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ENDURING CHANGES
SOCIAL MEDIA PLATFORM
Case-specific changes
03/11/2011
Twitter is a social networking website.
The FTC complaint alleged that they engaged in deceptive acts or practices because, despite their claims that they had implemented reasonable and appropriate measures to protect consumers' nonpublic information from unauthorized access, they did not prevent unauthorized administrative control of the Twitter system, such as by failing to implement practices to make administrative passwords hard to guess, restricting administrative control based on employee role, and enforcing changing of administrative passwords, leading to hackers using an automated password-guessing tool that gain access that allowed them to access nonpublic user information for all Twitter users, rest any user's password, and send unauthorized tweets from any user account.
Ceridian
Lookout
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Dave and Buster's
ENDURING CHANGES
CONSUMER RETAILER
Case-specific changes
06/08/2010
Dave and Buster's is a restaurant and entertainment complex that operates in-store networks and a computer network.
The FTC complaint alleged that they engaged in unfair acts or practices because they did not provide reasonable security for consumer information, such as by failing to restrict third-party access to its network, monitor and filter outbound traffic from its network, and failing to employ measures to detect and prevent unauthorized access to its network, leading to a hacker connecting to Dave and Busters network and accessing the payment card information of 130,000 consumers.
Lifelock
Dave and Buster's
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Lifelock
ENDURING CHANGES
CONSUMER SERVICE PROVIDER
Case-specific changes
03/09/2010
LifeLock promotes and sells identity theft services which place fraud alerts on consumers' online behavior.
The FTC complaint alleged that they engaged in deceptive acts or practices because, despite their claim that they had implemented reasonable and appropriate measures to protect consumer information from unauthorized access, they failed to encrypt consumer information both at rest and in transit, failed to require employees with access to consumer information to use hard-to-guess passwords, and failed to limit access to consumer information based on job need, potentially enabling a hacker to access consumer information stored on LifeLock's network or information in transit through LifeLock's network or over the internet.
Lifelock
Dave and Buster's