Wyndham Hotels’ website claimed to protect customers’

information. Hackers cracked Wyndham’s customer base three times in a year, costing the customers at least $10 million. The FTC sued claiming it was an unfair and deceptive practice to claim to have a secure website when in fact it was not. Could the agency have a case? [FTC v. Wyndham Worldwide, 3rd Cir., 799 F.3d 236 (2015)]