Libby J. Weingarten
Partner
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A Recognized Leader in Privacy and Consumer Protection
In Chambers USA, Clients have praised Libby as an “incredibly sophisticated legal thinker” who “understands nuance in privacy law” and has “unmatched” persuasive drafting skills. Consistently recognized among the nation's top privacy attorneys nationwide, Libby was also named a 2022 Rising Star in privacy and cybersecurity by Law360, and a 2022 D.C. Rising Star by The National Law Journal.
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Deep Experience with Regulatory Investigations
Libby has handled dozens of regulatory investigations brought by the Federal Trade Commission and State AGs, with especially deep experience in matters related to children’s privacy and minor safety.
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Representing Innovative Companies
Libby advises companies in a diverse range of emerging industries, including AI, electronic gaming, fintech, digital payments, adtech, and digital health.
Libby Weingarten is a data privacy, cybersecurity, and consumer protection partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she advises companies on a broad range of U.S. and international privacy and consumer protection issues. She has extensive experience defending major corporations facing investigations by the FTC and other federal and state regulators. She has defended social media companies, retailers, advertising technology companies, mobile app developers, and edtech companies against regulatory investigations into privacy, data security, and advertising and marketing practices, many of which were resolved without enforcement action.
Libby counsels clients on privacy and consumer protection laws, including Section 5 of the FTC Act, the Children's Online Privacy Protection Act, the Restore Online Shoppers' Confidence Act, the FTC's Endorsement Guides, and state privacy, biometrics, and AI laws. She works with clients at every stage to achieve their business goals by implementing practical solutions while managing risk, and she helps them develop policy positions and strategies to respond to new regulations.
Libby maintains an active pro bono practice and has successfully argued before the D.C. Superior Court and U.S. Immigration Court to obtain green cards for undocumented minors.
Experience
Libby Weingarten is a data privacy, cybersecurity, and consumer protection partner in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she advises companies on a broad range of U.S. and international privacy and consumer protection issues. She has extensive experience defending major corporations facing investigations by the FTC and other federal and state regulators. She has defended social media companies, retailers, advertising technology companies, mobile app developers, and edtech companies against regulatory investigations into privacy, data security, and advertising and marketing practices, many of which were resolved without enforcement action.
Libby counsels clients on privacy and consumer protection laws, including Section 5 of the FTC Act, the Children's Online Privacy Protection Act, the Restore Online Shoppers' Confidence Act, the FTC's Endorsement Guides, and state privacy, biometrics, and AI laws. She works with clients at every stage to achieve their business goals by implementing practical solutions while managing risk, and she helps them develop policy positions and strategies to respond to new regulations.
Libby maintains an active pro bono practice and has successfully argued before the D.C. Superior Court and U.S. Immigration Court to obtain green cards for undocumented minors.
Education
- J.D., Duke University School of LawCum Laude; Recipient, Faculty Graduation Award for Intellectual Property and Technology Law; Articles and Commentaries Editor, Duke Journal of Constitutional Law and Public Policy; Content Editor, Duke Law and Technology Review
- B.A., Stanford UniversityWith Distinction, Phi Beta Kappa
Honors
- Named in the 2022-2026 editions of Chambers USA: America's Leading Lawyers for Business
- Named in the 2024-2026 editions of Chambers Global
- Selected for inclusion in the 2024-2026 editions of the Lawdragon’s 500 Leading Global Cyber Lawyers guide
- Honored as a 2022 “D.C. Rising Star” by The National Law Journal Legal Awards
- Recognized as a “Rising Star” by Law360 in 2022
Admissions
- Bar of the District of Columbia
- State Bar of Virginia
Credentials
Education
- J.D., Duke University School of LawCum Laude; Recipient, Faculty Graduation Award for Intellectual Property and Technology Law; Articles and Commentaries Editor, Duke Journal of Constitutional Law and Public Policy; Content Editor, Duke Law and Technology Review
- B.A., Stanford UniversityWith Distinction, Phi Beta Kappa
Honors
- Named in the 2022-2026 editions of Chambers USA: America's Leading Lawyers for Business
- Named in the 2024-2026 editions of Chambers Global
- Selected for inclusion in the 2024-2026 editions of the Lawdragon’s 500 Leading Global Cyber Lawyers guide
- Honored as a 2022 “D.C. Rising Star” by The National Law Journal Legal Awards
- Recognized as a “Rising Star” by Law360 in 2022
Admissions
- Bar of the District of Columbia
- State Bar of Virginia
Select Representations
- Represented Shutterstock in FTC ROSCA (auto-renew) and advertising investigation. Successfully negotiated consent agreement resolving investigation.
- Represented online media company in FTC investigation into AI data licensing practices. Case closed with no enforcement action.
- Represented Google and YouTube in COPPA enforcement action brought by FTC and New York Attorney General. Successfully negotiated consent agreement resolving allegations.
- Represented Epic Games in COPPA and financial practices enforcement actions brought by FTC. Successfully negotiated consent agreements resolving allegations.
- Represented TikTok and predecessor Musical.ly in COPPA enforcement actions brought by FTC and DOJ.
- Represented communications company in FTC FCRA investigation. Case closed with no enforcement action.
- Represented major social media company in data security investigation brought by FTC. Case closed with no enforcement action.
- Represented major social media company in numerous state AG investigations into children’s privacy practices. Cases favorably resolved with no enforcement actions.
- Represented VPN provider in investigation into privacy and security practices brought by FTC. Case closed with no enforcement action.
- Currently representing online media company in auto-renewal investigation brought by FTC.
- Currently representing online media company in investigations into AI data licensing practices brought by FTC.
Matters
Select Representations
- Represented Shutterstock in FTC ROSCA (auto-renew) and advertising investigation. Successfully negotiated consent agreement resolving investigation.
- Represented online media company in FTC investigation into AI data licensing practices. Case closed with no enforcement action.
- Represented Google and YouTube in COPPA enforcement action brought by FTC and New York Attorney General. Successfully negotiated consent agreement resolving allegations.
- Represented Epic Games in COPPA and financial practices enforcement actions brought by FTC. Successfully negotiated consent agreements resolving allegations.
- Represented TikTok and predecessor Musical.ly in COPPA enforcement actions brought by FTC and DOJ.
- Represented communications company in FTC FCRA investigation. Case closed with no enforcement action.
- Represented major social media company in data security investigation brought by FTC. Case closed with no enforcement action.
- Represented major social media company in numerous state AG investigations into children’s privacy practices. Cases favorably resolved with no enforcement actions.
- Represented VPN provider in investigation into privacy and security practices brought by FTC. Case closed with no enforcement action.
- Currently representing online media company in auto-renewal investigation brought by FTC.
- Currently representing online media company in investigations into AI data licensing practices brought by FTC.
Select Publications
- Co-author, “FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices,” Wilson Sonsini Alert, April 28, 2025
- Co-author, “The Busy Lawyer's Guide to the New "Data Export Control" Rules,” Wilson Sonsini Alert, February 4, 2025
- Co-author, “New Federal Children's Privacy Requirements Are Not Child's Play: FTC Amends COPPA Rule, Imposing New Obligations on Child-Directed Services,” Wilson Sonsini Alert, January 29, 2025
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Co-author, “Proposed Rulemaking Issued by the DOJ Covering Data Export Transactions with Entities from Countries of Concern,” Wilson Sonsini Alert, November 22, 2024
- Co-author, “Subscription and Auto-Renew Offerings Face New Hurdles: FTC Issues Broad 'Click-to-Cancel' Rule Imposing Nationwide Requirements,” Wilson Sonsini Alert, October 17, 2024
- Co-author, “Maryland Age-Appropriate Design Code Effective October 1, 2024,” Wilson Sonsini Alert, October 7, 2024
- Co-author with J. Cheng and M. Alioto, “Fintech Compliance Amid Regulatory Focus on Sensitive Data,” Law360, May 31, 2024
- Co-author, “SEC Expands Security and Breach Notification Requirements for Investment Firms,” Wilson Sonsini Alert, May 30, 2024
- Co-author, “Maryland Passes Age-Appropriate Design Code,” Wilson Sonsini Alert, May 21, 2024
- Co-author, “New Minor Safety Obligations for Online Services: REPORT Act Expands Child Sexual Exploitation Reporting Requirements,” Wilson Sonsini Alert, May 10, 2024
- Co-author, “New Federal Data Broker Restrictions Signed into Law,” Wilson Sonsini Alert, April 25, 2024
- Co-author, “Time to Hit the Books for Student Privacy Compliance: College Board Agrees to Pay $750K for N.Y. Student Privacy Violations,” Wilson Sonsini Alert, February 26, 2024
- Co-author, “U.S. Privacy Predictions: What to Watch for in 2024,” Wilson Sonsini Alert, January 3, 2024
- Co-author, “FTC Proposes Significant Changes to COPPA Rule,” Wilson Sonsini Alert, December 21, 2023
- Co-author, “FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches,” Wilson Sonsini Alert, November 6, 2023
- Co-author, “Coalition of States Sues Meta for Alleged Harms to Children and Teens, and Alleged COPPA Violations,” The WSGR Data Advisor, October 27, 2023
- Co-author, “CFPB Announces Proposed Rules to Accelerate Open Banking,” The WSGR Data Advisor, October 24, 2023
- Co-author, “FTC Extends Deadline to Comply with the Updated Safeguards Rule Until June 9, 2023,” The WSGR Data Advisor, November 22, 2022
- Co-author, “FTC Holds Event on Digital Marketing and Blurred Advertising’s Impact on Children,” The WSGR Data Advisor, October 27, 2022
- Co-author, “CFPB: New Sheriff in Town for Tech Companies?” The WSGR Data Advisor, August 15, 2022
- Co-author, “Privacy Legislation Update: The “Three Corners” Bill and the Cantwell Draft,” The WSGR Data Advisor, June 9, 2022
- Co-author, “CFPB and Fintech Companies: Charting a New Course on Regulatory Supervision,” The WSGR Data Advisor, May 3, 2022
- Co-author, “BBB National Programs’ Center for Industry Self-Regulation Launches Roadmap for Teen Privacy,” The WSGR Data Advisor, April 26, 2022
- Co-author, “FTC Settles with Weight Watchers in First Children’s Privacy Case Requiring Deletion of Algorithms,” The WSGR Data Advisor, February 22, 2022
- Co-author with L. Ahmed and M. Mithal, "Fintech and Financial Privacy: Regulatory Developments on the Use of Financial Data," Wilson Sonsini Alert, January 25, 2022
- Co-author, “European Court of Justice Finds That “Inbox Advertising” Is Direct Marketing,” The WSGR Data Advisor, December 6, 2021
- Co-author, “FTC Releases Updated Safeguards Rule for Financial Institutions,” The WSGR Data Advisor, November 2, 2021
- Co-author with T. Shapiro, “FTC Settles COPPA Action Against ‘Coloring Book for Adults,’” Privacy & Cybersecurity Law Report, Vol. 7, No. 8, October 2021
- Co-author, “Liu v. SEC: Foreshadowing a Challenge to the FTC’s Disgorgement Authority,” The WSGR Data Advisor, July 10, 2020
- Co-author, “FTC Seeks Public Comment on Children’s Online Privacy Protection Rule,” The WSGR Data Advisor, July 22, 2019
- "Vermont Enacts Groundbreaking Data Broker Regulation," The WSGR Data Advisor, October 8, 2018
- "Facebook Biometric Suit Moves Forward," The WSGR Data Advisor, July 24, 2018
- "Online Talent Agency Stars in FTC's 30th COPPA Case," The WSGR Data Advisor, March 26, 2018
- Co-author with L. Parnes and E. Holman, "Sears Petitions FTC to Reopen and Modify 2009 Order Concerning Online Browsing Tracking," The WSGR Data Advisor, November 20, 2017
- Co-author with L. Parnes, "To Disclose or Not To Disclose: The FTC's Dueling Concurrences over Deceptive Omissions in Lenovo," The WSGR Data Advisor, November 15, 2017
- Co-author with T. Shapiro, "Hello Dolly: What You Need to Know About Connected Smart Toys and Privacy," The WSGR Data Advisor, September 1, 2017
Insights
Select Publications
- Co-author, “FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices,” Wilson Sonsini Alert, April 28, 2025
- Co-author, “The Busy Lawyer's Guide to the New "Data Export Control" Rules,” Wilson Sonsini Alert, February 4, 2025
- Co-author, “New Federal Children's Privacy Requirements Are Not Child's Play: FTC Amends COPPA Rule, Imposing New Obligations on Child-Directed Services,” Wilson Sonsini Alert, January 29, 2025
-
Co-author, “Proposed Rulemaking Issued by the DOJ Covering Data Export Transactions with Entities from Countries of Concern,” Wilson Sonsini Alert, November 22, 2024
- Co-author, “Subscription and Auto-Renew Offerings Face New Hurdles: FTC Issues Broad 'Click-to-Cancel' Rule Imposing Nationwide Requirements,” Wilson Sonsini Alert, October 17, 2024
- Co-author, “Maryland Age-Appropriate Design Code Effective October 1, 2024,” Wilson Sonsini Alert, October 7, 2024
- Co-author with J. Cheng and M. Alioto, “Fintech Compliance Amid Regulatory Focus on Sensitive Data,” Law360, May 31, 2024
- Co-author, “SEC Expands Security and Breach Notification Requirements for Investment Firms,” Wilson Sonsini Alert, May 30, 2024
- Co-author, “Maryland Passes Age-Appropriate Design Code,” Wilson Sonsini Alert, May 21, 2024
- Co-author, “New Minor Safety Obligations for Online Services: REPORT Act Expands Child Sexual Exploitation Reporting Requirements,” Wilson Sonsini Alert, May 10, 2024
- Co-author, “New Federal Data Broker Restrictions Signed into Law,” Wilson Sonsini Alert, April 25, 2024
- Co-author, “Time to Hit the Books for Student Privacy Compliance: College Board Agrees to Pay $750K for N.Y. Student Privacy Violations,” Wilson Sonsini Alert, February 26, 2024
- Co-author, “U.S. Privacy Predictions: What to Watch for in 2024,” Wilson Sonsini Alert, January 3, 2024
- Co-author, “FTC Proposes Significant Changes to COPPA Rule,” Wilson Sonsini Alert, December 21, 2023
- Co-author, “FTC Amends Safeguard Rule with Requirement for Non-Banking Financial Institutions to Report Data Security Breaches,” Wilson Sonsini Alert, November 6, 2023
- Co-author, “Coalition of States Sues Meta for Alleged Harms to Children and Teens, and Alleged COPPA Violations,” The WSGR Data Advisor, October 27, 2023
- Co-author, “CFPB Announces Proposed Rules to Accelerate Open Banking,” The WSGR Data Advisor, October 24, 2023
- Co-author, “FTC Extends Deadline to Comply with the Updated Safeguards Rule Until June 9, 2023,” The WSGR Data Advisor, November 22, 2022
- Co-author, “FTC Holds Event on Digital Marketing and Blurred Advertising’s Impact on Children,” The WSGR Data Advisor, October 27, 2022
- Co-author, “CFPB: New Sheriff in Town for Tech Companies?” The WSGR Data Advisor, August 15, 2022
- Co-author, “Privacy Legislation Update: The “Three Corners” Bill and the Cantwell Draft,” The WSGR Data Advisor, June 9, 2022
- Co-author, “CFPB and Fintech Companies: Charting a New Course on Regulatory Supervision,” The WSGR Data Advisor, May 3, 2022
- Co-author, “BBB National Programs’ Center for Industry Self-Regulation Launches Roadmap for Teen Privacy,” The WSGR Data Advisor, April 26, 2022
- Co-author, “FTC Settles with Weight Watchers in First Children’s Privacy Case Requiring Deletion of Algorithms,” The WSGR Data Advisor, February 22, 2022
- Co-author with L. Ahmed and M. Mithal, "Fintech and Financial Privacy: Regulatory Developments on the Use of Financial Data," Wilson Sonsini Alert, January 25, 2022
- Co-author, “European Court of Justice Finds That “Inbox Advertising” Is Direct Marketing,” The WSGR Data Advisor, December 6, 2021
- Co-author, “FTC Releases Updated Safeguards Rule for Financial Institutions,” The WSGR Data Advisor, November 2, 2021
- Co-author with T. Shapiro, “FTC Settles COPPA Action Against ‘Coloring Book for Adults,’” Privacy & Cybersecurity Law Report, Vol. 7, No. 8, October 2021
- Co-author, “Liu v. SEC: Foreshadowing a Challenge to the FTC’s Disgorgement Authority,” The WSGR Data Advisor, July 10, 2020
- Co-author, “FTC Seeks Public Comment on Children’s Online Privacy Protection Rule,” The WSGR Data Advisor, July 22, 2019
- "Vermont Enacts Groundbreaking Data Broker Regulation," The WSGR Data Advisor, October 8, 2018
- "Facebook Biometric Suit Moves Forward," The WSGR Data Advisor, July 24, 2018
- "Online Talent Agency Stars in FTC's 30th COPPA Case," The WSGR Data Advisor, March 26, 2018
- Co-author with L. Parnes and E. Holman, "Sears Petitions FTC to Reopen and Modify 2009 Order Concerning Online Browsing Tracking," The WSGR Data Advisor, November 20, 2017
- Co-author with L. Parnes, "To Disclose or Not To Disclose: The FTC's Dueling Concurrences over Deceptive Omissions in Lenovo," The WSGR Data Advisor, November 15, 2017
- Co-author with T. Shapiro, "Hello Dolly: What You Need to Know About Connected Smart Toys and Privacy," The WSGR Data Advisor, September 1, 2017
Recent Insights
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Recent Events
WSGR Events
Children's Online Protection: An Update on Key Legal Developments Across the U.S., EU and UK
Join Wilson Sonsini's Data, Privacy, and Cybersecurity Group for a timely webinar exploring the latest legal developments impacting online services in the U.S., EU, and UK. This session will feature a special focus on children's privacy and online safety, highlighting key regulatory changes, compliance deadlines, and best practices.
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WSGR Events
Navigating the DOJ’s New Data Export Rules – What Your Business Needs to Know
The U.S. Department of Justice has unveiled sweeping new Data Export Rules that could significantly impact businesses handling sensitive data—especially those with international operations. These regulations introduce strict limitations on transactions that could expose government-related or large-scale personal data to countries of concern, with a strong focus on China.
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