News & Analysis as of

Section 5 Cybersecurity Enforcement Actions

BakerHostetler

FTC Signals Heightened Scrutiny on the Security of APIs

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On Jan. 15, the Federal Trade Commission (FTC) announced a proposed settlement with web hosting giant GoDaddy over alleged violations of Section 5 of the FTC Act. Specifically, the FTC alleged that GoDaddy had violated the...more

WilmerHale

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

WilmerHale on

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

Akin Gump Strauss Hauer & Feld LLP

FTC Commercial Data Surveillance Crack Down: Kochava Gains a Win in Data Privacy Suit

On May 4, 2023, an Idaho federal judge ruled that the Federal Trade Commission (FTC) needs stronger assertions of consumer harm in order for its data privacy suit against data broker/mobile analytics provider Kochava Inc....more

NAVEX

Part 1: Privacy in 2023 – What to Expect and How to Prepare

NAVEX on

Privacy law compliance in the United States today demands resilience, flexibility, and responsiveness. To date, the U.S. Congress has failed to enact broadly applicable privacy standards to govern companies uniformly...more

Wyrick Robbins Yates & Ponton LLP

Not What the Doctor Ordered: GoodRx to Pay $1.5 Million in FTC’s First Enforcement of the Health Breach Notification Rule

The Federal Trade Commission earlier this month undertook an enforcement action against online pharmacy and telehealth provider GoodRx, in the latest example of the agency seriously pursuing its role as the nation’s de facto...more

Robinson+Cole Data Privacy + Security Insider

FTC Files Suit Against CafePress for “Data Breach Cover Up”

The Federal Trade Commission (FTC) issued a press release on March 15, 2022, stating that it was taking action against CafePress “over allegations that it failed to secure consumers’ sensitive personal data and covered up a...more

Snell & Wilmer

The Anatomy of an FTC Data Security Lawsuit

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The Federal Trade Commission (“FTC”) has described itself as “Your cop on the privacy beat” and a top federal regulator of consumer-facing data security practices. An example of how the FTC asserts itself when it comes to...more

Hogan Lovells

FTC’s Privacy Shield Enforcement Actions Show Broader Enforcement Lens

Hogan Lovells on

On September 27, the Federal Trade Commission (FTC) announced proposed settlement agreements with four companies it alleges violated Section 5 of the FTC Act by misrepresenting their certification status and compliance with...more

Cozen O'Connor

Don’t Misrepresent Your U.S. – E.U. Privacy Shield Status: FTC Brings An Enforcement Action

Cozen O'Connor on

As US companies continue to spend time and effort complying and responding to all of the new privacy laws and regulations both in the United States and aboard (i.e. GDPR and California Consumer Privacy Act of 2018) companies...more

McGuireWoods LLP

FTC’s Loss in the Eleventh Circuit Will Not Impede Data Security Enforcement

McGuireWoods LLP on

In the matter of LabMD Inc. v. Federal Trade Commission, case number 16-16270, the U.S. Court of Appeals for the Eleventh Circuit ruled against the FTC, finding that the order against LabMD for lax data security measures was...more

Patterson Belknap Webb & Tyler LLP

FTC Chronicle: “Lessons Learned” from the Agency’s Data Breach Investigations

The Federal Trade Commission (FTC) – often criticized for not providing clear guidance as to what the agency considers reasonable data security – announced on Friday that it would publish a weekly blog discussing “lessons...more

Dorsey & Whitney LLP

Case Update: In Consumer Data Breach Case, Eleventh Circuit Indicates Concern over Scope of FTC’s Enforcement Actions

Dorsey & Whitney LLP on

On June 21, 2017, the Eleventh Circuit Court of Appeals heard oral argument in LabMD, Inc. v. FTC, Case No. 16-16270, a case that is being carefully watched to see if it will clarify the limits of the Federal Trade...more

Lowndes

A Primer On FTC Cybersecurity Enforcement

Lowndes on

According to the Breach Level Index, the total number of data records lost or stolen in just the first half of 2016 was 554,454,942, stemming from 974 breach incidents. In the entire year of 2015, there were 707.5 million...more

Davis Wright Tremaine LLP

IoT Vendors Beware: FTC’s Latest Enforcement Action Signals Further Scrutiny of the Industry

The FTC’s first data security enforcement action in 2017 sends a clear signal to vendors serving the Internet of Things (“IoT”) marketplace: make sure your data security promises match your data security practices. IoT is in...more

Fenwick & West LLP

Return of the Cyborg—FTC and SEC Oversight of Cybersecurity Ramps Up

Fenwick & West LLP on

The government appears to be increasing its enforcement efforts regarding cybersecurity risks. A three-judge panel of the U.S Court of Appeals for the Third Circuit recently held the FTC may bring a claim that a company’s...more

Akin Gump Strauss Hauer & Feld LLP

3rd Circuit Affirms FTC’s Cybersecurity Oversight

If you read one thing: - The Federal Trade Commission (FTC) secured a major appellate victory in its quest to challenge lax corporate cybersecurity practices - In light of the 3rd Circuit’s decision,...more

Ballard Spahr LLP

Federal appeals court confirms FTC authority to regulate cybersecurity policies and procedures

Ballard Spahr LLP on

Banks and other companies subject to the CFPB’s jurisdiction face the possibility that the CFPB could begin using its authority under Sections 1031 and 1036 of the Dodd-Frank Act (which proscribe unfair, deceptive or abusive...more

Robinson+Cole Data Privacy + Security Insider

FTC issues statement on its enforcement abilities under § 5 of the FTC Act

On August 13, 2015, the Federal Trade Commission (FTC) issued a statement on its ability to prosecute ‘unfair trade practices’ and enforce violations under § 5 of the FTC Act. The guidance said: Section 5’s ban on...more

Robinson+Cole Data Privacy + Security Insider

Third Circuit affirms FTC’s jurisdiction over security practices in Wyndham case

In a strongly worded opinion, the Third Circuit Court of Appeals on Monday slammed Wyndham Worldwide Corporation’s arguments that the FTC did not have jurisdiction to enforce the security practices of businesses following a...more

Arnall Golden Gregory LLP

Recent Appellate FTC Cybersecurity Ruling

On August 24, 2015, the United States Court of Appeals for the Third Circuit ruled that the Federal Trade Commission (hereinafter “FTC”) has the power under the FTC Act to police companies that fail to employ adequate...more

Orrick, Herrington & Sutcliffe LLP

Third Circuit to Wyndham (Part I): It's "Fair" that FTC Did Not Articulate Specific Cybersecurity Standards in Enforcement Action...

On Monday, the Third Circuit issued a highly anticipated opinion affirming the Federal Trade Commission's authority to regulate "unfair" cybersecurity practices under Section 5 of the FTC Act. In allowing the data breach...more

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