Blog Archives

Dwolla and the CFBP – Is mere puffery a deceptive practice in cyber-security?

The Consumer Financial Protection Bureau (“CFPB”) filed an interesting consent order in re: Dwolla, Inc. concerning their cyber security practices. 1)See “CFPB Takes Action Against Dwolla for Misrepresenting Data Security Practices”, available at The order begins with CFPB identifying

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Understanding the Implications of FTC v. Wyndham on Data Security Practices

The Federal Trade Commission (FTC) is very active and interested in data breaches and other cyber security incidents. The federal government and many state governments are slowly adding legislation that specifically addresses issues of cyber security and data breach reporting,

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Ashley Madison – Thoughts about Cyber Liability

I’ve written about the Ashley Madison data breach before especially about their use of DMCA takedown notices. Today a short twitter conversation about technicalities gave me a thought to write something brief about how insurance coverage and cyber liability interact

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Ashley Madison – Adulterous Data Breach and Copyright Takedown Notices

Ashley Madison is a website devoted to facilitating adultery. That is literally their customer base – married individuals seeking to cheat on their spouses. Their trademark slogan is, “Life is short. Have an affair.” They further self-describe their operation as,

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The Hacking Team Data Breach in a Nutshell

I wrote briefly about the Hacking Team Data Breach yesterday in the context of data breaches generally. This is an interesting area of the law because of all the high profile breaches in the last couple of years, the upsurge

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