Fair Notice or No Notice? Wyndham Worldwide Case and the Expanding Power of the FTC to Police Data Security – Part II

Fair Notice or No Notice? Wyndham Worldwide Case and the Expanding Power of the FTC to Police Data Security – Part II
 In our first blog in this series, we provided a summary of the District Court of New Jersey’s recent decision in FTC v. Wyndham Worldwide Corp., in which Judge Salas confirmed the FTC’s authority to bring enforcement actions to redress deficient corporate data security practices, even in the absence of formal rules or regulations setting forth what practices are unreasonable.

Federal Court Upholds FTC’s Authority to Bring Enforcement Actions Over Data-Security Standards; Will Class Actions Follow?

Already, 2014 has been an eventful year in the world of data breaches and cybersecurity. In addition to a flurry of litigation over high-profile breaches at the start of the year, the National Institute for Standards and Technology released its long-anticipated Cybersecurity Framework.