Fred H. Cate and Rachel D. Dockery co-wrote this article. Fred H. Cate is Vice President for Research, Distinguished Professor, and C. Ben Dutton Professor of Law at Indiana University, and a senior policy adviser in the Centre for Information Policy Leadership. He is a former president of Phi Beta Kappa. Rachel D. Dockery is a senior research fellow in cybersecurity and privacy law at the Indiana University Maurer School of Law and Executive Director of the Indiana University Cybersecurity Clinic.