Timothy Cornell of Clifford Chance US LLP has an interesting write-up on the Wyndham case that really details the time and labor costs of responding to a government investigation following a data breach. Here’s an example: On April 8, 2010, the FTC began to investigate Wyndham Worldwide and three of its subsidiaries (collectively “Wyndham”), sending Wyndham…
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Recap of Oral Argument in FTC v. Wyndham
Katherine Gasztonyi reports: Today, the U.S. Court of Appeals for the Third Circuit heard oral arguments in FTC v. Wyndham Worldwide Corp.The court focused on several themes: First, whether Congress has entrusted the FTC to define new unfair practices, whether the FTC has declared that unreasonable cybersecurity practices are unfair, and whether the FTC is asking the…
Wyndham: Third Circuit Requests Briefing on Whether FTC Declared Unreasonable Cybersecurity Practices Are ‘Unfair’
Katherine Gasztonyi writes: On February 20, the Third Circuit sent a letter to counsel in FTC v. Wyndham Worldwide Corp., identifying at least one topic that will be addressed in the upcoming oral argument regarding the parties’ dispute over whether the FTC has the authority to regulate companies’ data security practices: whether unreasonable cybersecurity practices…
FTC and Wyndham to Mediate Dispute Over FTC Data-Security Authority
Meena Harris writes: Earlier this week, U.S. District Court Judge Esther Salas directed the Federal Trade Commission (“FTC”) and Wyndham Hotels and Resorts to seek mediation to resolve their landmark dispute over whether the FTC has the authority to regulate companies’ data-security practices. As we’ve previously reported, the FTC alleged that Wyndham violated Section 5…
CDT Files Brief in Wyndham Supporting FTC Regulation of Data Security
G.S. Hans writes: On Wednesday, November 12th CDT, along with the Electronic Frontier Foundation, filed an amicus brief in the long-running FTC v. Wyndham litigation. […] Our amicus highlights a few additional points that we think demonstrate why it’s vital that the FTC regulate data security. Read more on CDT.
FTC Refutes Wyndham’s Challenge; Unreasonable Security Is “Unfair”
Patricia Ballin reports: Generating a flurry of conversation among privacy professionals worldwide, the U.S. Federal Trade Commission (FTC) last week filed its response to Wyndham Worldwide Corporation’s interlocutory appeal in the Third Circuit. […] The FTC’s response outlines and affirmatively answers the three questions presented in Wyndham’s appeal: whether a company’s unreasonable failure to protect the security…