On April 24, 2018, the Securities and Exchange Commission announced the settlement of its first enforcement proceeding that was brought under a disclosure theory related to a cyber incident. The enforcement proceeding was against Altaba Inc. (formerly d/b/a Yahoo! Inc.) and arose out of Yahoo!’s highly publicized data breaches. See our recent Client Alert for a discussion of the Yahoo! settlement and related insights into the Commission’s views regarding an issuer’s responsibility after suffering a cyber incident.