Volume: 14 Issue: 2
steptoe & johnson
On 5 January 2017, the Federal Trade Commission (‘FTC’) filed a complaint in the U.S. District Court for the Northern District of California against a Taiwanese network equipment maker, D-Link Corporation, and its US subsidiary, alleging that they had violated the FTC Act 1914 by failing to take reasonable steps to secure their wireless routers and webcams. Most notably, the complaint neither alleges that consumer data was actually breached nor claims that there were any specific instances of tangible harm resulting from vulnerabilities in D-Link’s products. Michael A. Vatis, Partner at Steptoe & Johnson LLP, analyses the FTC’s complaint and the FTC’s former data security enforcement, and discusses whether the change in the FTC’s leadership as a result of the US Presidential election will result in a change of the FTC’s course.