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FTC Settles Allegations of Data Security Failures with Edtech Company Chegg

On October 31, 2022, the Federal Trade Commission (FTC) announced a complaint and proposed consent order against Chegg, an edtech company, over its security practices that resulted in four security breaches in three years....more

California Legislature Passes Far-Reaching Online Privacy and Content Regulation Bill for Minors

On August 30, 2022, the California legislature passed the California Age-Appropriate Design Code Act (the Act). Modeled after the UK's Age-Appropriate Design Code, California's act drastically changes the landscape of online...more

California Attorney General Settles First-Ever CCPA Enforcement Action

On August 24, 2022, the California Attorney General (AG) announced the entry of a final judgment to resolve claims that makeup retailer Sephora violated the California Consumer Privacy Act (CCPA). Notably, this is the...more

Privacy Post-Dobbs: Recent Guidance from U.S. Regulators

On June 24, 2022, the United States Supreme Court issued its decision in Dobbs v. Jackson Women's Health Organization,1 opening a legal path to state laws restricting or prohibiting access to certain reproductive health...more

Privacy and Security of Health Information: A Primer for Digital Health Companies

COVID-19 has rapidly accelerated our expectations that virtual connection can deliver better and more economical care. As a result, digital health companies have an unprecedented opportunity to innovate, but with that...more

And Then There Were Five: Connecticut Enacts Comprehensive Privacy Law

Connecticut became the fifth U.S. state to enact a comprehensive consumer privacy law following California, Virginia, Colorado, and Utah. On May 10, 2022, Connecticut Governor Ned Lamont signed "An Act Concerning Personal...more

Colorado Attorney General Issues Pre-Rulemaking Considerations for the Colorado Privacy Act

On April 12, 2022, the Colorado Attorney General's Office released "Pre-Rulemaking Considerations for the Colorado Privacy Act," which provides a series of topics and questions for which the office seeks informal public...more

FTC Issues Complaint and Proposed Settlement with Online Retailer for Deceptive and Unfair Security and Privacy Practices

On March 15, 2022, the Federal Trade Commission (FTC) announced it had filed a complaint against Residual Pumpkin Entity, LLC, formerly doing business as CafePress, and PlanetArt LLC, which bought CafePress in 2020...more

Utah Poised to Become Fourth State with General Privacy Law

Utah is poised to become the fourth state to enact comprehensive consumer privacy legislation, following California, Virginia, and Colorado. Earlier this month, Utah's legislature passed the Utah Consumer Privacy Act (S.B....more

Colorado Attorney General Announces Privacy Rulemaking

The Colorado Attorney General's office is poised to begin the rulemaking process for the Colorado Privacy Act (ColoPA). On January 28, 2022, Colorado Attorney General Phil Weiser issued prepared remarks outlining key...more

California Privacy Protection Agency Issues Invitation for Preliminary Comments on Proposed Rulemaking Under the California...

The California Privacy Protection Agency (CPPA), the newly formed state agency responsible for implementing the California Privacy Rights Act (CPRA), recently posted its first invitation for public comment on proposed...more

California Attorney General Mandates CCPA-Covered Businesses Honor the Global Privacy Control and Announces Update on CCPA...

Recently, the Office of the Attorney General of California announced three major updates that 1) added to the California Consumer Privacy Act's (CCPA) opt-out rules related to the sale of personal information, 2) made it...more

FTC Settles COPPA Action Against “Coloring Book for Adults”

On July 1, 2021, the Federal Trade Commission (FTC) announced that it settled allegations against Toronto-based Kuuhuub Inc., along with Kuuhuub's Finnish subsidiaries Kuu Hubb Oy and Recolor Oy (together, defendants), that...more

Virginia Legislature Sends Novel Privacy Law to Governor's Desk

Virginia is poised to become the second U.S. state to enact broad consumer privacy legislation. While the legislation draws some parallels with the California Consumer Privacy Act (CCPA) and upcoming California Privacy Rights...more

Apple Requires Apps to Include New Privacy "Nutrition Label" by December 8, Delays Opt-In for Tracking Requirement Until Early...

Apple recently announced that app developers must check a series of yes/no boxes that will generate a "nutrition label"-style summary of the app's privacy practices. This new summary, formally called "App Privacy," will be...more

New California Privacy Rights Act to Effectively Replace the California Consumer Privacy Act

On Election Day, November 3, 2020, California voters overwhelmingly voted in favor of Proposition 24—a ballot measure that creates the California Privacy Rights Act (CPRA). The CPRA revises and expands the California Consumer...more

FTC Announces Unusually Stringent Consent Order in Privacy Shield Case Settlement

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...more

CCPA Update: California Attorney General Submits Final Proposed Regulations to OAL

On June 2, 2020, the California Attorney General announced that it had submitted the final proposed regulations package for the California Consumer Privacy Act (CCPA) to the California Office of Administrative Law (OAL). The...more

Feeling BLU: What You Need to Know About Overseeing Your Service Providers

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...more

California Enacts Sweeping Privacy Law to Avert Potential Ballot Measure

In a surprising twist, the California legislature rushed last week to pass one of the most comprehensive privacy laws in the country. The bill was introduced only a week prior, and within hours of passage, it was signed into...more

Eleventh Circuit LabMD Decision Significantly Restrains FTC's Remedial Powers in Data Security and Privacy Actions

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),...more

FTC Grants Sears’ Petition to Reopen and Modify 2009 Order Concerning Online Browsing Tracking

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...more

FTC Carves New Path for Collecting Voice Recordings from Children Without Parental Consent

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...more

Hello, Dolly: What You Need to Know About Connected Smart Toys and Privacy

As connected devices become ubiquitous, it comes as no surprise that interactive toys that connect to the internet are more popular than ever. At the same time, regulators have taken note of the privacy and security concerns...more

FCC Orders Far-Reaching New Privacy and Data Security Rules

As expected, the Federal Communications Commission (FCC) has handed down sweeping new privacy and security rules for Internet service providers (ISPs). On Thursday, October 27, 2016, a sharply divided commission voted to...more

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