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The Federal Trade Commission (FTC) and the U.S. Department of Health and Human Services' Office for Civil Rights (OCR) recently published a warning letter that they jointly sent to more than 130 hospital systems and...more
The Federal Trade Commission (FTC) adopted a policy statement on Sept. 15, 2021, emphasizing that developers of digital health apps, connected devices and other health products have obligations under the Health Breach...more
On July 1, 2021, the Federal Trade Commission (FTC) announced that it settled allegations against Toronto-based Kuuhuub Inc., along with Kuuhuub's Finnish subsidiaries Kuu Hubb Oy and Recolor Oy (together, defendants), that...more
The Federal Trade Commission (“FTC”) released an updated version of its guidance on complying with the Children’s Online Privacy Protection Act (“COPPA”) on June 21, 2017. Companies that collect personal information from...more
The demand for subscription-based and recurring revenue business models is growing faster than ever. According to a 2014 report by The Economist Intelligence Unit, 80 percent of customers are demanding new consumption models...more
On July 24, 2013, the Digital Advertising Alliance (DAA), comprised of the largest media and marketing trade associations in the U.S., released new guidance regarding mobile and other devices (Mobile Guidance). The Mobile...more
Lawmakers in Washington, D.C., continue to show interest in understanding and developing regulatory proposals relating to mobile apps. The interest appears to be driven, at least in part, by policymakers’ concerns about...more
The Federal Trade Commission has emphasized in the past that general privacy protections in the website space apply equally to mobile services, but a new FTC Staff Report released on Friday hones in on some privacy...more
On February 1, 2012, “smart journal” application provider, Path, Inc. (“Path”) agreed to settle Federal Trade Commission (“FTC”) charges that it deceived consumers and improperly collected personal information in violation of...more
On February 1, 2013, the Federal Trade Commission (FTC) announced a settlement with Path, Inc., a social networking mobile application developer. Path offers and distributes "smart journal" mobile apps, which permit users to...more
The FTC announced a potentially groundbreaking settlement with the social networking app Path and released an important new staff report on Mobile Privacy Disclosures late last week. The FTC’s Settlement with Path...more
In December 2012, the Federal Trade Commission (FTC) issued updated rules to the Child's Online Privacy Protection Act (COPPA), which significantly expand COPPA's scope and application. COPPA, which governs the collection,...more
After a two-year comment process, the Federal Trade Commission adopted its long-awaited amendments to the Children's Online Privacy Protection Rule in December 2012. The amendments, which go into effect July 1, 2013,...more
The Federal Trade Commission reached a settlement last week with a mobile app company, its data provider, and their CEO in its first Fair Credit Reporting Act (“FCRA”) enforcement action involving mobile applications. The...more
The Federal Trade Commission (FTC) published its final rule amendments today in the Federal Register updating the FTC regulations that implement the Children’s Online Privacy Protection Act (COPPA Rule)....more
Nearly all businesses today are involved in some way in the development or distribution of mobile applications. The first part of this Client Alert highlights recent activities of the California State Attorney General to...more
On December 19, 2012, the Federal Trade Commission (FTC) made major changes to the Children’s Online Privacy Protection Act (COPPA) for the first time in nearly 15 years, by significantly amending the Children’s Online...more
A report recently released by the Federal Trade Commission (FTC) reveals that mobile applications targeted at children often collect and share children’s private information with third parties but generally do not provide...more
The end of 2012 saw a flurry of activity in the area of privacy enforcement. In July, Kamala Harris, the Attorney General of California, announced the formation of California's own state agency to investigate and enforce the...more
On December 19, 2012, the Federal Trade Commission (FTC) finalized amendments to the Children's Online Privacy Protection Rule (the Rule), which applies to operators of commercial websites or online services that (1) are...more
Recent FTC and California Attorney General actions highlight the need to reassess privacy policies. The Federal Trade Commission (FTC) recently ordered the data brokerage industry to provide information on the collection...more
On December 19, 2012, the Federal Trade Commission (“Commission”) announced long-awaited amendments to its rule implementing the Children’s Online Privacy Protection Act (“Rule”). The changes – which take effect on July 1,...more
After years of consideration and feedback the Federal Trade Commission released the final revision to the 14-year old Children’s Online Privacy Protection Act (COPPA) Rule. The FTC began its review of the Rule back in April...more
On December 19, 2012, the Federal Trade Commission (FTC) issued final amendments to the Children's Online Privacy Protection Rule (COPPA Rule), which implements the Children's Online Privacy Protection Act (COPPA)....more
After two years of proposals, discussions and comments, the Federal Trade Commission approved final amendments to the Children’s Online Privacy Protection Rule (the “COPPA Rule” or “Rule”)1 on December 19, 2012. These...more