Rebecca Engrav

Rebecca Engrav

Perkins Coie

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Latest Publications


FTC Theory of Unrealized Consumer Injury Rejected in LabMD Data Security Case

In what could be a major setback for the Federal Trade Commission (FTC) in the data security arena, an Administrative Law Judge (ALJ) has ruled that an unfairness claim brought by the FTC under Section 5 of the FTC Act...more

11/17/2015 - Data Security FTC LabMD Personally Identifiable Information Section 5

Third Circuit Affirms FTC Authority to Police Whether Companies Have Reasonable Data Security

Since at least 2005, the Federal Trade Commission has asserted that it may regulate lax data security practices as an “unfair” business practice under Section 5 of the FTC Act. The Wyndham hotel chain was the first to...more

8/27/2015 - COPPA Credit Cards Cyber Attacks Cyber Crimes Cybersecurity Data Breach Data Protection Data Security Debit Cards FCRA Fraudulent Charges FTC FTC Act FTC v Wyndham Hackers Personally Identifiable Information Popular SCOTUS Section 5 Unfair or Deceptive Trade Practices Wyndham

Federal Court Holds That FTC May Regulate Company Data Security Practices

In a closely watched and first-of-its-kind case, the U.S. District Court for the District of New Jersey rejected, for purposes of a motion to dismiss, a defendant company’s argument that the Federal Trade Commission (FTC)...more

4/10/2014 - Data Protection FTC Jurisdiction Wyndham

New Self-Regulatory Rules For Mobile Apps: What Your Company Needs To Know

Even as efforts to achieve industry-wide consensus on Do Not Track appear to be stalling, self-regulatory associations are forging ahead with their own rules governing online and mobile data collection....more

7/31/2013 - Data Collection Digital Advertising Alliance Do Not Track Marketing Mobile Apps

The New COPPA Rule Takes Effect Today — Are You Ready?

In December 2012, the Federal Trade Commission (FTC) adopted final amendments to the Children's Online Privacy Protection Act (COPPA) Rule, which regulates how companies may collect information online from children under 13. ...more

7/1/2013 - COPPA Data Protection FTC Parental Consent Personally Identifiable Information

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