Emily Tabatabai

Emily Tabatabai

Orrick, Herrington & Sutcliffe LLP

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Latest Posts › FTC


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

Mobile Apps Remain Regulatory Focus as FTC Enforces Data Privacy of Popular Program

The provider of the immensely popular “Brightest Flashlight Free” mobile app for Android reached a settlement with the Federal Trade Commission (FTC) over charges that it collected sensitive personal information, including...more

12/9/2013 - Data Collection Data Protection Disclosure Requirements Enforcement Actions FTC Mobile Apps Personally Identifiable Information Settlement Terms of Use

FTC Dot Com Disclosure Update: What's New for 2013

In March, the Federal Trade Commission issued updated advertising guidelines to take into account the challenges created by the rapid growth of mobile and online advertising platforms, particularly small screen size and other...more

4/24/2013 - Advertising Disclosure Requirements Dot Com Disclosure Guide FTC Mobile Devices Unfair or Deceptive Trade Practices

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

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