Mr. Kniaz is an associate in Davis Polk’s Litigation Department, practicing in the Washington DC office. [Full Bio]

On June 6, 2018, the Eleventh Circuit vacated a cease and desist order issued by the FTC against LabMD as unenforceably vague.  The FTC’s Order, which resulted from a finding that LabMD had failed to maintain an adequate cybersecurity program, directed LabMD to “establish and implement, and thereafter maintain,
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One of the many difficult questions that companies face in the immediate aftermath of discovering a cyber breach is whether to inform their regulators or law enforcement.  Assuming there is no mandatory disclosure obligation, some companies are reluctant to call the government because (1) they may not know all the
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