Penalty Amount
$16,000,000
Connecticut, as part of a 40-state coalition, secured multistate settlements totaling over $16 million with Experian and T-Mobile related to data breaches in 2012 and 2015 that exposed consumers' personal information. Experian agreed to pay $12.67 million and implement enhanced data security measures, while T-Mobile agreed to pay $2.43 million and strengthen vendor management. Additionally, Experian Data Corp. paid $1 million to resolve a separate 2012 breach investigation, with all entities required to improve data protection practices.
Experian agreed to pay $12.67 million and implement a comprehensive information security program with zero-trust principles, due diligence, data minimization, and specific security requirements. T-Mobile agreed to pay $2.43 million and implement a vendor risk management program with contractual security requirements for vendors. Experian Data Corp. agreed to pay $1 million to improve vetting of third parties and maintain a Red Flags program. Experian also must offer 5 years of free credit monitoring to affected consumers.
In-house legal teams should review vendor agreements (particularly those involving data brokers or credit reporting agencies like Experian), customer agreements (such as telecom service contracts with T-Mobile), and any data processing addendums. Focus on clauses governing data security obligations, breach notification timelines and procedures, audit and inspection rights, indemnification for data breaches, data encryption and access control standards, incident response plans, data retention and disposal policies, and vendor oversight requirements. Changes may include strengthening security specifications (e.g., mandatory encryption, regular penetration testing), clarifying breach notification within 72 hours, requiring third-party security audits, enhancing vendor due diligence and monitoring provisions, and updating indemnification terms to cover regulatory fines and consumer redress.
Entity
Experian; T-Mobile
Industry
Data Broker$2.0M
Attorney General Tong and a coalition of four other states and the FTC sued Zillow and Redfin after Zillow paid Redfin $100 million to shut down its multifamily rental advertising business and transfer clients to Zillow. The settlement requires the companies to restore competition, with Redfin rebuilding its apartment advertising business, and pay $2 million to the coalition.
Attorney General William Tong sent a letter to the Connecticut Insurance Department urging rejection of double-digit rate increases sought by Anthem, ConnectiCare, and UnitedHealthcare for individual and small group health insurance plans covering about 220,000 people. The letter argues the rates exceed inflationary measures and criticizes the carriers for failing to control costs and for poor claims system management, particularly ConnectiCare's transition to Molina Healthcare.
$275K
Connecticut Attorney General William Tong announced a $275,000 settlement with TaxAct, an online tax preparation company, over allegations that between January 2018 and December 2022, TaxAct improperly disclosed detailed customer financial information to Meta and Google through third-party tracking technologies without notifying taxpayers. The settlement requires TaxAct to pay $275,000 and implement new third-party tracking compliance measures, including a review committee, written policies, a tag monitoring system, and two independent third-party audits.
$4.0M
Connecticut Attorney General William Tong and the Federal Trade Commission announced a $4 million settlement with Manchester City Nissan (Chase Nissan LLC) resolving allegations that the dealership double-charged for 'certified pre-owned' vehicles and collected unauthorized junk fees. The settlement requires payment for consumer redress, prohibits misrepresentations, mandates clear disclosure of the maximum total price, and requires express informed consent for all charges.
Attorney General Tong and a coalition of 21 attorneys general and Pennsylvania filed lawsuits against the U.S. Department of Transportation, FMCSA, and DHS to block demands for the personal information of 17 million CDL drivers. The lawsuits allege violations of federal privacy laws and the Administrative Procedure Act, and seek an emergency order to prevent the data transfer.
Attorney General William Tong and a coalition of 10 attorneys general filed a lawsuit challenging a new OCC rule that preempts state laws requiring national banks to pay interest on homeowners' mortgage escrow accounts. The lawsuit argues the OCC ignored federal court decisions and bypassed safeguards, and seeks to block the rule.