News & Analysis as of

FTC Reaches $32.5 Million Settlement Agreement with Apple, Inc. Over Deceptive Billing Practices in Mobile Apps for Children

The Federal Trade Commission announced its sizeable settlement agreement with Apple, Inc. on Wednesday, over allegations that the company had violated Section 5 of the Federal Trade Commission Act by billing consumers...more

Guide to Compliance with the Amended COPPA Rule

What Is COPPA? •Children’s Online Privacy Protection Act, enacted by Congress in 1998 •Congress directed the Federal Trade Commission (FTC), the nation’s consumer protection agency, to issue and enforce regulations...more

FTC Assesses $800,000 Fine Against Mobile App Operator and Issues Mobile Privacy and Security Guidance

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

Path/FTC Settlement - Much More Than A Slap On The Wrist

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

Social Networking Mobile App Developer Agrees to Pay $800,000 and Implement Comprehensive Privacy Program to Settle Claims for...

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

FTC Announces Important Settlement with Social Networking App and Releases New Mobile App Report

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

Maryland AG Launches New Internet Privacy Unit, Plans Aggressive Enforcement

Maryland Attorney General Douglas Gansler (D) has announced that his office is launching a new Internet Privacy Unit designed to address issues related to online privacy and to ensure that companies are in compliance with...more

FTC Releases Guidance on Mobile Privacy Best Practices; Enters Into $800K Consent Order with Path

The FTC guidance released February 1 is Mobile Privacy Disclosures: Building Trust Through Transparency: A Federal Trade Commission Staff Report. In Mobile Privacy Disclosures, the FTC as the primary federal regulator on...more

Privacy Update: Complying With COPPA Under The FTC's New Children's Online Privacy Protection Rules

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

Privacy Alert: COPPA Amendment Impacts Apps, Ads and Social Networks

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

FTC Announces COPPA Rule Changes

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

Recent Privacy Developments: California AG Continues to Lead on Mobile with New Recommendations and FTC Amends COPPA

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

#3 in our 2013 Issues Series: Privacy of Mobile Applications

As we continue our “new year, new look” series into important privacy issues for 2013, we boldly predict...more

FTC Amends COPPA Rule and Previews Future Enforcement Policies

On December 19, 2012, the Federal Trade Commission ("FTC") adopted the first amendments to the Rule promulgated under the Children's Online Privacy Protection Act (hereinafter, "COPPA" for the Act, and "COPPA Rule" for the...more

FTC Strengthens Laws To Protect Children’s Privacy

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

FTC Survey: Disclosure Of Use Of Private Information In Mobile Apps For Children Is Insufficient

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

Privacy Resolutions for Mobile App Providers in the New Year

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

Advertising Law -- Jan 02, 2013

In This Issue: Does a Virtual Pet Site Violate COPPA?; Legislative Updates: Geolocation bill and VPPA Updates Advance, ECPA Update Stalls; Dunkin’s “Best Coffee” Slogan Can’t Be Trademarked; Takeoff: First California...more

FTC Expands Scope Of Children's Privacy Law To Keep Pace With New Technologies

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

Increasing Scrutiny of Consumer Data Collection

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

FTC Issues Substantially Revised COPPA Rule, Effective July 1, 2013: Review of Changes and Compliance Tips

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

Children’s Online Privacy Protection: U.S. Developments Compared To Canada

There were two important developments in the U.S. regarding children and mobile technologies....more

FTC Adopts New Amendments to Add to Children’s Online Privacy

The Federal Trade Commission announced on December 19, 2012, that it has adopted final amendments to the Children’s Online Privacy Protection Act (COPPA) that strengthen privacy protections online and give parents greater...more

Updated COPPA Rule – “Strong, Stronger and Yet Stronger” or Just More Confusion?

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

FTC Releases Final Amendments to Children's Online Privacy Protection Rule WSGR to Host Webinar on COPPA Revisions in January

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

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