued the legal texts of the EU-U.S Privacy Shield which aims to replace the defunct EU-U.S Safe Harbor Framework as a legitimate mechanism for transferring personal data from the...more

3/2/2016 - EU EU-US Privacy Shield European Commission FTC International Data Transfers Personal Data Transparency US-EU Safe Harbor Framework

Safe Harbor 2.0: Political Agreement Reached – The EU-US Privacy Shield

The European Commission has announced that it has reached a deal to replace the EU-US Safe Harbor framework that was declared invalid last year by the Court of Justice of the European Union (“ECJ”). Heralded as the EU-US...more

2/3/2016 - Article 29 Working Party (WP29) Data Protection EU EU-US Privacy Shield FTC International Data Transfers Ombudsman Personal Data Popular Safe Harbors

FTC Enforcement in Schein: Misleading Statements about Encryption and Cybersecurity

On January 5, 2015, the Federal Trade Commission (FTC) entered into a consent order with dental software manufacturer Henry Schein Practice Solutions, Inc. ("Schein") in connection with allegations that Schein had made...more

1/26/2016 - Cybersecurity Dental Practice Encryption FTC HIPAA Misleading Statements Popular Software Developers

FTC/FCC MOU: Even the Justice League Needs It In Writing

On November 13, 2015, the Federal Trade Commission and the Federal Communications Commission entered into a Memorandum of Understanding to address coordination of consumer protection actions by each agency. Following a wave...more

11/30/2015 - Collaboration Common Carriers Data Security FCC FTC Popular

Third Circuit to Wyndham (Part II): "Deceptive" is also "Unfair" in the Cybersecurity Context

In Part I, we discussed the Third Circuit's finding that the "unfair" prong of the FTC Act does not require the agency to provide specific cybersecurity standards with "ascertainable certainty" to which companies must...more

9/11/2015 - Cybersecurity FTC FTC v Wyndham Hackers Misleading Statements Privacy Policy Public Statements Unfair or Deceptive Trade Practices Wyndham

Third Circuit to Wyndham (Part I): It's "Fair" that FTC Did Not Articulate Specific Cybersecurity Standards in Enforcement Action...

On Monday, the Third Circuit issued a highly anticipated opinion affirming the Federal Trade Commission's authority to regulate "unfair" cybersecurity practices under Section 5 of the FTC Act. In allowing the data breach...more

8/27/2015 - Credit Cards Cyber Attacks Cyber Crimes Cybersecurity Data Breach Data Protection Data Security Debit Cards Enforcement Actions Fraudulent Charges FTC FTC v Wyndham Hackers Section 5 Wyndham

FTC Puts "Standalone" Section 5 Enforcement Approach on the Record

For the first time in its 101-year history, the Federal Trade Commission recently issued a policy statement outlining the extent of its authority to police "unfair methods of competition" on a "standalone" basis under Section...more

8/17/2015 - Antitrust Investigations DOJ FTC Rule-of-Reason Analysis Section 5 Sherman Act Standalone Authority The Clayton Act Unfair Competition

EU/Swiss-U.S. Safe Harbor: More Scrutiny by the FTC?

On May 29, 2015, the Federal Trade Commission ("FTC") announced the approval of the final orders for two U.S. companies, TES Franchising, LLC ("TES") and American International Mailing, Inc. ("AIM"), settling complaints that...more

6/22/2015 - Arbitration Binding Corporate Rules Compliance Data Protection Dispute Resolution EU FTC Germany International Data Transfers Mediation Safe Harbors Section 5 Switzerland U.S. Commerce Department UK Unfair or Deceptive Trade Practices

Roadmap Offers Important Insights on How to Prepare for FTC Data Breach Investigations

On May 20, 2015, Federal Trade Commission Assistant Director Mark Eichorn of the Bureau of Consumer Protection’s Division of Privacy and Identity Protection (DPIP) offered an inside look into the FTC’s investigative process...more

5/28/2015 - Assessment Data Breach Enforcement Actions FTC Internal Investigations Privacy Policy

FTC Assesses $800,000 Fine Against Mobile App Operator and Issues Mobile Privacy and Security Guidance

The Federal Trade Commission has emphasized in the past that general privacy protections in the website space apply equally to mobile services, but a new FTC Staff Report released on Friday hones in on some privacy...more

2/11/2013 - Address Book App Developers COPPA Data Collection Data Protection FTC Mobile Apps Notice Requirements Parental Consent Path Inc. Personally Identifiable Information Privacy Policy Settlement Social Networks Transparency

Recent Privacy Developments: California AG Continues to Lead on Mobile with New Recommendations and FTC Amends COPPA

Nearly all businesses today are involved in some way in the development or distribution of mobile applications. The first part of this Client Alert highlights recent activities of the California State Attorney General to...more

1/15/2013 - Advertising App Platform Providers Attorney Generals COPPA Data Collection Enforcement FTC Kamala Harris Mobile Apps Mobile Ecosystems Notice Requirements Online Privacy Protection Act Parental Consent Personally Identifiable Information Privacy Policy

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