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A collection of 9 posts

Amazon Snuck Promoted Products Into Its Baby Registries: Lessons for In-House Lawyers

Ed note: I wrote this in 2019 and published it to my earlier blog. It's still relevant, so I'm reposting it here. From a WSJ article [https://www.wsj.com/articles/new-parents-complain-amazon-ads-are-deceptive-1543417201] titled “New Parents Complain Amazon Baby-Registry Ads Are Deceptive”: > Kima Nieves recently received

Privacy Harms: An Overview (or, Why We Won't Have Broad U.S. Privacy Regulations Anytime Soon)

Ed note: I wrote this in 2018 and published it to an earlier version of this blog. The content is still relevant, so I'm reposting it here. tl;dr People have drastically different sensitivities about privacy. Some believe that only those acts that cause some real-world negative consequences,

All the Privacy Scandals in One Place

When you're thinking through a privacy issue, it's helpful to look at the relevant precedent. But, it's not so easy to find—some of it is in FTC consent decrees, some of it is in class action lawsuits, and some of it is in press stories that, for one reason or another, never turned into litigation.

Counseling Privacy Issues and Expectations: Four Questions and a Framework

Privacy Featured

Counseling Privacy Issues and Expectations: Four Questions and a Framework

It sucks to botch privacy issues. It feels professionally bad (like, how did I not see that coming!?) and people—Twitter, the press, users, and, in extreme cases, regulators and plaintiffs’ attorneys—won’t let you forget it.

Why Sears Holdings is a critical FTC consent decree

The Sears consent decree dispels the notion, still common among some clients and some attorneys, that a privacy policy disclosure is a cure-all. Sears released a consumer research app that paid consumers $10 to join an “online community” of Sears Holding

Did Google violate its security obligations by retaining just two weeks of logging data?

Did Google violate its security obligations by retaining just two weeks of logging data?

Here’s the background in case you missed it: Google+ had a vulnerability which made it possible for third parties to access, via the Google+ API, private Google+ user data between 2015 and March 2018. Google found no evidence that this bug was ever exploited, although it only had two