They were also subject to paying restitution to affected consumers.
ITV put in place a scheme which allowed affected consumers to be offered refunds.
The reason ChoicePoint did not begin notifying the affected consumers until only recently, he said, was because investigators had requested the delay.
ComReg said it was monitoring Vodafone's provision of refunds to affected consumers.
The company says it has mailed notification to the affected consumers, who should all receive their letters by the end of the week.
Many states have laws that govern how businesses should respond to data breaches, and what notice or assistance they are required to provide to affected consumers.
Some of the Online Pass codes were invalid from the time of purchase, which EA responded to by telling affected consumers to ask the retailer for a replacement code.
The Commission distributed the $40 million as redress to affected consumers.
Several class action lawsuits were filed, which were ultimately settled by agreements to provide affected consumers with a cash payout or album downloads free of DRM.
The judgment provides $7.3 million in restitution to affected consumers.