Kelly Singleton

Firm/Organization: Wilson Sonsini Goodrich & Rosati

Latest Articles

WSGR Event Recap: The State of Play at the FTC on Privacy

May 3, 2019

On May 1, 2019, WSGR held an event in which regulators and experts discussed privacy developments in the U.S. and Europe. The first session featured a fireside chat with the Federal Trade Commission’s (FTC’s) Bureau of Consumer Protection Director, Andrew Smith, on “The State of Play at the FTC on Privacy.” In case you missed it, here are the key takeaways from the discussion: More specificity in data security orders. Director Smith noted that we…

The WSGR Data Advisor

New Colorado Law Takes Effect That Includes Strict 30-Day Data Breach Notification Requirement

By Kelly Singleton

October 8, 2018

On September 1, 2018, a new Colorado law took effect that, among other things, amends the state’s data breach law to: (1) expand the scope of the categories of “personal information” that trigger notification requirements; (2) require notification to residents and the state attorney general no more than 30 days after determining that a security breach has occurred; and (3) specify what must be included in these notifications.1 In addition, the statute requires entities…

The WSGR Data Advisor

Federal Judge Allows Researchers’ First Amendment Challenge to CFAA’s “Access” Provision to Move Forward

By Kelly Singleton

May 23, 2018

On March 30, 2018, in Sandvig v. Sessions,1 the U.S. District Court for the District of Columbia held that a group of academic researchers can move forward with their First Amendment challenge to the Computer Fraud and Abuse Act (CFAA),2 a federal law that criminalizes, among other things, accessing a computer in a manner that “exceeds authorized access.” The CFAA was enacted in the early 1980s in response to concerns that there were…

The WSGR Data Advisor

New FTC Report Recommends Steps to Improve Mobile Security Updates

By Matthew Staples & Kelly Singleton

May 23, 2018

In February 2018, the Federal Trade Commission (FTC) released a report that explores the complexities of the mobile ecosystem and makes recommendations for industry to improve the mobile security update process for consumers. The report is part of the FTC’s effort to address concerns that mobile devices are not receiving the operating system patches they need to defend against attacks. It begins by highlighting that even though three-quarters of Americans own smartphones and increasingly rely…

The WSGR Data Advisor

“Two Cops on the Beat is Nothing Unusual”: Ninth Circuit Reverses Panel Decision, Rules FTC Act’s “Common Carrier” Exemption is Activity-Based

By Lydia Parnes & Kelly Singleton

March 26, 2018

On February 26, 2018, the U.S. Court of Appeals for the Ninth Circuit issued an en banc decision in FTC v. AT&T holding that the Federal Trade Commission (FTC) Act’s “common carrier” exemption is activity-based, reversing the panel’s decision that the exemption is status-based, which would have opened a large enforcement gap for telecommunications companies like AT&T. This is an important decision in terms of FTC jurisdiction: it means that the FTC can and will…

The WSGR Data Advisor

FTC Announces Settlement with PayPal for Alleged FTC Act and GLBA Violations by Venmo

By Edward Holman & Kelly Singleton

March 26, 2018

On February 27, 2018, the Federal Trade Commission (FTC) announced1 that it had reached an agreement with PayPal to settle allegations that its peer-to-peer payment service, Venmo, engaged in deceptive acts and practices and violated the Gramm-Leach-Bliley Act (GLBA)’s Safeguards Rule2 and Privacy Rule.3 Since 2011, Venmo has offered peer-to-peer payment services through an app that consumers can download, link to their external bank accounts, and use to transfer and receive money…

The WSGR Data Advisor

Illinois Appellate Court Holds That BIPA Plaintiffs Must Show Actual Harm

By Kelly Singleton

March 26, 2018

On December 21, 2017, the Illinois Second District Appellate Court dealt a significant blow to the recent wave of Illinois Biometric Information Privacy Act (BIPA) class actions, holding in Rosenbach v. Six Flags Entertainment Corp. that plaintiffs alleging mere procedural violations of BIPA, without “any injury or adverse effect,” are not “aggrieved” persons entitled to any relief—monetary or otherwise—under the statute.1 BIPA prohibits companies from collecting biometric information from individuals without notice and written…

Kelly Singleton

WSGR Event Recap: The State of Play at the FTC on Privacy

New Colorado Law Takes Effect That Includes Strict 30-Day Data Breach Notification Requirement

Federal Judge Allows Researchers’ First Amendment Challenge to CFAA’s “Access” Provision to Move Forward

New FTC Report Recommends Steps to Improve Mobile Security Updates

“Two Cops on the Beat is Nothing Unusual”: Ninth Circuit Reverses Panel Decision, Rules FTC Act’s “Common Carrier” Exemption is Activity-Based

FTC Announces Settlement with PayPal for Alleged FTC Act and GLBA Violations by Venmo

Illinois Appellate Court Holds That BIPA Plaintiffs Must Show Actual Harm

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