The Securities and Exchange Commission’s cybersecurity-related case against SolarWinds and its CISO was largely dismissed, but a securities fraud claim against the CISO lives on. Our Securities Litigation, Privacy, Cyber &...more
7/26/2024
/ CEOs ,
CFOs ,
Chief Information Security Officer (CISO) ,
Cybersecurity ,
Cybersecurity Framework ,
Misleading Statements ,
NIST ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
SolarWinds
On June 24, 2024, the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued five new Compliance and Disclosure Interpretations (“C&DIs”) related to the disclosure of “material”...more
7/11/2024
/ Corporate Governance ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Form 8-K ,
Publicly-Traded Companies ,
Ransomware ,
Reporting Requirements ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
Does the R.R. Donnelley settlement mean heightened Securities and Exchange Commission (SEC) involvement in regulating public companies’ cybersecurity policies and practices? Our Securities Litigation, Privacy, Cyber & Data...more
7/2/2024
/ Cease and Desist Orders ,
Cybersecurity ,
Data Security ,
Disclosure ,
Enforcement Actions ,
Ransomware ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Regulation ,
Sensitive Personal Information ,
Settlement
On May 22, 2024, the Director of the Division of Corporation Finance (“Corp Fin”) of the Securities and Exchange Commission (“SEC”) issued further guidance regarding disclosure of cybersecurity incidents on Form 8-K. The...more
New regulations continue to push boards in the direction of active engagement in their cyber oversight role, including breach response. But, how can boards strike the right balance in their oversight role during a significant...more
Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s final changes to its cybersecurity reporting rules for public companies...more
Observers have been awaiting decisions in a number of cybersecurity and privacy securities fraud class actions with potentially important implications for corporate liability. Over the last several weeks, critical...more
4/4/2022
/ Alphabet Company ,
Corporate Counsel ,
Corporate Liability ,
Cybersecurity ,
Disclosure Requirements ,
Failure To Disclose ,
Google ,
Popular ,
Risk Management ,
Securities Fraud ,
Shareholders ,
Zoom®
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s latest sweeping changes to its cybersecurity reporting rules for public...more
3/16/2022
/ Corporate Governance ,
Cyber Incident Reporting ,
Cybersecurity ,
Disclosure Requirements ,
Form 10-Q ,
Form 8-K ,
Publicly-Traded Companies ,
Regulation S-K ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
A California federal court has dismissed a putative securities fraud class action alleging that a large title insurer that disclosed a data security incident in May 2019 made false and misleading statements related to its...more
In early July, investigations by a Chinese cybersecurity regulatory agency, the Cyberspace Administration of China (“CAC”), into at least three China-based technology companies—DiDi Global Inc. (“DiDi”), Full Truck Alliance...more
The Securities and Exchange Commission’s $35 million settlement with Altaba Inc., the successor in interest to Yahoo! Inc., is the first civil penalty of its kind for a data breach and underscores the agency’s increasing...more
The Securities and Exchange Commission (SEC) issued a press release announcing its unanimous approval of a statement by SEC Chairman Jay Clayton and interpretive guidance (the “2018 Guidance”) to assist public companies in...more
SEC Chairman Jay Clayton issued a public statement on Cybersecurity (the “Clayton Statement”) last week, disclosing a 2016 attack on the SEC’s database of corporate filings. The intrusion exploited a vulnerability in the test...more
Participating in a panel at the “SEC Speaks” event on February 19, Deputy Director of the SEC’s Enforcement Division Stephanie Avakian expressed that the Commission continues to focus on cybersecurity as a top priority in...more