Chris Leach is featured in this article.

Whether and how businesses make adjustments will be dependent on "a number of factors," but "now the market has new information to use for its corporate decision making and risk tolerance assessment," said Chris Leach, a former FTC attorney who is now a partner at Mayer Brown LLP.

"Like any federal agency, the FTC respects its own internal precedents," Leach said. "Companies covered by the Health Breach Notification Rule should regard the enforcement action against GoodRx as an ongoing tool in the FTC's kit."