Noted hospitality company Wyndham Worldwide Corporation (and certain of its hotel business subsidiaries) and the Federal Trade Commission (FTC) last month entered into a landmark settlement resolving an FTC enforcement action1 related to hackers breaching the Wyndham Hotels and Resorts network on three occasions between May 2008 and January 2010 and obtaining the personal and financial data of guests from the networks of several Wyndham-branded hotels.

The Stipulated Order,2 entered by the U.S. District Court on Dec. 11, 2015, is remarkable for the reasons set forth below and should prove of great comfort to franchisors nationwide who now face, or in the future may face, similar actions relating to data breaches occurring in their networks.

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