In case you think that data breaches are never a major legal issue in commercial real estate, Marriott International and Starwood Hotels & Resorts are still dealing with the aftermath of three major data breaches that took place between 2014 and 2018 and collectively affected more than 344 million customers globally.

According to the Federal Trade Commission and a proposed settlement order, Marriott and its subsidiary, Starwood, failed to "implement reasonable data security," which led to the data breaches. They allegedly deceived customers by claiming to have "reasonable and appropriate data security."

Marriott's acquisition of Starwood made it responsible for the latter's data security problems. Overall, Marriott manages and franchises 30 brands across more than 7,000 properties across 131 countries and territories. It is the largest hotel chain in the world with more than 1.1 million rooms, about 7% of all hotel rooms worldwide.