FTC v Wyndham

News & Analysis as of

Not Just Heads In Beds – Cybersecurity for Hotel Owners

The basics of the hotel business have traditionally been simple: good location, fair prices, appropriate amenities and good service were the keys to success. While those factors are important today, hotels are no longer...more

Wyndham Settles with FTC

Last month, Wyndham Worldwide Corp. settled its lengthy civil case with the Federal Trade Commission. The suit began in 2012, when the FTC sued Wyndham and three of its subsidiaries, alleging three data breaches between 2008...more

FTC and Wyndham Settle Suit Regarding Wyndham's Alleged Cybersecurity Failures

On December 9, 2015, the Federal Trade Commission (the "FTC") and Wyndham Worldwide Corporation (and three additional Wyndham entities, collectively, "Wyndham") filed a stipulated order ("Stipulated Order") settling their...more

Reading the Section 5(a) Tea Leaves: What the end of 2015 may suggest about the FTC priorities in 2016

The end of 2015 represented a mixed bag for the Federal Trade Commission on privacy enforcement. In November, the FTC’s Chief Administrative Law Judge dismissed the FTC’s complaint against LabMD for a possible data breach of...more

Advertising Law - January 2016

Ending Challenge to FTC's Data Security Authority, Wyndham Settles - In a significant development, Wyndham Hotels and Resorts reached a deal with the Federal Trade Commission in the high-profile litigation that began...more

Lessons Learned from LabMD's Successful Challenge to the FTC's Cyber Authority and Wyndham's Monumental Settlement with the FTC

On the shifting sands of cyber security regulation, it is important to understand the outcome of two recent enforcement cases brought by the Federal Trade Commission (FTC) – one against clinical lab services company LabMD,...more

The Digital Download - Privacy & Data Security Monthly Newsletter - January 2016

Senior Counsel Peter Swire to Debate European Privacy Activist Max Schrems. The debate, set to take place on January 26 in Brussels, will highlight key differences between certain European and U.S. attitudes towards U.S....more

“We’ve Been Hacked!”—New Developments in Cyber-Security Litigation

February’s Business Litigation Report advised clients that they could prepare for potential data breaches by conducting readiness audits and preparing cyber incident response plans. (See Traversing the Breach, February 2015.)...more

LabMD and Wyndham Decisions Curtail FTC’s Data Privacy and Security Reach

Both the administrative law judge’s decision in LabMD and the Third Circuit’s recent decision in Wyndham, which we previously blogged about, put the FTC on notice that it cannot assume that in the wake of a security breach,...more

Privacy & Cybersecurity Update - December 2015

In this edition of our Privacy & Cybersecurity Update, we provide a detailed summary of the sweeping changes to be imposed by the European Union’s new data protection regulation, which will require many companies to begin...more

Wyndham and FTC Agree to Consent Order Ending Data Security Breach Litigation

On Friday, December 11, 2015, the U.S. District Court for the District of New Jersey entered a consent order between the Federal Trade Commission (“FTC”) and hospitality company Wyndham Hotels and Resorts, LLC (“Wyndham”)...more

Information Security and Privacy News: Critical Cybersecurity Policies and Practices After the Settlement Order in FTC v. Wyndham...

Companies are threatened daily by attacks that expose customer credit card and other information stored on company servers, personal computers and other devices. It is, therefore, critical that companies do these three...more

What the FTC’s Settlement With Wyndham Means for Your Company

The recent settlement entered into between the Federal Trade Commission (FTC) Wyndham Hotels and Resorts and related companies (Wyndham) provides an important roadmap for companies seeking to avoid running afoul of the FTC’s...more

FTC and Wyndham Call a Truce

Following the Third Circuit’s ruling upholding the FTC’s authority to regulate unfair and deceptive cybersecurity practices under Section 5 of the FTC Act, Wyndham Worldwide Corporation and the FTC have agreed to settle. ...more

Landmark Wyndham Settlement Provides Guidelines For Companies To Meet FTC’S Datasecurity Requirements

On December 9, Wyndham Hotels and Resorts (“Wyndham”) agreed to a landmark settlement with the Federal Trade Commission (“FTC”) stemming from the FTC’s lawsuit against it after three data breaches that occurred between 2008...more

Wyndham Agrees to Settle FTC Data Security Case

After four years of litigation, this past Wednesday, Wyndham Worldwide Corporation and three of its subsidiaries (collectively, “Wyndham”) settled the Federal Trade Commission’s (“FTC”) allegations that the global...more

Long and Wyndham Road: The Federal Trade Commission Extends Section 5 Unfairness to Regulate Data Security

In a surprising development, Wyndham Worldwide Corporation settled a long running dispute last week with the Federal Trade Commission that arose from three data breaches Wyndham suffered between 2008-2010. After an...more

Wyndham and FTC Settle Case Over “Unfair” Data Security Practices

The years-long saga of the Federal Trade Commission’s suit against Wyndham Hotels over data breaches that occurred at least as early as April 2008 is finally coming to an end with a proposed settlement filed today with the...more

FTC and Wyndham Settle Data Security Allegations

On December 9, 2015, the Federal Trade Commission announced that Wyndham Worldwide Corp., Wyndham Hotel Group LLC, Wyndham Hotels and Resorts, LLC, and Wyndham Hotel Management, Inc. (“Wyndham”) had agreed to settle FTC...more

The FTC’s Proposed Wyndham Settlement and its Implications for the Regulatory Landscape

On December 9, 2015, the Federal Trade Commission (FTC), with the agreement of Wyndham Hotels and Resorts (“Wyndham”), filed a stipulated order for injunction (“Consent Order”) in the U.S. District Court for the District of...more

Wyndham and FTC Settle Data Breach Lawsuit: Implications

On December 9, 2015, Wyndham and the FTC settled the enforcement action brought by the FTC that had led to a significant decision by the Third Circuit in August of this year. While the details of the settlement are...more

Wyndham settles with FTC

We have been following the hard fought case between the FTC and Wyndham over an investigation that was launched by the FTC following a series of data breaches of Wyndham’s payment card information between 2010 and 2012 (see...more

Look for an increase in shareholders’ suits in 2016

A new study released by NYSE Governance Services and security firm Veracode, “Cybersecurity and Corporate Liability: The Board’s View,” is a must read for directors and officers. Veracode was quite accommodating when I asked...more

Wyndham Ruling Reinforces FTC's Role in Cybersecurity Regulation

In Federal Trade Commission v. Wyndham Worldwide Corporation, the United States Court of Appeals for the Third Circuit held that the Federal Trade Commission (FTC) has authority to regulate cybersecurity under 15 U.S.C. §...more

Which Way is the “Wyndham” Blowing? Cyber Regulation After FTC vs. Wyndham

Does the Third Circuit’s recent decision in FTC v. Wyndham Worldwide Corp. usher in a new era of enforcement by the FTC and other federal agencies regarding cybersecurity practices? Regardless of the answer, it is important...more

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