The Briefing: Failure to Disclose Relationship with Real Party in Interest Results in Serious Sanctions
Podcast: The Briefing - Failure to Disclose Relationship with Real Party in Interest Results in Serious Sanctions
Joseph Sullivan, Uber’s beleaguered former Chief Information Security Officer, was back in the news last month when he appealed his 2023 conviction for his role in concealing a 2016 breach of Uber’s network and customer data....more
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
A New Your federal district judge handed down a significant decision dismissing much of the SEC’s securities fraud enforcement action against SolarWinds arising from its claims relating to SolarWinds’ cybersecurity policies,...more
In the ever-evolving compliance landscape, the recent enforcement action by the Securities and Exchange Commission (SEC) against RR Donnelley is a significant case study. This incident underscores the importance of robust...more
The SEC on Oct. 30, 2023, filed a landmark cybersecurity enforcement action against SolarWinds Corp. (SolarWinds) and the company's current Chief Information Security Officer (CISO) Timothy Brown. The SEC's complaint alleges...more
The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach, has brought the issue of executive liability in cybersecurity disclosures to the forefront. This case sheds light on the...more
In a first, bold move by the Securities and Exchange Commission (SEC) following its new Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies, issued on July 26, 2023, this...more
The U.S. Securities and Exchange Commission has a message for publicly-traded companies that suffer a data breach: own up. On Monday, the SEC sued Texas-based SolarWinds––and its Chief Information Security Officer...more
On October 5, 2022, after a monthlong jury trial, former Uber Chief Information Security Officer Joseph Sullivan was found guilty of obstructing proceedings of the Federal Trade Commission (FTC) and misprision of a felony...more
This past summer’s string of cyber enforcement actions signals that cybersecurity has become a top priority for the US Securities and Exchange Commission (“SEC”). This focus is consistent with the SEC’s Division of...more
As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more
On April 24, 2018, the Securities Exchange Commission (SEC) announced a $35 million fine against the company formerly known as Yahoo! Inc. (now known as Altaba, Inc.) for failing to disclose a massive cyber data breach to its...more