Month: April 2024
Fatal Flaws in SEC’s Amended Complaint Against SolarWinds
In March 2024, a coalition of more than 50 cybersecurity leaders and organizations called for dismissal of an amended complaint by the Securities and Exchange Commission (SEC) against SolarWinds and its chief information security officer (CISO), Tim Brown. Amici from the business community and the software industry, as well as […]
Understanding Washington’s My Health My Data (MHMD) Act: Applicability, Scope and Requirements
On January 31, 2024, Cooley lawyers Brooke Fritz and Andrew Epstein led a virtual presentation on Washington state’s My Health My Data (MHMD) Act. Below are some key highlights from the discussion. The MHMD Act’s origins and purposes:In an effort to close the “gap” that exists between consumer knowledge and […]
CISA Opens Notice and Comment Process on CIRCIA Draft Regulations
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) within the Department of Homeland Security published a long-awaited notice of proposed rulemaking (NPRM) pursuant to the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). Signed into law in 2022 by President Joe Biden, CIRCIA required CISA to […]
Washington State’s My Health My Data Act FAQ, Part Three – Enforcement Risks
In Part Three of our FAQ series on Washington state’s My Health My Data (MHMD) Act, we answer questions related to the MHMD Act’s enforcement risks – including the much-feared private right of action. Given the MHMD Act’s broad scope, its private right of action, the potential for large certified […]