On October 27, 2017, WLF filed comments with the Federal Trade Commission (FTC) to inform its examination of consumer injury in the context of privacy and data security. The agency sought comments ahead of a December 12, 2017 public workshop. For the past two decades, the FTC has utilized its broad authority under Section 5 of the Federal Trade Commission Act to prosecute what it perceives as unfair or deceptive data practices, with a vast majority of such actions resulting in settlements. WLF’s comments applaud the FTC’s willingness to look for input on how it should evaluate harm, while also warning the agency not to create a new, amorphous new category of “informational injuries.”