For the first time, the Federal Trade Commission has brought an enforcement action under its 2009 Health Breach Notification Rule (HBNR). The case was brought against a digital health company, GoodRx Holdings, Inc., for sharing users’ health information with third-party advertising platforms without the authorization of the users whose data was being shared.

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Photo of Rebecca Engrav Rebecca Engrav

Rebecca Engrav litigates disputes for technology companies regarding online advertising, privacy and data security, user-generated content and intellectual property.

Photo of Janis Kestenbaum Janis Kestenbaum

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…

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.

Photo of Zubin Khambatta Zubin Khambatta

As a partner in Perkins Coie’s Healthcare industry group, Zubin Khambatta has devoted his career to representing major hospital systems, free-standing hospitals, specialty and pediatric physician practices, clinical laboratories, telehealth providers, academic medical centers, and behavioral health and other providers in complex transactional…

As a partner in Perkins Coie’s Healthcare industry group, Zubin Khambatta has devoted his career to representing major hospital systems, free-standing hospitals, specialty and pediatric physician practices, clinical laboratories, telehealth providers, academic medical centers, and behavioral health and other providers in complex transactional, regulatory, and reimbursement matters.

Photo of Cassi Carley Cassi Carley

Cassi Carley returns to Perkins Coie after working as a privacy, data, and security fellow for 2019 and 2020.

Photo of Laura DePonio Laura DePonio

Laura DePonio advises clients on healthcare industry matters related to business transactions and regulatory compliance.