On October 6, 2015, the European Court of Justice (“ECJ”) invalidated the US-EU Safe Harbor Framework (“Safe Harbor”). This ruling will have far-reaching consequences. The Safe Harbor allowed U.S. companies to receive EU citizens’ personal data from the EU if the U.S. companies complied with the Safe Harbor requirements.  The Safe Harbor greatly facilitated the transfer of private personal data from the EU to the U.S. by avoiding the necessity of U.S. organizations having to comply with the much stricter EU Data Protection Directive and by allowing the U.S. Federal Trade Commission and Department of Transportation to enforce

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