So, You Just Got a Letter From the FTC: A Guide for Attorneys (Part Two of Two)

The receipt of a civil investigative demand from the FTC should not induce panic – a CID is “a vehicle for inquiry and we close far more [cases] than we bring,” Maneesha Mithal, Associate Director of the FTC’s Division of Privacy and Identity Protection, said during a panel at the recent IAPP Practical Privacy Series. Along with Mithal, the panel featured private outside counsel experts Stuart Ingis, a partner at Venable; and Hunton & Williams counsel Phyllis Marcus. They provided advice on how to handle a CID, from the first steps through requesting a closed case, including the view from behind the scenes at the FTC. In this second installment of our two-part series, we cover the FTC’s perspective on the CID process and how best to prepare for and conduct the meetings with the FTC staff and directors. Part one examined best practices for the first steps to take after receiving the CID, as well as strategies for setting up the client for a successful result. See also “FTC Director Analyzes Its Most Significant 2015 Cyber Cases and Provides a Sneak Peek Into 2016“ (Jan. 6, 2016).

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