William Carleton

Letter to FTC Opposing Proposed Settlement with Facebook

This is a letter to the FTC posted at its online page for public comment on the proposed settlement agreement with Facebook. Because no factual record has been established on which to base a settlement, the letter opposes it…more

| Administrative Law, Consumer Protection, Privacy

Redline Showing Changes to Twitter API TOS (June 2010 to March 2011)

Twitter announced changes on March 11, 2011, to the "rules of the road" for its community of independent developers. This announcement has been controversial. The purpose of this redline is to pin down precisely what has changed…more

| Commercial Law & Contracts, Intellectual Property
S.3804 - Combating Online Infringement...

Changes between bill introduced 09-20-10 and bill reported 11-18-10

This is a redline that shows the difference between Senator Leahy's "Combating Online Infringement and Counterfeits Act," as introduced in September 2010, and the same bill as reported on November 18, 2010. Unfortunately, the…more

| Communications & Media Law, Intellectual Property

Prospective Changes to Google Privacy Policy

This redline shows changes Google proposes to make to its general privacy policy, to be effective in October. The changes are marked against the current privacy policy dated March 11, 2009…more

| Privacy

Changes to Foursquare Privacy Policy - May to August 2010

Foursquare made some subtle but significant changes to its privacy policy. I think this is a sign that social media platforms are figuring out how better to approach setting privacy expectations with users. I will blog on this…more

| Privacy

Changes between Bond Amendment and Version Passed by Senate

The US Senate acted last night to strip the financial regulatory reform bill of the provisions in it (Section 412 and 926) that would have devastated startup seed financing and angel investing in America. Hooray!!! The amendment…more

| Securities Law
Amendment to Save Startup Seed...

SA 4037

This is a critical amendment to Sen. Dodd's financial regulatory reform bill. This amendment would save angel investing in America and also preserve the ability of entrepreneurs to raise modest amounts of seed capital using a…more

| Securities Law
Restoring American Financial Stability...

Amendment to Save Angel Financing

This amendment to Section 926 of Sen. Dodd's financial regulatory reform bill, the Restoring American Financial Stability Act of 2010, would save angel financing for start up companies, while reforming Rule 506 of Regulation D…more

| Finance & Banking, Securities Law
Skype Stock Option Controversy

SKYPE GLOBAL S.À R.L. EQUITY INCENTIVE PLAN

Skype filed its option plan -- it would appear to be the very one subject to the recent controversy over Skype employees whose stock, from the exercise of vested options, was subject to repurchase at cost -- with the SEC as part…more

| Securities Law

What Happened to the 1x Liquidation Preference

Liquidation preferences in venture capital investments have moved north of 1x lately. Is this trend wise, either for investors or early stage companies? This brief post discusses the point and links to other discussions on how…more

| Business Organizations, Finance & Banking, Science, Computers, &...

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