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
The New York State Department of Financial Services (NYDFS) and the Attorney General’s office have recently imposed significant fines totalling $11.3 million on Geico and Travelers for data breaches that compromised the...more
On October 22, 2024, the SEC charged two current reporting companies, Unisys Corp. and Check Point Software Technologies, and two former public companies, Mimecast Limited and Avaya Holdings Corp., with making materially...more
An unprecedented cyber qui tam action involving Georgia Tech’s alleged failure to comply with certain cybersecurity controls underscores the importance of having advanced cyber requirements for federal contractors. Our...more
Late last week, the U.S. Department of Justice (DOJ) filed its complaint-in-intervention in a qui tam lawsuit against the Georgia Institute of Technology (Georgia Tech), alleging that the university failed to meet certain...more
The SEC has been aggressively pursuing cybersecurity investigations and enforcement actions against public companies and foreign private issuers. In these actions, the SEC often alleges one of two theories: 1) that the...more
The Securities and Exchange Commission entered into a resolution agreement with R.R. Donnelley & Sons (RRD) on June 18, 2024 with RRD agreeing to pay $2.125 million to resolve disclosure and control violations alleged by the...more
When the regulator has decided to investigate your organisation following a data breach, the remit for the investigation will be wide-ranging and go beyond the narrow circumstances of the breach. Recent decisions shed useful...more
In this part of our briefing series, we cover how prior regulatory enforcement action affects the assessment of sanctions and some pitfalls associated with undertaking internal security audits. Who is this relevant for?...more
What insights into cyber security norms can organisations glean from the UK ICO’s recent enforcement decisions, most of which have been released since the GDPR came into force? Final fines are still awaited on the UK’s...more
On September 26, 2018, the United States Securities and Exchange Commission (“SEC”) announced a $1 million settlement with an Iowa-based broker-dealer over allegations that it maintained deficient cybersecurity policies and...more
On August 15, 2017, the Federal Trade Commission (FTC) announced that it had reached an agreement with Uber Technologies to settle allegations that the ride-sharing company had deceived consumers by failing to live up to its...more
Investment firm R.T. Jones Capital Equities Management (R.T. Jones) has agreed to settle with the Securities and Exchange Commission (SEC) and pay a $75,000 penalty over charges that it failed to adopt written policies and...more
Recently, the SEC announced that R.T. Jones Capital Equities Management, a St. Louis-based investment adviser, agreed to settle charges that it failed to establish the required cybersecurity policies and procedures before a...more
On September 22, 2015, the Securities and Exchange Commission (SEC) filed a settled administrative proceeding[1] alleging that a registered investment adviser failed to adopt cybersecurity procedures in violation of an SEC...more
On August 24, in FTC v. Wyndham Worldwide Corp. et al, the Third Circuit Court of Appeals affirmed that the FTC could enforce its own reasonable interpretation of what cybersecurity standards are necessary to avoid...more
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