David Cohen

David Cohen

Ropes & Gray LLP

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Latest Publications


ALJ Dismisses FTC Data Security Claims Against LabMD Due to Lack of Actual or Likely Substantial Consumer Harm

On November 13, a Federal Trade Commission administrative law judge dismissed the FTC data security complaint against medical laboratory LabMD, potentially vindicating LabMD’s vigorous two-year struggle to deny the FTC’s...more

11/25/2015 - ALJ Data Breach FTC LabMD Section 5

FCC Expands Its Claim of Data Security Authority with Recent Enforcement Action Against Cox Communications

Last week, the Federal Communications Commission (“FCC”) reached a settlement with Cox Communications, Inc. (“Cox”) regarding a 2014 data security breach that allegedly exposed the personal information of at least 54 current...more

11/16/2015 - Consent Decrees Cox Communications Customer Proprietary Network Information (CPNI) Data Breach Enforcement Actions FCC Popular

Nomi FTC Settlement Highlights Risks of Publicizing Company Privacy Policies

A closely divided Federal Trade Commission (“FTC” or the “Commission”) has signaled support for the agency’s recent focus on mobile device privacy. On April 23, 2015, the five-member Commission voted 3-2 to accept a proposed...more

5/21/2015 - Consent Order Corporate Counsel Data Collection FTC Misrepresentation Mobile Privacy Nomi Technologies Opt-Outs Prior Express Consent Privacy Laws Retailers Section 5

PCI SSC Releases Version 3.1 of Data Security Standard

On April 15, 2015, the Payment Card Industry Security Standards Council (the “PCI SSC” or “Council”) released a new version of its Data Security Standard (“PCI DSS”), version 3.1, which contains numerous updates including,...more

5/20/2015 - Cybersecurity Debit and Credit Card Transactions Encryption Payment Processors PCI-DSS Standard

FCC Action Against AT&T Reflects Regulator’s Increasing Focus on Privacy and Data Security

In the wake of the Federal Communications Commission’s (“FCC’s”) first-ever foray last October into fining companies over data security practices, the agency’s Enforcement Bureau Chief, Travis LeBlanc, asserted that the...more

4/24/2015 - AT&T Data Breach Enforcement Actions FCC Open Internet Rules Regulatory Agenda

FTC Complaint Against Medical Laboratory Signals Agency’s Continued Intent to Assert Authority in Data-Security-Breach Actions

In taking action against medical laboratory LabMD, the U.S. Federal Trade Commission demonstrated its continued intent to assert authority through the Federal Trade Commission Act in data-security-breach actions. On August...more

9/11/2013 - Clinical Laboratories Compliance Data Breach Data Protection Enforcement Actions FTC Medical Research

FTC Actions Against Payment Processors Heighten Legal Risks for Service Providers in Privacy Cases

In taking action against two payment processors earlier this month for providing processing services to merchants allegedly engaged in deceptive telemarketing practices, the U.S. Federal Trade Commission demonstrated a broad...more

6/28/2013 - FTC Payment Processors Telemarketing Telemarketing Sales Rule Third-Party

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