The Federal Trade Commission’s Enforcement of Data Security Standards

June 10, 2015

Seemingly every week a front page headline reports a cyber attack involving the theft of the personal or financial information of millions of consumers.  Although companies that have suffered a data breach are victims of a crime, regulators and plaintiffs’ attorneys may seek to hold such companies liable for "failing to lock the door" to adequately protect the stolen data. 

Gibson Dunn of counsel Ryan Bergsieker and Richard Cunningham and associate Lindsey Young are authors of the following article recently published by The Colorado Lawyer.  They discuss the active and ongoing efforts by the Federal Trade Commission to hold companies responsible for sufficiently securing sensitive consumer data. 

The Federal Trade Commission’s Enforcement of Data Security Standards (click on link)

Ryan T. Bergsieker, a former federal computer crimes prosecutor based in the firm’s Denver office, handles cyber-related internal investigations, government enforcement defense, litigation and counseling.  Richard H. Cunningham, previously Senior Trial Counsel with the FTC’s Bureau of Competition, focuses on consumer protection and antitrust matters, including counseling, government investigations and litigation, also in Denver.  Lindsey Young, who practices in the firm’s litigation department in Palo Alto, previously worked in media and consumer behavior research.    

© 2015, The Colorado Lawyer, Vol. 44, No. 6, June 2015.  Reprinted with permission, 2015 Colorado Bar Association, 44 The Colorado Lawyer 39 (June 2015).    

Gibson, Dunn & Crutcher LLP   

For further information, please contact the Gibson Dunn lawyer with whom you usually work, the authors, or any of the following leaders of the Privacy, Cybersecurity and Consumer Protection practice group:

M. Sean Royall – Dallas (214-698-3256, [email protected])
Alexander H. Southwell – New York (212-351-3981, [email protected])
Debra Wong Yang – Los Angeles (213-229-7472, [email protected])

Denver of counsels Ryan Bergsieker and Richard Cunningham and Palo Alto associate Lindsey Young are the authors of “The Federal Trade Commission’s Enforcement of Data Security Standards” [PDF] published in the June 2015 issue of The Colorado Lawyer.