On December 1, 2010, the Federal Trade Commission (“FTC”) released a report entitled “Protecting Consumer Privacy in an Era of Rapid Change” (the “FTC Report”), available at http://www.ftc.gov/ os/2010/12/101201privacyreport.pdf. The FTC Report, which proposes a new framework for protecting consumer privacy, is intended to inform policy makers, as they develop policies and enact privacy-related laws, and to guide and motivate businesses, as they develop and implement best practices and self-regulatory guidelines. The FTC Report raises numerous very interesting and complex policy and practical questions for which the FTC is seeking comment by January 31, 2011. The FTC intends to issue a final report later this year.
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