Kyle Dull is a senior associate in the Data Privacy, Cybersecurity & Digital Assets Practice and a Certified Information Privacy Professional (IAPP CIPP/US). A former Assistant Attorney General, he advises industry-leading companies on domestic and international privacy laws, as well as on consumer protection, advertising, and retail and e-commerce laws and self-regulation.

Clients regularly turn to Kyle for his knowledge and know-how in defending and resolving federal and state regulatory and enforcement actions. Informed by his prior position in the Florida Attorney General’s Consumer Protection Division, Kyle has extensive experience in investigating and litigating privacy and advertising law violations. During his time in the AG’s office, Kyle focused on singular and multistate enforcement actions involving advertising, marketing, price gouging, consumer finance, privacy and cybersecurity. He now draws on that experience to share insights with and advise clients on their own data privacy, cybersecurity and advertising risks.

Kyle also helps clients develop and implement effective e-commerce business and marketing strategies. He routinely advises clients on technology, data privacy and security, intellectual property, advertising and marketing, and website development matters. In addition to regulatory counseling, Kyle negotiates and drafts a broad array of contracts, including licensing, joint venture and data sharing agreements.

In all aspects of his work, Kyle remains focused on helping clients achieve their privacy governance and advertising objectives while balancing consumer interests.

Kyle is a member of the Florida Bar Association’s Consumer Protection Law Committee and Data Privacy & Cybersecurity Subcommittee.

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  • Coordinating the breach response of a large publicly traded, multinational company, including analysis of breach notification obligations for all 50 states and Canada.
  • Counsels clients on general advertising issues, including adequate disclosures, gift cards, automatic renewals, marketing of products under development, and health and wellness claims.
  • Defends businesses before the Federal Trade Commission (FTC) and state Attorneys General, including California Consumer Privacy Act (CCPA) enforcement actions brought by the California Attorney General, COVID-19-related inquiries by the New York Attorney General and Department of Justice, data breach enforcement actions, and advertising and privacy investigations by the FTC.
  • Advises clients on CCPA and California Privacy Rights Act (CPRA) compliance, including loyalty program compliance, third-party cookie issues and privacy disclosures.
  • Works with clients to develop text, telemarketing, email and digital advertising campaigns in order to reduce TCPA and CAN SPAM risks.
  • Counsels clients on FOSTA-SESTA compliance and the immunity protections provided by Section 230 of the Communications Decency Act.
  • Advises clients in heavily regulated industries on sweepstakes and advertising compliance nationwide.

Prior Government Experience

  • Negotiated settlements with e-commerce companies for fictitious pricing, unsubstantiated claims, deceptive advertisements, and failure to clearly and conspicuously disclose material terms and conditions.
  • Led and organized multistate investigations with other state attorney generals, including investigations of an e-cigarette company, social media platforms, technology companies and a cruise line.
  • Investigated and negotiated a precedent-setting settlement banning a company from selling fake social media followers.
  • Supervised a team of five lawyers and nine investigators, investigating more than 20 companies in the vaping industry, the largest investigation by a state attorney general.

Education

  • Tulane University Law School, J.D., Dean's Scholarship for Academic Excellence, 2012
  • Vanderbilt University, B.A., Dean’s List, 2009

Admissions

  • New York, 2014
  • Florida, 2013

Courts

  • U.S. Dist. Ct., S. Dist. of Florida

Memberships and Affiliations

  • Consumer Protection Law Committee and Data Privacy and Cybersecurity Subcommittee, Florida Bar
  • Law360 Consumer Protection Editorial Advisory Board (2021 and 2022)

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  • Speaker, “For Your Eyes Only: Dealing with Security Risks, New Privacy Laws, and Vendor Management,” Association of Corporate Counsel (ACC) South Florida’s 12 Annual CLE Conference, September 16, 2022.
  • Co-author, “Brand’s Influencer Marketing Practices in Regulators’ Crosshairs on Both Sides of the Atlantic,” The Licensing Journal, January 2022.
  • Speaker and Chair, “Panel on AI and Data Governance – Regulatory Initiatives and Considerations,” International Institute of Communications Telecommunications and Media Forum, May 20, 2022.
  • Author, “Virginia: Consumer and business concerns under CDPA enforcement,” OneTrust DataGuidance, May 7, 2021.

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