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Kyle R. Dull
Senior Associate
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.
- 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 & Affiliations
- Consumer Protection Law Committee and Data Privacy and Cybersecurity Subcommittee, Florida Bar (2020 to 2023)
- Law360 Consumer Protection Editorial Advisory Board (2021 and 2022)
- Quoted, “States Pile On Privacy Law Patchwork As Congress Stagnates,” Law360, May 5, 2023.
- Quoted, “Consumer Protection Policy and Cases To Watch In 2023,” Law360, January 2, 2023.
- Quoted, “Top Privacy Developments Of 2022: Year In Review,” Law360, December 21, 2022.
- Quoted, “Cyber Training Center To Give State AGs Enforcement Boost,” Law360, May 27, 2022.
- Quoted, “Calif. AG Sets Sights On Loyalty Programs’ Privacy Pitfalls,” Law360, February 16, 2022.
- Press Mention, “Consumer Protection Cases and Policy To Watch In 2022,” Law360, January 3, 2022.
- Quoted, “Insurance, Regulatory Ripples Likely After Colonial Pipeline Hack,” Bloomberg Law, May 11, 2021.
- Quoted, “Florida Legislature's privacy law efforts fall short,” IAPP, May 3, 2021.
- Quoted, “Florida Consumer Privacy Bill Falls Short at the Eleventh Hour,” Bloomberg Law, April 30, 2021.
- Quoted, “Fla. Privacy Bill Can't Cross Finish Line As Session Ends,” Law360, April 30, 2021.
- Featured, “SPB add three US data professionals,” ICLG, April 19, 2021.
- Quoted, “Squire Patton Boggs Nabs Data Privacy Team from BakerHostetler,” Bloomberg Law, April 5, 2021.
- Quoted, “Squire Patton Grows Data Privacy Practice With 3 New Attys,” Law360, April 5, 2021.
- Author, “Florida: Digital Bill of Rights – Privacy Concerns and Key Differences for Businesses to Consider,” OneTrust, July 2023.
- Speaker, “Best Practices for Obtaining Enforceable Online Notices, Consent and Agreements in Negative Option Marketing – and Avoiding ‘Dark Patterns,’” Association of National Advertisers (ANA) Conference, Los Angeles, July 19, 2023.
- Co-author, “Direct Marketing in the US: Overview,” Thomson Reuters Practical Law, June 2023.
- Co-author, “Uncloaking Dark Patterns: Identifying, Avoiding, and Minimizing Legal Risk,” Competition Policy International® TechREG Chronicle, May 2023.
- Speaker, “Technology for Law Practice,” Southern Methodist University (SMU) Dedman School of Law, May 10, 2023.
- Co-author, “FTC Proposal Greatly Widens Auto-Renewal Regulation,” Law360, April 2023.
- Speaker, “Protect Your Business from Regulatory Risk: Mitigating the Threat of Dark Patterns,” MyLawCLE and Federal Bar Association webinar, April 19, 2023.
- Speaker, “Website Data Scraping: Evolving Legal, Case Law, and Business Challenges, User Agreement Enforcement, Safeguards,” Strafford webinar, February 16, 2023.
- Speaker, “Consumer Privacy: What You Need to Know About the New State Privacy Laws,” 2022 Association of National Advertisers (ANA) Masters of Advertising Law Conference, November 8, 2022.
- 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.