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The U.S. Department of Justice (“DOJ”) Data Security Program (“DSP”) 90-day enforcement grace period ended as of July 8, 2025. While the program became effective April 8, 2025, DOJ implemented a 90-day enforcement grace period until July 8, 2025 for good-faith efforts towards compliance (see our previous blog here). With the expiration of the grace period, the majority of the DSP is now effective and will be enforced.Continue Reading DOJ’s 90-Day Data Security Compliance Grace Period is Over: Are You Compliant?

To kick off the New Year (and as is now tradition, since we put out a similar Recap & Forecast last year), Sheppard Mullin’s Governmental Practice Cybersecurity & Data Protection Team has prepared a cybersecurity-focused 2024 Recap (highlighting major updates and including links to the resources we put out over the past year) and a 2025 Forecast (previewing what we expect to see in 2025). This Recap & Forecast covers the following six high-interest topic areas relating to cybersecurity and data protection:Continue Reading Governmental Practice Cybersecurity and Data Protection: 2024 Recap & 2025 Forecast Alert

In Van Buren v. United States, No. 19-783 (U.S. June 3, 2021), the United States Supreme Court issued an opinion drastically limiting the application of the Computer Fraud and Abuse Act (CFAA) (18 U.S.C. § 1030 et seq.), holding that the “exceeds authorized access” clause of the Act applies only to those who obtain information from particular areas in the computer—such as files, folders, or databases—to which the individual is not authorized to access under any circumstances. However, the Supreme Court excluded application of the clause to individuals who misuse their access to obtain information otherwise available to them for an unauthorized purpose.
Continue Reading Supreme Court Resolves Circuit Split Over CFAA