Earlier this year, the SEC released its Interpretive Statement and Guidance on Public Company Cybersecurity Disclosures (“Guidance”).
The SEC then sued Yahoo! alleging that Yahoo! had delayed disclosing a massive breach of its user database, which was disclosed only when Yahoo! was selling its operating business to Verizon.
The enforcement proceeding resulted in a $35 million fine.
Law.com presents an analysis of the decision here.