Abstract

In recent years, regulators in both the U.S. and the European Union (EU) have been increasingly aggressive in privacy enforcement within their respective jurisdictions. The enforcement trend follows expanded privacy protections adopted by U.S. regulators (such as the Federal Communications Commission's recently announced "net neutrality" privacy rules, as well as the extra-territorial reach of EU data protection authorities following the invalidation of a trans-Atlantic accord that had governed cross-border privacy protections). This governmental enforcement trend creates a template for ...