Privacy & Cybersecurity Update - April 2014

In This Issue:

- Decision in Wyndham Case Provides FTC With Significant Victory

- SEC Announces Cybersecurity Initiative

- Heartbleed Bug Generates Significant Security Concerns

- FTC and DOJ Announce Policy Regarding the Sharing of Cyber Threat Information

- Key Developments in State Data Breach Notification Laws

- EU Court of Justice Strikes Down Data Retention Directive

- EU Introduces Processor to Sub-Processor Model Contract

- EU Article 29 Expands Data Breach Notification Requirements

- Steps Taken Toward ‘Do-Not-Track’ System

- Comptroller of the Currency Stresses Importance of Cybersecurity


In a much-anticipated decision with potentially broad implications, a district court denied Wyndham Hotels and Resorts, LLC’s motion to dismiss a Federal Trade Commission enforcement action alleging that Wyndham had violated Section 5 of the Federal Trade Commission Act as a result of a cybersecurity attack. Judge Esther Salas’ April 7, 2014, decision in FTC v. Wyndham Worldwide Corporation, et al.,1 addresses the scope of the FTC’s authority over cybersecurity at a time when it is taking a greater enforcement role in such incidents and privacy more generally...

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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