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Federal Trade Commission (FTC) › Third-Party Liability

Hinch Newman LLP

Ad Agency Liability and the FTC

Hinch Newman LLP on

Advertising agencies are potentially liable to the Federal Trade Commission for deceptive acts or practices, along with their clients. The FTC will consider numerous factors, including, but not limited to, the extent to...more

Hinch Newman LLP

When a Company Can be Liable to the FTC for Participating with Another Company in Misconduct

Hinch Newman LLP on

The FTC has initiated a number of investigations and enforcement actions in recent years holding companies responsible for consumer injury caused by others or in which they directly participated in the misconduct. For...more

WilmerHale

FTC Proposes Rule to Make Impersonating Government Entities and Businesses Unlawful

WilmerHale on

On February 15, 2024, the Federal Trade Commission (FTC) finalized its Government and Business Impersonation Rule (the Impersonation Rule, available here) prohibiting fraudulent impersonation of governments, businesses and...more

Sheppard Mullin Richter & Hampton LLP

New Trends Emerge in FTC Data Security Orders, Including Emphasis on C-Suite Involvement

Sheppard Mullin Richter & Hampton LLP on

The FTC recently summarized three major changes it made to its orders in data security cases. In a blog signaling these changes, the FTC Indicated that some of the things it has been requiring of companies in 2019 are here to...more

WilmerHale

A Primer on FTC Expectations for Your Partner and Vendor Relationships: Enforcement Shows You Are Your Brother’s Keeper

WilmerHale on

With all of the privacy and data security enforcement actions brought by the Federal Trade Commission in recent years, and with all of the guidance distributed by the FTC in that time frame, it is easy to get caught up in...more

Mintz - Privacy & Cybersecurity Viewpoints

Guide to Compliance with the Amended COPPA Rule

Mintz - Privacy & Cybersecurity Viewpoints on

What Is COPPA? •Children’s Online Privacy Protection Act, enacted by Congress in 1998 •Congress directed the Federal Trade Commission (FTC), the nation’s consumer protection agency, to issue and enforce regulations...more

Manatt, Phelps & Phillips, LLP

Lessons from the Automated Electronic Checking Inc. Case

Manatt, Phelps & Phillips, LLP on

Recent action by the Federal Trade Commission against a third party processor found to be processing transactions for a merchant engaged in wrong-doing, indicates the necessity of processors employing adequate due diligence...more

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