Photo of Caleb Skeath

Caleb Skeath

Caleb Skeath helps companies manage their most complex and high‑stakes cybersecurity and data security challenges, combining deep regulatory insight, technical fluency, and practical judgment informed by leading incident response matters.

Caleb Skeath advises in‑house legal and security teams on the full lifecycle of cybersecurity and privacy risk—from governance and preparedness through incident response, regulatory engagement, and follow‑on litigation. A Certified Information Systems Security Professional (CISSP), he is trusted by clients across highly regulated and technology‑driven sectors to provide clear, practical guidance at moments when legal judgment, technical understanding, and business realities must be aligned.

Caleb has deep experience leading and overseeing responses to complex cybersecurity incidents, including ransomware, data theft and extortion, business email compromise, advanced persistent threats and state-sponsored threat actors, insider threats, and inadvertent data loss. He regularly helps in‑house counsel structure and manage investigations under attorney‑client privilege; coordinate with internal IT, information security, and executive stakeholders; and engage with forensic firms, crisis communications providers, insurers, and law enforcement. A central focus of his practice is advising on notification obligations and strategy, including the application of U.S. federal and state data breach notification laws and requirements along with contractual notification obligations, and helping companies make defensible, risk‑informed decisions about timing, scope, and messaging.

In addition to his work responding to cybersecurity incidents, Caleb works closely with clients’ legal, technical, and compliance teams on cybersecurity governance, regulatory compliance, and pre‑incident planning. He has extensive experience drafting and reviewing cybersecurity policies, incident response plans, and vendor contract provisions; supervising cybersecurity assessments under privilege; and advising on training and tabletop exercises designed to prepare organizations for real‑world incidents. His work frequently involves translating evolving regulatory expectations into actionable guidance for in‑house counsel, including in highly-regulated sectors such as the financial sector (including compliance with NYDFS cybersecurity regulations, the Computer Security Incident Notification Rule, and GLBA guidelines and guidance) and the pharmaceutical and healthcare sector (including compliance with GxP standards, FDA medical device guidance, and HIPAA).

Caleb’s practice also addresses evolving and emerging areas of cybersecurity and data security law, including advising clients on compliance with the Department of Justice’s Data Security Program, CISA‑related security requirements for restricted transactions, and preparation for new regulatory regimes such as the CCPA cybersecurity audit requirements and federal incident reporting obligations. He regularly counsels clients on how artificial intelligence and connected devices intersect with cybersecurity, privacy, and consumer protection risk, and how to support innovation while managing regulatory exposure.

Caleb also has extensive experience helping clients navigate high-stakes cybersecurity-related inquiries from the Federal Trade Commission, state Attorneys General, and other sector-specific regulators, including incident-specific inquiries as well as broader inquiries related to an entity’s cybersecurity practices and the security of product or service offerings. For companies that have entered into cybersecurity-related settlement agreements with regulators, Caleb has helped guide them through compliance with settlement agreement obligations, including navigating required third-party assessments and strategically responding to cybersecurity incidents that can arise while a company is subject to a settlement agreement. Caleb also routinely works hand-in-hand with colleagues in Covington’s class action litigation, commercial litigation, and insurance recovery practices to prepare for and successfully navigate incident-related disputes that can devolve into litigation.

On March 6, 2026, the Administration released “President Trump’s Cyber Strategy for America” alongside an Executive Order (entitled “Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens”) and accompanying Fact Sheet.  The framework set forth in the Strategy document is significantly shorter and higher-level than the prior

Continue Reading White House Releases New National Cyber Strategy and Executive Order

On January 28, 2026, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published a new resource on Assembling a Multi-Disciplinary Insider Threat Management Team.  The guidance is intended to assist critical infrastructure stakeholders, which includes private sector entities across various sectors, with implementing an insider threat mitigation program that combines physical security, cybersecurity, personnel awareness, and community partnerships.  Although framed for critical infrastructure, CISA’s guidance is relevant to a broader range of organizations, including those outside of critical infrastructure sectors—a point echoed in Covington’s 2025 insider threat webinar series, discussed further below.

Continue Reading CISA Releases New Guidance on Assembling Multi-Disciplinary Insider Threat Management Teams

Earlier this month, the U.S. Cybersecurity and Infrastructure Security Agency (“CISA”) announced a series of public town hall meetings to solicit additional stakeholder input on the Notice of Proposed Rulemaking (“Proposed Rule”) implementing the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”), which CISA published in April 2024.

Continue Reading CISA Announces Town Halls to Gather Input on CIRCIA Proposed Rule

The Federal Trade Commission (FTC) recently announced that it agreed to proposed consent orders with two companies that experienced recent cybersecurity incidents, Illuminate Education (“Illuminate”) and Illusory Systems, which does business as Nomad (“Illusory”), to resolve allegations that both companies’ information security practices had violated Section 5 of the FTC

Continue Reading FTC Announces 10-Year Information Security Consent Orders with Illuminate Education and Illusory Systems

On December 16, 2025, the U.S. National Institute of Standards and Technology (“NIST”) published a preliminary draft of the Cybersecurity Framework Profile for Artificial Intelligence (“Cyber AI Profile” or “Profile”).  According to the draft, the Cyber AI Profile is intended to “provide guidelines for managing cybersecurity risk related to AI

Continue Reading NIST Publishes Preliminary Draft of Cybersecurity Framework Profile for Artificial Intelligence for Public Comment

On December 11, 2025, the U.S. Cybersecurity and Infrastructure Security Agency (“CISA”) released its Cybersecurity Performance Goals 2.0 (“CPG 2.0”), an update to its core set of recommended cybersecurity practices for critical infrastructure owners and operators, which we previously wrote about here.  Established by the 2021 National Security Memorandum

Continue Reading CISA Releases Cybersecurity Performance Goals 2.0 for Critical Infrastructure

On November 20, 2025, the Securities and Exchange Commission (“SEC”) announced that it was voluntarily dismissing the case it brought against SolarWinds Corp. (“SolarWinds”) and its Chief Information Security Officer, Timothy Brown, regarding the company’s security practices and related statements in connection with the “Sunburst” cybersecurity incident. The SEC stated in a brief release that its decision to dismiss with prejudice the case against SolarWinds and Mr. Brown was “in the exercise of its discretion” and “does not necessarily reflect the Commission’s position on any other case.”

Continue Reading SEC Voluntarily Dismisses SolarWinds Litigation

The Cybersecurity Information Sharing Act of 2015 (“CISA 2015”), which provides protections for sharing cybersecurity threat information with the federal government and others, was reauthorized under the funding bill to reopen the federal government, which was enacted on November 12, 2025.  The information sharing mechanisms and protections under CISA 2015, which had previously sunset on September 30, 2025, will now extend through January 30, 2026.

Continue Reading Cybersecurity Information Sharing Act of 2015 Reauthorized Through January 2026

On October 21, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter (the “Guidance”) highlighting the cybersecurity risks related to Covered Entities’ use of Third-Party Service Providers (“TPSPs”) and providing strategies to address these risks. The Guidance is addressed to all Covered Entities subject to NYDFS’s cybersecurity regulation codified at 23 NYCRR Part 500 (“Cybersecurity Regulation”), which requires Covered Entities to implement a comprehensive cybersecurity program that includes written policies addressing TPSP risks as well as due diligence, contractual requirements, and periodic assessments for TPSPs. While the Guidance is explicit that it “does not impose any new requirements” beyond those already included in the Cybersecurity Regulation, it provides significant additional detail to clarify how to comply with existing requirements and offers industry best practices to mitigate TPSP-related cyber risks. As the Guidance suggests that NYDFS will continue to focus on TPSP-related cyber risks, Covered Entities should consider reviewing their TPSP oversight and management against the specific recommendations from the Guidance and adjusting their practices where appropriate. Alongside a review of TPSP oversight and management, Covered Entities may also consider reviewing their implementation of the provisions of the Cybersecurity Regulation requiring multifactor authentication, asset management, and data retention, which take effect on November 1, 2025.

Continue Reading NYDFS Publishes Industry Guidance on Managing Cyber Risks Related to Third-Party Service Providers

The Cybersecurity Information Sharing Act of 2015 (“CISA 2015”), which provided protections for sharing cybersecurity threat information with the federal government and others, officially sunset on September 30, 2025 pursuant to the law’s original sunset date after efforts to re-authorize it did not succeed.  The law created a cybersecurity information

Continue Reading Cybersecurity Information Sharing Act of 2015 Allowed to Sunset