Foley Partner Andrew Serwin was quoted in an article that appeared in the San Diego Daily Transcript on May 4, 2011 titled "Encryption is key to protecting private data." Serwin discusses the potential for federal government enforcement in the event of large privacy breaches, stating that the Federal Trade Commission (FTC) is conducting an increasing amount of privacy breach investigations that are not made public. He adds that organizational training is key to preventing privacy breaches and also shows the FTC that efforts are being made to protect private data.