Last Friday, Fiat Chrysler announced the recall of 1.4 million vehicles to fix security vulnerabilities, further highlighting the importance of properly addressing cybersecurity issues created by the use of connected devices.  The recall follows an article published last Tuesday by Wired magazine which described methods used by security researchers to remotely access a Jeep Cherokee, including attacks that disabled the car’s brakes and transmission.  While Fiat Chrysler’s statement on the recall emphasized that it was not aware of any incidents where the vulnerability had been exploited, the recall demonstrates the increasing attention being paid to security vulnerabilities discovered in connected devices.  The same day that the Wired article was published, Sens. Ed Markey (D-Massachusetts) and Richard Blumenthal (D-Connecticut) introduced legislation aimed at establishing federal standards for cybersecurity of connected cars and privacy of drivers’ information.

According to the Wired article, many of Fiat Chrysler’s vehicle models – including the Jeep Cherokee – use Uconnect, an Internet-connected computer feature, to offer entertainment, navigation, and communication features.  The Wired article described a method by which security researchers were able to use Sprint’s cellular network, the same network used by the Uconnect feature, to wirelessly access any vulnerable vehicle nationwide through its Uconnect system.  Once the researchers accessed a vehicle, they could access the car’s internal computer network and control certain physical components of the car, such as its engine and wheels.  According to the article, the researchers notified Fiat Chrysler of the vulnerability nine months ago, and Fiat Chrysler responded by releasing a software patch that could be manually implemented via a USB stick or a dealership mechanic.  Following the article’s release, Fiat Chrysler initiated a full safety recall of multiple affected vehicle models, mailing a USB containing the patch to each vehicle’s owner that the owner could plug into a port in the vehicle to implement the fix.  The automaker has also worked with Sprint to block the methods used by the researchers to find and access vehicles wirelessly using Sprint’s network.

Last week, Sens. Ed Markey and Richard Blumenthal also introduced the SPY Car Act, designed to protect drivers from the security and privacy risks inherent in the increased use of connected cars.  According to the copy of the bill released by Sen. Markey, the bill would require NHTSA, in consultation with the FTC, to develop performance standards to prevent hacking of vehicles’ control systems.  These standards, which would take effect within 2 years after the final regulations are prescribed, would require manufacturers to use “reasonable measures” to protect all access points to the car, including isolation of critical software systems and evaluation using penetration testing.  Manufacturers would also have to secure all collected information against unauthorized access, both at rest and in transit, and equip vehicles with “capabilities to immediately detect, report, and stop attempts to intercept driving data or control the vehicle.”  In addition to these hacking protections, the bill would also require the FTC, in consultation with NHTSA, to develop privacy standards to govern the collection of data by vehicles, including increased transparency and choice for drivers and a prohibition on the use of such data for marketing purposes without express consent.  Finally, the bill would also require NHTSA and the FTC to develop a “cyber dashboard” that would allow potential purchasers of new vehicles to easily evaluate how well each vehicle protects owners’ security and privacy.

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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…

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.