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Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security, and consumer protection issues.

Data security will undoubtedly remain an enforcement priority for the Federal Trade Commission in 2023. A presentation on the FTC’s approach to data security by Deputy Chief Technologist Alex Gaynor at a Commission open meeting on December 14, 2022, highlighted four provisions found in one or more recent FTC consent orders as particularly important, though