Christopher Olsen

Subscribe to Christopher Olsen's Posts

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) announced that it adopted final rules requiring disclosure by public companies of material cybersecurity incidents in a Current Report on Form 8-K, and of material information regarding their cybersecurity risk management, strategy, and governance in an Annual Report on Form 10-K. Foreign private issuers will be required to make comparable disclosures on Forms 6-K and 20-F. Set forth below is a brief summary of the final rules; a more detailed client alert will follow.Continue Reading SEC Adopts Cybersecurity Disclosure Rules

On June 13, 2023, Texas Governor Greg Abbott signed the Securing Children Online through Parental Empowerment Act (HB 18) (SCOPE Act). With this signing, Texas joins Utah and Arkansas in regulating social media and its impact on minors and their mental health.

The SCOPE Act requires covered “digital service providers” to provide minors with certain data protections, prevent minors from accessing harmful content, and give parents tools to manage their child’s use of the service. The Act also has age verification requirements for digital service providers that knowingly distribute a significant amount of “harmful” or “obscene” content.Continue Reading Texas Joins Other States in Enacting Social Media Law for Minors

On May 3, 2023, the Federal Trade Commission (FTC) announced that it issued an order to show cause (the “show cause order”) to Meta Platforms, Inc. (formerly Facebook, Inc., “Meta”). The show cause order proposes…

Continue Reading Round Three: FTC Proposes Further Restrictions on Meta’s Privacy Practices and a Complete Prohibition on Meta Monetizing Youth Data

Last week, the Federal Trade Commission (FTC) and the District Attorneys of Los Angeles County and Riverside County agreed to an order to settle claims against Frontier Communications Intermediate, LLC and its parent company, Frontier Communications Parent, Inc. (collectively, Frontier). The plaintiffs alleged that Frontier promised internet speeds that Frontier did not deliver. The order, approved by all Commissioners, contains far-reaching and, in some cases, novel relief, including an $8.5 million penalty, a requirement for customer-by-customer substantiation, an absolute prohibition on signing up of certain new customers, and a mandated $50-60 million investment in new technology.
Continue Reading FTC Takes Aggressive Action Against Internet Service Provider for Misrepresenting Internet Speeds

On April 12, 2022, the U.S. Consumer Financial Protection Bureau (CFPB) filed a lawsuit against TransUnion, two of its subsidiaries, and former TransUnion executive John Danaher in his individual capacity for violating an enforcement order. That order, from January 2017, was part of a settlement in which TransUnion agreed to pay $16.9 million in restitution and civil penalties for deceptively marketing credit scores and credit-related products, such as credit monitoring services.
Continue Reading Consumer Financial Protection Bureau Alleges Dark Patterns in Advertising of Financial Products; Files Suit Against TransUnion and Senior Executive for Violating Order