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CFTC Settlement Asserts Data Breach Disclosure Requirement for Future Commission Merchants

On September 12, 2019, the Commodity Futures Trading Commission (CFTC) announced a settlement with Phillip Capital Inc. (PCI or the “Company”), a registered futures commission merchant (FCM), after hackers successfully...more

New York Enacts SHIELD Act with Expansive Data Breach Notification and Data Security Requirements

• New York recently enacted the Stop Hacks and Improve Electronic Data Security (SHIELD) Act, which expands data breach notification requirements and imposes new data security obligations on businesses that own, license or,...more

Recent FTC Settlements Highlight Risks of Flawed Information Security Practices and Related Representations

In a set of recent settlements, the Federal Trade Commission (the FTC or Commission) resolved charges against two companies, ClixSense and D-Link, for failing to provide reasonable security and to live up to their data...more

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