Cybersecurity Lessons Learned From the FTC’s Enforcement History

By: Soyong Cho, Andrew L. Caplan

In 2014, cybersecurity and data breach incidents regularly made the headlines, with the reported breaches becoming increasingly large and complex. As in the past, these data breaches have inevitably been followed by a flurry of class actions and government investigations. But amid this flurry of activity, one federal regulator in particular, the Federal Trade Commission (the “FTC” or “Commission”), has unquestionably been the most prominent and active cybersecurity enforcer.

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