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Hefty FTC Penalty Against Twitter Reveals Privacy Policy Disclaimers Not Sufficient

The Federal Trade Commission has levied a negotiated $150 million civil penalty against Twitter for violating an existing FTC order for alleged misrepresentations to its users, claiming the company deceptively collected...more

FTC Guidance Creates New Breach Notification Obligations

The Federal Trade Commission has issued new guidance under which consumers or companies should be notified of data breaches “regardless of whether a breach notification law applies.” Our Consumer Protection/FTC Team analyzes...more

FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events

On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of...more

Supreme Court Positioned to Limit FTC Ability to Obtain Monetary Relief

For nearly 40 years, the Federal Trade Commission has used a provision of the FTC Act to impose monetary penalties in consumer protection cases that is under scrutiny by the Supreme Court. Our Consumer Protection/FTC Team...more

The FTC Expands its FCRA Enforcement Activity In Action Against Retailer

Most businesses are already familiar with the Fair Credit Reporting Act (“FCRA”) and the various requirements to protect the fairness, accuracy, and privacy of consumer credit information. However, a recent FTC enforcement...more

The Updated CCPA Regulations: 30 Potentially Material Business Impacts

California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more

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