Dan Solove and Woody Hartzog have 5 suggestions for how FTC could use its authority to improve data security: Here’s how we think the FTC should use its authority to drive important change: 1. Do more proactive enforcement 2. Take on more data security cases 3. Push companies toward improved authentication – moving beyond mere passwords 4….
Search Results for: wyndham
More reaction to the Third Circuit opinion in FTC v. Wyndham
Two more commentaries site visitors interested in this issue may wish to read: What Exactly Does Reasonable Mean? – Josephine Wolff, Slate The FTC’s Wyndham victory is good for privacy but confusing for businesses – Stacey Higginbotham, Fortune
In Wyndham, the FTC won a battle but perhaps lost its data security war
Gus Hurwitz has a slightly different take on the Third Circuit’s opinion in FTC v. Wyndham. On the issue of notice, he writes, in part: The court goes on to find that Wyndham had sufficient notice of the requirements of Section 5 under the standard that applies to judicial interpretations of statutes. And it expressly notes…
FTC claims victory in Wyndham case; Appellate court upholds authority to enforce data security
Commissioner Julie Brill of the FTC has claimed victory in Wyndham’s appeal in the Third Circuit: Big news: FTC wins Third Circuit Wyndham appeal. Inadequate data security can be unfair under FTC Act & companies have adequate notice. — Julie Brill (@JulieBrillFTC) August 24, 2015 “Big news: FTC wins Third Circuit Wyndham appeal. Inadequate data…
Does the Seventh Circuit opinion in Neiman Marcus litigation impact FTC v. Wyndham?
Since the Seventh Circuit revived the class action lawsuit, Remijas v. Neiman Marcus, there has been a lot of buzz about how the opinion will make it easier for consumers going forward. The opinion (appended to this file), addresses Article III standing, which has been a major stumbling block in the majority of lawsuits. But skip on…
FTC and Wyndham Present Arguments on Whether FTC has Declared Unreasonable Cybersecurity Practices Unfair
Katherine Gasztonyi writes: On Friday, March 27, 2015, the Federal Trade Commission and Wyndham Worldwide Corp. filed supplemental briefing in the Third Circuit regarding whether the FTC had made an adjudicative decision that the FTC Act prohibits unreasonable cybersecurity practices and, if not, whether a federal court could hear a case charging a violation of the FTC Act…