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Ushering in 2006 - FTC Not Waiting for Congressional Action on Data Security

January 03, 2006

By Behnam Dayanim and Kristine A. Rembach

The Federal Trade Commission’s recent consent decree with shoe discounter DSW Inc. represents the Commission’s broadest exercise of authority in the area of data security and sends a clear signal that the FTC is willing to take action even in the absence of a specific statutory data security mandate.