FTC Publishes Revised Guides for Advertising Allowances and Other Merchandising Payments

by Wiggin and Dana LLP | Sep 15, 2019

Recently, for the first time in 24 years, the Federal Trade Commission (“FTC”) published revisions to its guidelines on advertising allowances and other promotional payments and services, widely known as the Fred Meyer Guides (“Guides”)....

False Claims Act Update: Heightened Risk and Record Settlements Predicted in Fiscal Year 2015

by Wiggin and Dana LLP | Sep 15, 2019

False Claims Act (“FCA”) settlements and judgments continued their striking rate of growth in fiscal year 2014. According to the Department of Justice (“DoJ”), FCA settlements and judgments for the year surpassed the $3.8 billion the government...

Time to Focus on Compliance Programs Again: SEC Enforcement Actions and Sanctions Are On The Rise

by Wiggin and Dana LLP | Sep 15, 2019

Probably to no one’s surprise, given the SEC’s much publicized enforcement efforts, the Commission has announced that it filed a record number of enforcement actions over the last three fiscal years and secured record payouts in penalties and...

‘Kill Chain’ Analysis of Target Data Breach is a Chilling Read for Corporate Cybersecurity and Privacy Professionals

by S Z | Sep 15, 2019

A staff report on last year’s consumer data breach at Target Corporation, released today by the Senate Committee on Commerce, Science and Transportation (Rockefeller, D-WV, Chair), provides a gripping wake-up call for those who oversee the security of corporate...

District Court Judge Applies ‘Negative Multiplier’ to Reduce Requested Attorneys’ Fees

by Wiggin and Dana LLP | Sep 15, 2019

On February 28, 2014, Chief Judge George King of the United States District Court for the Central District of California issued an In Chambers Order reducing requested attorneys’ fees from a whopping $3,253,902 to a mere $91,715 by, among other things,...