Karen H Bromberg

Karen H Bromberg

Cohen & Gresser LLP

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Encryption is Key to Limiting Company Exposure for Data Security Breaches

Companies doing business in California may find themselves targeted for investigation if they fail to encrypt personal information, according to a recent report issued by the California Attorney General’s office. ...more

7/9/2013 - Breach Notification Rule Cybersecurity Data Breach Data Protection Employer Liability Issues Encryption Identity Theft Loss Mitigation Passwords

FTC’s Authority to Police Data Security Practices Challenged

Hotelier Wyndham Worldwide Corp’s motion to dismiss an FTC lawsuit alleging lax data security practices is likely to have significant implications for the agency’s ability to police cybersecurity practices at American...more

6/11/2013 - Credit Cards Cybersecurity Data Breach Data Protection FTC Motion to Dismiss Personally Identifiable Information Wyndham

For Small Business Owners, Cybersecurity Is Not a Question of "If" But 'When..."

While much of the discussion around cybersecurity tends to focus on critical information sectors, national security, and the concerns of global corporations, data breaches can be just as devastating for small and medium-sized...more

5/31/2013 - Cyber Attacks Cyber Insurance Cybersecurity Data Breach Data Protection Legal Perspectives Personally Identifiable Information Small Business

Berlin Court Rules that Apple's Privacy Policy Violates German Data Protection Laws

A Berlin court ruled that eight clauses in Apple Sales International's (“Apple”) standard data use policy, which covers how the company can share data, do not comply with Germany’s privacy protection laws and enjoined Apple,...more

5/30/2013 - Apple Consent Data Collection Data Protection EU EU Data Protection Laws

FTC Recommends Stronger Safeguards for Mobile Payments

With the use of mobile payments by consumers reaching “fever pitch”, the FTC has released a new report entitled, “Paper, Plastic… or Mobile? An FTC Workshop on Mobile Payments,” discussing how companies can develop mobile...more

4/18/2013 - Data Protection FTC Mobile Payments Privacy Concerns Privacy-By-Design

Taming the Wild West: FTC Report Urges Mobile App Industry to Adopt Strong Privacy Measures

App providers and developers are in the hot seat again. On the same day that the FTC fined the social networking app Path $800,000 over allegations that it collected personal information without obtaining consumers’ consent,...more

2/11/2013 - App Developers Dashboard Data Collection Data Protection Do Not Track FTC Mobile Apps Mobile Ecosystems Personally Identifiable Information Privacy Policy

FTC Fines Path Mobile Social Networking App $800,000 for Privacy Breaches

The developer of the popular Path social networking app for mobile devices has agreed to settle Federal Trade Commission charges that it deceived users by collecting their personal information without their consent. As part...more

2/4/2013 - COPPA Data Breach Data Collection Fines FTC Mobile Apps Privacy Policy Settlement Social Networks Unfair or Deceptive Trade Practices

FFIEC Proposed Guidance on Social Media Risk Management: Practice Points for All Organizations Using Social Media

Organizations using social media are confronted with an ever increasing challenge of social media risk management. To help financial institutions identify, measure, monitor, and control such risks, the Federal Financial...more

1/30/2013 - Audits Due Diligence FFIEC Financial Institution Liability Risk Management Social Media Social Media Policy Training

US Tech Companies May Soon be Required to Report Security Breaches to the EU

U.S. based tech companies that store data on the Internet may soon be required to report the loss or theft of personal information to the E.U. or face sanctions and fines according to legislation being proposed by the...more

1/23/2013 - Cloud Computing Data Breach Data Protection Databases E-Commerce EU European Commission Personally Identifiable Information Reporting Requirements Social Networks Technology

USPTO Soliciting Comments on Software Patent Issues

The United States Patent and Trademark Office announced its intent earlier this month to form a “Software Partnership” with the software community in order to enhance the quality of software-related patents (the “Notice”)...more

1/21/2013 - Patents Software USPTO

Mobile App Disclaimers Not Sufficient to Circumvent FCRA Requirements

The Federal Trade Commission reached a settlement last week with a mobile app company, its data provider, and their CEO in its first Fair Credit Reporting Act (“FCRA”) enforcement action involving mobile applications. The...more

1/18/2013 - Advertising Criminal Background Checks Disclaimers Enforcement Actions FCRA FTC Mobile Apps Notice Requirements Settlement

California’s Attorney General Releases Privacy Recommendations for Mobile Apps

California’s Attorney General released, on January 10, 2013, a lengthy set of recommended privacy practices aimed at app developers, app platform providers, mobile ad networks, operating system developers, and mobile...more

1/11/2013 - Attorney Generals Data Collection Delta Airlines Kamala Harris Mobile Apps Online Privacy Protection Act Personally Identifiable Information Privacy Policy

Effective Data-Use Policies Can Have “Far-Reaching” Benefits in Cracking Down on Employee Cyber Theft

In a decision that could make it easier for U.S. companies to enforce claims against employees who commit cyber theft from remote locations, including from beyond U.S. borders, the Second Circuit breathed life into a...more

1/9/2013 - Cross-Border Cybersecurity Cybertheft Data Use Policies Email Employee Handbooks Misappropriation Personal Jurisdiction Trade Secrets Unauthorized Access

FTC Consent Order Illustrates Importance of Privacy Policy Disclosure and Adherence

The importance of fully disclosing (and abiding by) your company’s privacy policies was underscored last month when the U.S. Federal Trade Commission issued a consent order barring Epic Media Group, LLC, an online advertising...more

1/8/2013 - Behavioral Advertising Browser History Sniffing Consent Order Data Collection Disclosure Requirements Epic FTC Privacy Policy Technology

Instagram Retreats on Privacy Policy Change but Gets Sued Anyway

Photo-sharing app Instagram announced last Thursday, December 20, 2012 that it will withdraw one of its recent changes to the site's privacy policy following a public backlash. The withdrawn language explicitly permitted...more

12/28/2012 - Advertising Class Action Consent Instagram Privacy Policy Terms of Use Third-Party

Fashion Week in the Second Circuit: A Win-Win for Louboutin and YSL

Both Christian Louboutin and Yves Saint Laurent have claimed victory in the Second Circuit's much anticipated decision in Christian Louboutin SA v. Yves Saint Laurent America Holding Inc., decided on September 5, 2012. And in...more

9/20/2012 - Christian Louboutin Trademarks

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