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So far Judy Cochran has created 96 blog entries.

EU-U.S. Privacy Shield – European Commission Releases Draft Agreement

On Monday, the European Commission issued a draft of the newly minted EU-U.S. Privacy Shield Agreement.  The new agreement replaces the Safe Harbor provisions that regulates the transfer of personal data of European individuals between U.S. companies and countries in the European Union (“EU”).  After two years of coordinated effort between the U.S. and the [...]

Medical Equipment Company Will Pay $646 Million to Resolve FCPA, FCA and Anti-Kickback Investigations

The Department of Justice announced yesterday the resolution of multiple investigations of Olympus Corp. of the Americas (“OCA”), the U.S. arm of the Japanese camera and medical device manufacturer. OCA, the largest distributor of endoscopes and related equipment in the United States will pay $623.2 million to resolve criminal and civil False Claims Act violations [...]

The Core of the Apple Controversy is not About Lessening Security Measures

The recent controversy involving Apple’s refusal to assist with FBI efforts to obtain access to the iPhone used by the perpetrators of the San Bernardino massacre features a good deal of discussion about the use of encryption to prevent disclosure of data on the phone. This discussion is often framed as one involving the nature [...]

Reporting Deadline for 2015 PHI Breaches Affecting Fewer than 500 Individuals is February 29

Covered entities are required to report any breach of unsecured protected health information (“PHI”) to the Secretary of the U.S. Department of Health & Human Services, Office of Civil Rights (“OCR”). A covered entity’s breach notification obligations differ based on whether the breach affects 500 or more individuals or fewer than 500 individuals. For breaches [...]


One of the items on the startup’s to-do list is posting a privacy policy on its web site. Often they think that this is one item that won’t cost them anything if they take the do-it-yourself approach, meaning (i) finding a privacy policy that looks good on a website, (ii) copying it, (iii) searching and [...]

California Hospital IT Systems Held Hostage by Ransomware Attack

The Hollywood Presbyterian Medical Center in Los Angeles, California. MARIO ANZUONI / Reuters Today national news outlets are reporting a hacking assault on Hollywood Presbyterian Medical Center in California. According to authorities, the hospital was the victim of a cyber-attack on February 5 that locked the hospital out of its computer systems using [...]

PTC Agrees to $26 Million Settlement to Resolve China FCPA Violations

Massachusetts software company, PTC, Inc. (“PTC”) agreed to pay a $14.5 million criminal penalty to resolve a Department of Justice (“DOJ”) investigation into payments for recreational travel by Chinese government officials that violated the Foreign Corrupt Practices Act “(“FCPA”) and a civil settlement with the U.S. Securities and Exchange Commission (“SEC”) by disgorging $11.8 million. [...]

DOJ Asks for $1.1 Billion Increase for Enforcement Components in FY 2017 Budget

The Department of Justice released President Obama’s FY 2017 Budget proposal on Tuesday, asking for an increase of $1.1 billion for the department’s law enforcement divisions. The overall FY 2017 Budget proposal is $29 billion to support federal enforcement priorities and the criminal justice priorities of state, local and tribal law enforcement partners. The proposed [...]

2016 PATH Real Estate Tax Updates

Several US tax provisions specific to real estate investing were recently enacted as part of the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act” or “Act”) approved by President Obama in December of 2015. Below are the highlights. Currently, the definition of a QFPF applies only with regard to FIRPTA withholding, not [...]