Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 3228 In early 2015, the NY Attorney General proposed legislation to help strengthen cybersecurity laws. The proposed legislation expands the definition of private information to include email addresses, medical information, and health insurance information. It also requires companies to notify consumers and employees in the event of a breach, and encourages companies to share information with law enforcement by granting them a safe harbor where there are data breaches. On February 25, 2015, President Barack Obama “directed the Director of National Intelligence to establish what will be known as the Cyber Threat Intelligence Integration Center (CTIIC).” The CTIIC will be a news agency designed to combat cybersecurity threats by using information from all the different agencies currently involved in combating foreign and domestic cyber threats so that the information is more effectively communicated and used to protect U.S. interests. In FTC v. Wyndham Worldwide Corp., the FTC sued Wyndham in the wake of three cybersecurity attacks that allegedly exposed the personal information of “hundreds of thousands of consumers [and led] to over $10.6 million in fraudulent charges.” The FTC brought suit under the “unfair or deceptive acts or practices” provision of the FTCA—15 U.S.C. § 45(a)—claiming that Wyndham’s failure to establish and maintain reasonable cybersecurity protocols allowed the hackers to attack Wyndham’s systems. The Third Circuit decided that the FTC had the authority to regulate cybersecurity under the unfairness prong of § 45(a) and that Wyndham had notice that its cybersecurity practice could fall short of § 45(a) because it had been hacked in the past, among other reasons. WHAT WE'RE WATCHING: 2016 EMERGING ISSUES Cybersecurity Following several high-profile data breaches in late 2014, cybersecurity remained a hot topic in 2015, and we expect the focus in this area to continue. Below are just a few cybersecurity developments over the year.