On December 17, 2015, the FTC issued its largest monetary award ever. An identity theft
protection company, LifeLock, agreed to pay consumers $100M to
settle FTC charges that it violated the terms of a 2010 federal court order regarding the
security of personal information and deceptive advertising. In the
2015 action, the FTC alleged that LifeLock: (i) failed to
comprehensively secure consumer data, as ordered in 2010; (ii)
falsely advertised that it had a comprehensive information security
program in place; (iii) falsely advertised that it would notify
consumers of indications of identity theft; and (iv) failed to
abide by recordkeeping requirements.
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