In an excellent blog post, “Avoiding AI Pitfalls in 2026: Lessons Learned from Top 2025 Incidents,” ISACA’s Mary Carmichael summarizes lessons learned from top incidents in 2025 using MIT’s AI Incident Database and risk domains. According to Carmichael, an analysis of the incidents showed recurring patterns across different risk domains, including privacy, security
Linn Foster Freedman
Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law. Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.
Privacy Tip #472 – FTC Issues Proposed Order Against Illusory Systems Over Allegations of Lax Security
On December 17, 2025, the Federal Trade Commission (FTC) issued a press release announcing that it is taking action against Illusory Systems, Inc. “for failing to implement adequate data security measures, leading to a major security breach in which hackers stole $186 million from consumers.”
In its complaint, the FTC alleged that Illusory, doing business…
FBI Warns of Account Takeover Fraud
On November 25, 2025, the Federal Bureau of Investigation (FBI) published a Public Service Announcement warning that cyber criminals are “impersonating financial institutions to steal money or information in Account Takeover (ATO) fraud schemes.” These schemes target individuals and businesses of all sizes across all sectors. According to the announcement, “Since January 2025, the FBI…
Cyber Insurer Offers Product for Deepfakes
Deepfakes continue to be problematic for organizations and individuals. They are hard to detect and hard to respond to when used in an attack against a company.
To respond to this ongoing, and increasingly prevalent, problem, cyber insurer Coalition announced this week that it will expand coverage for “certain incidents where AI and deepfakes lead…
Privacy Tip #471 – SMS Phishing on the Rise Before the Holidays
The holidays are always a busy time—sending holiday cards, cooking, present shopping and giving, and spending time with family and friends. It’s also an opportune and busy time for scammers too.
A new report by KrebsonSecurity reminds us that fraudsters use the holidays to launch new campaigns, in this case, SMS phishing scams. According to…
Threat Actors Targeting Messaging Applications
On November 24, 2025, the Cybersecurity & Infrastructure Security Agency (CISA) issued an alert titled “Spyware Allows Cyber Threat Actors to Target Users of Messaging Applications,” which outlines how “multiple cyber threat actors” are “leveraging commercial spyware to target users of mobile messaging applications.”
The threat actors “use sophisticated targeting and social engineering techniques to…
FTC Settles With Illuminate for Data Breach of $10M Students’ Data
On December 1, 2025, the Federal Trade Commission (FTC) approved a proposed complaint and order against Illuminate Education, Inc., an education technology provider requiring it to “to implement a data security program and delete unnecessary data to settle allegations that the company’s data security failures led to a major data breach, which allowed hackers to…
Privacy Tip #470 – Consumer Group Warns that AI Chatbots in Toys Contain Sexually Explicit Messages
In its 40th anniversary report, Trouble in Toyland 2025, the Public Interest Research Group (PIRG) warns that “[T]oys with artificial intelligence bots or toxics present hidden dangers. Tests show A.I. toys can have disturbing conversations. Other concerns include unsafe or counterfeit toys bought online.”
The report outlines PIRG’s testing of four toys (Curio’s Grok…
Compromised Credentials Responsible for 50% of Ransomware Attacks
- August and September showed a sharp increase in ransomware activity, with those months accounting for 26% and 18% of reported ransomware incidents in the last half year, respectively.
- Akira, Qilin, and INC Ransomware represented 65%
DOJ Subpoena for Patient Records from Children’s Hospital of Philadelphia Blocked by Federal Court
On November 21, 2025, in a lengthy decision, U.S. District Judge for the Eastern District of Pennsylvania Mark A. Kearney quashed a subpoena issued by the U.S. Department of Justice (DOJ) to Children’s Hospital of Pennsylvania’s Gender and Sexuality Development Program (CHOP) seeking documents:
(1) identifying the names, addresses, and social security numbers of…