[tptacek]

An example of a complicating factor identified by this postmortem is that the CSO was simultaneously a Dep. GC, and was made a DGC in part to facilitate direct reporting relationships with the CEO that ended up short circuiting the normal GC process.

Further factors identified in the postmortem involve responses given to the FTC that weren't properly vetted, but easily could have been by a typical counsel's team.