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Surviving an FTC Investigation After a Data Breach

New York Law Journal

September 18, 2008

Lisa J. Sotto, a partner at Hunton & Williams and vice chair of the Department of Homeland Security's Data Privacy and Integrity Advisory Committee, and Aaron P. Simpson, an associate with the firm, write that an FTC investigation and enforcement action against a company as a result of a data security incident can take over two years, cost the target company millions of dollars in legal and consulting fees and end in obligations on target companies that last decades into the future. Also in this issue of GCNewYork, "Protective Orders Guard Against Unwarranted Depositions of Executive" and "'Manifest Disregard' After 'Hall Street': The Early Returns."

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