67 Am. U. L. Rev. 927 (2018)

*Law Clerk, Debevoise & Plimpton LLP—Cybersecurity & Data Privacy; Articles Editor, American University Law Review, Volume 67; J.D. Candidate, May 2018, American University Washington College of Law; B.A., International Studies, University of Washington, Seattle.  I would like to thank Elizabeth Beske, Jennifer Daskal, Luke Dembosky, Melanie Teplinsky, and Sean Zadig for their contributions to and support of this piece.  I would also like to thank the hard-working staff at the American University Law Review, especially Annie Anderson, Laura Collins, and Jordan Helton, for their thoughtful feedback and support during the publication process.  The views expressed herein are those of the author and do not necessarily reflect those of Debevoise & Plimpton LLP.