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Data Security Unfair or Deceptive Trade Practices

Troutman Pepper Locke

Looking Back at 2024's Noteworthy State AG Litigation

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State attorneys general across the U.S. took bold steps in 2024 to address unlawful activities by corporations in several areas, including privacy and data security, financial transparency, children’s internet safety, and...more

Alston & Bird

Class Action & MDL Roundup 2024 Q4 – We Give You the Benefit of the Bargain

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Welcome back to the Class Action & MDL Roundup! This edition covers notable class actions from the fourth quarter of 2024. In this edition, an overdue audiobook suit is shelved, an old case gets new reps and new...more

Orrick, Herrington & Sutcliffe LLP

New York attorney general files complaint over insurance data breaches

On March 1, New York State Attorney General Letitia James filed a complaint in the Supreme Court of the State of New York against a group of insurance companies and a parent corporation. The complaint alleged these companies...more

Kohrman Jackson & Krantz LLP

Marriott Settles for $52M & Enhances Data Protections After Multi-State Investigations

Marriott has agreed to pay $52 million dollars and implement new consumer data protections to settle investigations by attorneys general from 49 states and the Federal Trade Commission, following data breaches that occurred...more

Alston & Bird

Flurry of FTC Action in the Final Days of the Khan FTC Precedes Transition to the Ferguson FTC

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Our Consumer Protection/FTC and Antitrust Teams highlight a spate of activity by the Federal Trade Commission (FTC) in its final days under the leadership of Lina Khan and offers a preview of what’s to come with Andrew...more

Wiley Rein LLP

What Just Happened at the FTC and CFPB: Wiley Consumer Protection Download (January 24, 2025)

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In the two weeks before Inauguration, both the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) released a flurry of rulemaking developments, policy announcements, and enforcement filings and...more

Robinson+Cole Data Privacy + Security Insider

FTC Takes Action Against GoDaddy for Alleged Lax Data Security

The Federal Trade Commission (FTC) issued a proposed settlement order against GoDaddy alleging that it “has failed to implement reasonable and appropriate security measures to protect and monitor its website-hosting...more

Venable LLP

The Biden/Chopra CFPB's 2025 Guidance Compendium: A Last Gasp or Lasting Legacy?

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On the eve of a change in administration, the Biden/Chopra CFPB released a "Compendium of Recent CFPB Guidance," a sweeping collection of interpretations of federal consumer financial laws under the current leadership...more

Alston & Bird

FTC Announces Proposed Settlement with GoDaddy Incorporating Prescriptive Cybersecurity Requirements

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On January 15, 2025, the Federal Trade Commission (FTC) announced a proposed settlement with GoDaddy Inc. (GoDaddy) for making false or misleading representations about their security practices in violation of Section 5 of...more

Baker Botts L.L.P.

A Landmark Lawsuit in Data Privacy: Texas v. Allstate

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In a groundbreaking enforcement action, Texas Attorney General Ken Paxton has filed a lawsuit against Allstate Corporation and its subsidiary Arity, alleging systematic violations of the Texas Data Privacy and Security Act...more

Troutman Pepper Locke

OCC Releases Updated UDAAP Supervision and Examination Procedures Booklet

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On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook,...more

Foley & Lardner LLP

Office of the Comptroller of the Currency Updates “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or...

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Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and...more

Seyfarth Shaw LLP

Careful Data Governance Is a Must Amid Enforcement Focus

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Corporations face unprecedented challenges in safeguarding sensitive data and mitigating privacy risks in an era marked by the rapid proliferation of Internet of Things, or IoT, devices....more

Wiley Rein LLP

Wiley Consumer Protection Download (September 4, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Sheppard Mullin Richter & Hampton LLP

NY AG Releases Website Privacy Guides for Businesses and Consumers

New York Attorney General Letitia James recently released guidance for businesses and consumers about website tracking technologies. The consumer guide provided examples of common cookies, tracking technologies, and how...more

Sheppard Mullin Richter & Hampton LLP

We Don’t Use Dark Patterns!? FTC and Consumer Protection Networks Review Suggests You Might

In its ongoing concern with “dark patterns,” the FTC recently announced results of two reviews of sites and apps purportedly engaging in the practice. As a reminder, the FTC views as “dark patterns” practices or web designs...more

Robinson+Cole Data Privacy + Security Insider

Maryland Online Data Privacy Act

On May 9, 2024, Governor Wes Moore signed the Maryland Online Data Privacy Act (MODPA) into law. MODPA applies to any person who conducts business in Maryland or provides products or services targeted to Maryland residents...more

WilmerHale

FTC Announces Enforcement Action Against Global Tel*Link Corporation for Unfair Data Security Practices and Inadequate Data Breach...

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On November 16, the Federal Trade Commission (FTC) announced an enforcement action against Global Tel*Link Corporation and two of its subsidiaries (collectively, “GTL”), which provide communications and payment services to...more

Davis Wright Tremaine LLP

Litigation Preparedness Following a Data Breach: Three Tips to Consider During the Incident Response Period

Data breaches come in many different forms, sizes, and levels of complexity, but they tend to share certain key facts: A third-party bad actor—whether through a phishing attack, a ransomware attack, exploitation of a zero-day...more

Benesch

New FTC Investigation Into OpenAI May Shed Light on Developing AI Enforcement Landscape

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In the strongest regulatory move made against OpenAI since the launch of its Artificial Intelligence (AI) chatbot ChatGPT in November 2022, the Federal Trade Commission (FTC) has opened an investigation to determine whether...more

Wyrick Robbins Yates & Ponton LLP

The Next Post They Write Might Be About You: The FTC’s Business Blog Calls Out Health Data Practices That Can Violate Section 5

In another example of the agency’s practice of regulation by blog, the FTC published last week a Business Blog Post about protecting consumer health information. The post, which summarizes key points from several recent...more

BakerHostetler

FTC Launches Anticipated Investigation of OpenAI Inc.

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It was only a matter of time before the Federal Trade Commission (FTC) initiated a law enforcement investigation focusing on artificial intelligence (AI). It is not an exaggeration to say that the FTC has been hinting at, and...more

Woods Rogers

FTC Opens Consumer Protection Investigation of OpenAI, Creator of ChatGPT

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The Investigation - The Federal Trade Commission (FTC) recently opened an investigation into OpenAI, creator of ChatGPT, to determine whether the artificial intelligence company violated consumer protections laws. According...more

WilmerHale

FTC Announces Enforcement Action Against 1Health.io for Inadequate Protection of Genetic Data and Unfair Privacy Policy Changes

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On June 16, the Federal Trade Commission (FTC) announced an enforcement action against 1Health.io Inc. (“1Health,” also known as Vitagene, Inc.), a genetic testing company that analyzes consumer-provided DNA samples and uses...more

Sheppard Mullin Richter & Hampton LLP

Don’t Forget Deception: FTC and Biometrics

With the ongoing BIPA litigation activity in Illinois surrounding collection of biometrics, it can be easy to forget that other issues might surround this practice. Last month the FTC reminded companies not to forget general...more

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