Proactive Protection of Consumers or Premature Penalty? Consumer Financial Protection Bureau Bucks the Trend in Data Security Breach Cases Authors: R. Bruce Allensworth bruce.allenswort@klgates.com +1.617.261.3119 Ryan M. Tosi ryan.tosi@klgates.com +1.617.261.3257 Lindsay S. Bishop lindsay.bishop@klgates.com +1.617.951.9198 Anchorage Austin Beijing Berlin Boston Brisbane Brussels Charleston Charlotte Chicago Dallas Doha Dubai Fort Worth Frankfurt Harrisburg Hong Kong Houston London Los Angeles Melbourne Miami Milan Newark New York Orange County Palo Alto Paris Perth Pittsburgh Portland Raleigh Research Triangle Park San Francisco São Paulo Seattle Seoul Shanghai Singapore Spokane Sydney Taipei Tokyo Warsaw Washington, D.C.

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