Data Privacy + Cybersecurity team chair Linn Freedman was quoted in an article titled “Illusory Systems Settlement Shows FTC Active and Focused on Crypto,” published in Cybersecurity Law Report on February 4, 2026. The article highlights the Trump administration’s Federal Trade Commission’s (FTC) active enforcement in the data security area—especially when it is concerning cryptocurrency—with its proposed consent order to Illusory Systems for its alleged failure to implement adequate security measures, which allowed hackers to breach its systems and steal $186 million from consumers.

“Companies should be transparent with consumers about how they use security measures that are reasonable for their size, scope, and complexity,” said Linn. “They should also ensure that there is good communication and collaboration between the technical/security people and the sales/marketing staff, to discourage the latter from ‘puffing what the data security measures are.’”

Linn also comments on Illusory Systems’ alleged misrepresentations of security and the FTC’s comments on their lax approach to data security, stating that the FTC alleged that “[T]he company knew of the issues with its security, but it did not resolve those issues and ‘just ignored’ them.” In response, the FTC ordered it to implement a comprehensive information security program, return $37.5 million in assets recovered after the breach to consumers, and fall under a 10-year monitoring term to ensure its data practices meet compliance standards.

To read the article, click here.