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SEC Settles Charges for Alleged Misleading Disclosures, Shedding Light on Materiality in Cyber Context

On Oct. 22, 2024, the Securities and Exchange Commission (SEC) announced settled charges against four current and former public companies, Unisys, Avaya Holdings, Check Point Software Technologies and Mimecast, for allegedly...more

SEC Adopts Cybersecurity Risk Management Strategy Governance Incident Disclosure Rules

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) released proposed rules regarding public companies’ reporting of (i) cybersecurity incidents, (ii) policies and procedures for identifying and managing...more

SEC Proposes New, Formal Cybersecurity Disclosure Rules

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed a number of new rules to enhance public companies’ reporting of (i) cybersecurity incidents, (ii) their policies and procedures for identifying and...more

Between a Rock and a Hard Place: SEC Disclosure Analysis in Light of Yahoo Settlement

On April 25, the Securities and Exchange Commission announced a settlement with Yahoo that constituted its first enforcement action against a public company for failing to disclose a data breach. This settlement...more

New SEC Cybersecurity Guidance Outlines Disclosure Obligations

Last week, as previously reported, the U.S. Securities and Exchange Commission (SEC) unanimously voted to approve additional guidance for reporting cybersecurity risks. The release of this guidance underscores the SEC’s...more

Fitbit IPO Cyber Risk Disclosures

Earlier this month, fitness-tracking company Fitbit, Inc. filed a Form S-1 Registration Statement for an IPO of up to $100 million that exhaustively disclosed potential cybersecurity risks with respect to the personal data...more

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