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

Receiving a civil investigation demand (CID) from the FTC can be nerve-wracking, but there are ways to make the process smoother. During the recent IAPP Practical Privacy Series 2015, a panel of government and private outside counsel experts provided advice on how to respond to written requests and steps companies can take to best position themselves in front of the agency, starting with the first telephone call. The panel featured Maneesha Mithal, FTC Associate Director, Division of Privacy and Identity Protection; Venable partner Stuart Ingis; and Hunton & Williams counsel Phyllis Marcus. Part one in this two-part series examines best practices for first steps after receiving the CID, including the first call with the client and the initial contact with the FTC, as well as strategies for setting up the client for a successful result. Part two will 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. 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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