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Slaughter discusses the FTC’s priorities under the new administration, including ed-tech, health apps, and racial equity.

By Jennifer Archie, Michael Rubin, Marissa Boynton, and Jimmy Smith

On February 10, 2021, in her first major speech as acting chair of the Federal Trade Commission (the Commission, or the FTC), Rebecca Slaughter discussed the Commission’s enforcement priorities under the new administration — with a particular focus on deterring problematic data practices.

In her opening remarks at the Future of Privacy Forum, Slaughter stated that she would urge innovation and creativity and the use of all tools available to the Commission in order to bring about the best outcomes for consumers and to deter problematic privacy and data security practices.[i] She also noted that enhanced enforcement around ed-tech, health apps, and racial equity would be priorities for the new administration. In particular, Slaughter mentioned two types of relief that she believes the Commission should focus on going forward: disgorgement and effective consumer notice.

By Michael Rubin, Scott Jones, Cooper Rekrut

On September 19, 2017, Judge Donato of the Northern District of California ruled on Defendant D-Link System Inc.’s (D-Link) Motion to Dismiss, which challenged claims by the Federal Trade Commission (FTC) that D-Link’s conduct constituted unfair and deceptive trade practices in violation of Section 5 of the FTC Act.

The FTC’s complaint alleges that D-Link failed to implement adequate data security with respect to router and IP cameras it marketed and sold to the public. According to the FTC’s complaint, D-Link’s router and IP cameras were susceptible to well-known exploits and other vulnerabilities that left consumers at risk of compromise by hackers. The FTC alleged that these practices were both deceptive (contrary to D-Link’s representations about the security of their products) and unfair (caused or were likely to cause substantial injury to consumers).

August 2 Webcast to Consider Risks and Responses

A recent high-profile enforcement action by the Federal Trade Commission (FTC) provides meaningful context and occasion for examining data security risks in the hospitality industry.

In late June, the FTC filed suit against global hospitality company Wyndham Worldwide Corp. and three of its subsidiaries for alleged data security failures that led to three data breaches at 45 Wyndham properties in less than two years. The action followed an expansive and expensive civil…