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Cyber Barbarians & Federal Data Breaches In 2006

Client Alert | 1 min read | 10.25.06

In 2006, the lost Veterans Affairs laptop compromising the personal information of 26.5 million veterans represented just one of the hordes of information security breaches that flooded federal agencies, triggering Congressional hearings, GAO and IG investigations, and new OMB information security standards for federal agencies and contractors alike. In his article "When Cyber Barbarians Storm the Security Walls: The Mounting Risks of Security Breaches to Federal Agencies & Contractors" published in the Federal Contracts Report on October 3, 2006 (http://www.crowell.com/pdf/Security-Breach_Bodenheimer.pdf), David Z. Bodenheimer identifies the evolving rules governing federal information security and explains how the escalating federal outsourcing trends mean greater opportunities for contractors in the IT and cybersecurity business, but also that such opportunities come with mounting risks of tougher Congressional scrutiny, federal enforcement actions, and third-party litigation.

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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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