The Federal Government continues ramping up enforcement of data security requirements by deploying significant new enforcement theories and tools in support of cyber and data security controls required by federal law. Specifically, the DOJ and FTC recently entered into settlements with private companies that underscore these cybersecurity mandates and the additional investment of resources devoted to enforcing them by the Federal Government.
Why are these cases important?
- The DOJ settlement is the first False Claims Act case involving DOJ’s Civil Cyber-Fraud Initiative.
- The FTC settlement involves not only the current owner of the entity that experienced multiple data breaches, but also that entity’s former owner.
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