• A group of Attorneys General from 15 states, including Massachusetts, New York, and Illinois, filed a joint letter with the FTC in response to the December 2010 Staff Report on privacy (available here). They urged the FTC to maintain a role for states in the area of data security and privacy enforcement, arguing that federal privacy law should not preempt states from enforcing their own laws. They also proposed a “dual sovereignty model” in which both state and federal authorities would have the right to bring actions under federal law. In addition, the Attorneys General urged the FTC to adopt policies and regulations that take into consideration the size and resources of a business, as well as the types of private data that it possesses. The letter stressed the importance of protecting medical information and requiring informed consumer consent before location-based data is collected and used. To read the letter, click here.