On June 30, 2020 the Federal Trade Commission (FTC) announced that it reached a settlement in its litigation against NTT Global Data Centers (formerly RagingWire Data Centers) over allegations that the company misled customers about its adherence to the EU-U.S. Privacy Shield framework.1 As part of the settlement, the cloud service provider is required to hire … Continue Reading
On June 19, 2020, the Federal Trade Commission (FTC) submitted to Congress two reports that Congress requested in connection with the spending bill that funds the FTC. One of these reports (the “Resources Report”) describes the resources used and needed by the FTC to protect consumer privacy and security, and the second (the “Authorities Report”) describes … Continue Reading
On May 22, 2019, WSGR and the Future of Privacy Forum (FPF) co-hosted an event focusing on advertising technology and how to overcome the challenges of complying with evolving global privacy requirements. Jules Polonetsky from FPF opened the program, focusing on the evolution of online advertising, from contextual to programmatic behavioral advertising. WSGR attorneys Lydia … Continue Reading
On May 1, 2019, WSGR held an event in which regulators and experts discussed privacy developments in the U.S. and Europe. The first session featured a fireside chat with the Federal Trade Commission’s (FTC’s) Bureau of Consumer Protection Director, Andrew Smith, on “The State of Play at the FTC on Privacy.” In case you missed … Continue Reading
California Signs the First IoT Security Bill into Law, and the FTC Submits Comments to the Consumer Product Safety Commission Regarding the IoT California’s New IoT Law On September 28, 2018, California Governor Jerry Brown signed into law a cybersecurity bill governing Internet of Things (IoT) devices, the first law of its kind in the … Continue Reading
On April 30,2018, the Federal Trade Commission (FTC) announced a settlement with mobile phone manufacturer BLU Products and its owner over allegations that the company failed to implement appropriate procedures to oversee their service providers’ security practices, which allowed the service provider to install software containing commonly known security vulnerabilities on consumers’ mobile devices and … Continue Reading
In the latest episode of the WashingTECH Tech Policy Podcast, one of the leading national podcasts focused on tech law and policy debates driving the technology and communications sectors, Lydia Parnes, chair of the privacy and cybersecurity practice at Wilson Sonsini Goodrich & Rosati, discusses the state of privacy law after the Eleventh Circuit’s recent decision … Continue Reading
The U.S. Court of Appeals for the Eleventh Circuit recently released its highly anticipated decision in the long-running case pitting the now-defunct medical laboratory LabMD against the Federal Trade Commission (FTC), vacating the FTC’s data security order. In reaching its conclusion, the court held that the order’s requirement that LabMD establish a comprehensive information security … Continue Reading
On April 12, 2018, the Federal Trade Commission (FTC) announced that it was withdrawing its proposed August 2017 privacy and data security settlement with Uber Technologies and issuing a new and expanded proposed settlement.1 According to the FTC, the reason for this extraordinary step was to address additional allegations of misconduct by the ride-sharing company … Continue Reading
In a novel interpretation of the Federal Trade Commission (FTC) Act, the U.S. District Court for the District of Delaware recently held in FTC v. Shire ViroPharma that the FTC had failed to plead the facts necessary to invoke its authority to sue for permanent injunction in federal court because it did not allege an … Continue Reading
In February 2018, the Federal Trade Commission (FTC) released a report that explores the complexities of the mobile ecosystem and makes recommendations for industry to improve the mobile security update process for consumers. The report is part of the FTC’s effort to address concerns that mobile devices are not receiving the operating system patches they … Continue Reading
The Federal Trade Commission (FTC) recently granted a petition by Sears Holding Management requesting that the FTC reopen and modify a 2009 FTC order settling charges that Sears failed to disclose adequately the scope of consumers’ personal information it collected via a downloadable software app. Sears’ 2009 Order On August 31, 2009, the FTC entered … Continue Reading
On February 26, 2018, the U.S. Court of Appeals for the Ninth Circuit issued an en banc decision in FTC v. AT&T holding that the Federal Trade Commission (FTC) Act’s “common carrier” exemption is activity-based, reversing the panel’s decision that the exemption is status-based, which would have opened a large enforcement gap for telecommunications companies … Continue Reading
On February 27, 2018, the Federal Trade Commission (FTC) announced1 that it had reached an agreement with PayPal to settle allegations that its peer-to-peer payment service, Venmo, engaged in deceptive acts and practices and violated the Gramm-Leach-Bliley Act (GLBA)’s Safeguards Rule2 and Privacy Rule.3 Since 2011, Venmo has offered peer-to-peer payment services through an app … Continue Reading
On February 5, 2018, the Federal Trade Commission (FTC) announced its most recent Children’s Online Privacy Protection Act (COPPA) case against Explore Talent, an online talent agency marketed to aspiring actors and models.1 According to the FTC’s complaint, the company provided a free platform for users to find information about auditions, casting calls, and other … Continue Reading
2018 promises to be an interesting year in the world of privacy and cybersecurity. In this article, we highlight a few of the most notable developments we expect this year, including major developments in Europe, changes and pending cases at the Federal Trade Commission (FTC), notable U.S. Supreme Court cases scheduled to be decided this … Continue Reading
The Federal Trade Commission (FTC) has provided new guidance on how it will enforce the Children’s Online Privacy Protection Act (COPPA) against companies collecting voice recordings from children, loosening the rules on how companies can collect and use voice data. Under the guidance, online services covered by COPPA can now collect voice recordings from children … Continue Reading
On December 12, 2017, the Federal Trade Commission (FTC) held a workshop to examine consumer injury in the context of privacy and data security. The motivation for the workshop, according to Acting FTC Chairman Maureen Ohlhausen, was to help the FTC better understand consumer informational injury, weigh effectively the benefits of intervention against its inevitable … Continue Reading
The Federal Trade Commission (FTC) is seeking public comment on a petition by Sears Holding Management requesting that the FTC reopen and modify a 2009 FTC order settling charges that Sears failed to disclose adequately the scope of consumers’ personal information it collected via a downloadable software app. For more information, click here to see our … Continue Reading
On September 5, 2017, the Federal Trade Commission (FTC) announced that it and 32 state attorneys general had settled charges with Lenovo, Inc., regarding the company’s practice of pre-loading advertising software on its laptops that compromised consumers’ cybersecurity and privacy.1 In many respects, the case was reasonably straightforward: the facts as alleged were clear, and … Continue Reading
The U.S. District Court for the Northern District of California recently issued a mixed ruling on D-Link Systems’ motion to dismiss in FTC v. D-Link Sys., Inc.1 D-Link sells routers and Internet protocol (IP) cameras that it markets as having good data security, including “the latest wireless security features to help prevent unauthorized access” and … Continue Reading
The Federal Trade Commission (FTC) has settled its first-ever complaint against social media influencers for deceptive endorsements.1 According to the FTC’s complaint, Trevor “TmarTn” Martin and Thomas “Syndicate” Cassell, two influencers who have wide followings in the online gaming community, promoted an online gambling service called CSGO Lotto on YouTube and Twitter without disclosing that … Continue Reading
On September 5, 2017, the Federal Trade Commission (FTC) announced that it and 32 state attorneys general had settled charges with Lenovo regarding the company’s practice of pre-loading software on its laptops that compromised consumers’ cybersecurity and privacy. As part of the settlement, Lenovo agreed to pay $3.5 million in penalties to the states, and per an … Continue Reading
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 privacy and data security promises.1 Specifically, the FTC levied two deception counts against Uber: (1) that the company had … Continue Reading
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