Privacy Law Matters Blog

By Emily Litka On July 9, 2024, The Federal Trade Commission (FTC) and the Los Angeles District Attorney’s Office (LA DA) reached a settlement with NGL Labs, the maker of the “NGL: ask me anything” app and its co-founders. The complaint alleged violations of the Federal Trade Commission Act (FTC Act), the Children’s Online Privacy…

By Destiny Ginn Under a proposed stipulated order dated September 11, 2023, background check providers, Instant Checkmate, TruthFinder, The Control Group media company, IntelicareDirect, and PubRec, will be required to pay $5.8 million for alleged violations of the Fair Credit Reporting Act (FCRA) for activities as consumer reporting agencies (CRA) and of the Federal Trade…

By Sheila Sokolowski and Kate Black In a joint letter sent to 130 hospital systems and telehealth providers, the Federal Trade Commission (FTC) and the U.S. Department of Health and Human Services (HHS) warned health care providers, both those covered by HIPAA and those not, about their potential to violate the HIPAA Rules, FTC Act…

By Amy Lanchester On May 22nd, 2023, the Federal Trade Commission (FTC) issued a proposed order against Edmodo, LLC (“Edmodo”), a California-based education technology provider, for allegedly violating the FTC’s Children’s Online Privacy Protection Rule (“COPPA Rule") by illegally collecting the information of children and using that information for advertising, and for allegedly violating Section…

By Kate Black and Sam CasticThe Federal Trade Commission recently announced two enforcement actions under the FTC Act against digital health companies that focus on the use and disclosure of information for online advertising purposes. The agency's complaints against GoodRx and BetterHelp exhibit several shared themes and offer five lessons for companies that are looking…

By Sheila Sokolowski On March 2, 2023, the Federal Trade Commission (FTC) issued a proposed consent order with BetterHelp, Inc. (BetterHelp), an online counseling service, for allegedly misrepresenting its privacy practices and sharing information about consumers’ interest in or use of mental health counseling services (which the FTC alleges to be sensitive health information), in…

By Sheila Sokolowski, Kate Black, and Mason Fitch On February 1st, 2023, the Federal Trade Commission (FTC) issued a proposed order against GoodRx Holdings, Inc. (GoodRx), a digital health platform, for allegedly violating Section 5 of the FTC Act by making deceptive statements about its sharing of health data. In addition, in its first enforcement…

By Sheila Sokolowski and Charlotte Lunday  Following up on its warning that it would be cracking down on Education Technology companies, the Federal Trade Commission (FTC) issued a proposed order against Chegg Inc., an online tutoring and homework aid service for high school college students, for lax security practices. According to its complaint, the FTC…

By Charlotte Lunday The Federal Trade Commission hosted an event October 19, 2022, discussing digital advertising to kids. The event primarily focused on “blurred” or “stealth” advertising. Blurred advertising refers to ads that are difficult to distinguish from substantive content. One example of this type of advertising would be an ad that appears to be…

By Susan Hintze and Sam CasticOn August 11, 2022, the Federal Trade Commission (“FTC”) published an advance notice of proposed rulemaking (“ANPR”) in a 3-2 vote on party lines requesting public comment on questions covering a wide range of “commercial surveillance” and data security practices.  The FTC defines “commercial surveillance” to include a wide array…