On August 24, 2015, the US Court of Appeals for the Third Circuit released its opinion in the closely watched case of Federal Trade Commission v. Wyndham Worldwide Corp., holding that the Federal Trade Commission (FTC) has the authority under the “unfairness” provision of Section 5 of the FTC Act to assert claims against Wyndham for failure to implement certain cybersecurity safeguards that allegedly resulted in three data breaches over several years.

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