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Assessing the Federal Trade Commission’s Privacy Assessments
Why read this article? This short article points out the big differences between an "audit," and an "assessment," the latter of which is the tool used by the Federal Trade Commission to oversee companies that [...]
Comments on the CCPA
I filed the following comments today on the CCPA to the CA AG. March 8, 2019 VIA Email California Department of Justice ATTN: Privacy Regulations Coordinator 300 S. Spring St. Los Angeles, CA 90013 Re: [...]
Amsterdam Privacy Conference 2018
Opening keynote talk on The Tethered Economy, 87(4) Geo. Wash. L. Rev. ___ (2019)(with Aaron Perzanowski and Aniket Kesari), Amsterdam Privacy Conference, Oct. 2018.
Syllabi
I'm getting a lot of requests for my syllabi. Here are links to my most recent courses. Please note that we changed our LMS in 2014 and so some of my older course [...]
Embrace legitimate cost–benefit analysis, recognize that much of it is not legitimate
From Federal Trade Commission Privacy Law and Policy, Chapter 12: The FTC is surrounded by critics who urge that Agency actions must be more “rigorous” or based in the “sound economic policy” of cost–benefit analysis. [...]
Bait-and-switch advertising, bait-and-switch privacy
From Federal Trade Commission Privacy Law and Policy, Chapter 12: Professor Ross Petty highlighted that some of Posner’s objections reflected unstated assumptions and that recognizing these help us see the deficits of the Posner critique.27 [...]