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2024 Privacy, AI & Cybersecurity Year in Review

2024 was a pivotal year in the regulation of data practices, with increased scrutiny of artificial intelligence (AI), data brokers, and the ecosystem of commercial data, and the continued proliferation of comprehensive United...more

Spoliation: When the Duty to Preserve Data Outweighs the Obligation to Delete

Implementing and enforcing appropriate legal holds is essential to preventing the destruction of data related to current or anticipated litigation and avoiding inadvertent spoliation claims. Depending on the nature of the...more

CCPA Disclosure Requirements Emphasized by California AG’s Settlement With DoorDash‎

Enforcement of the California Consumer Privacy Act (“CCPA”) continues to heat up with California Attorney General Rob Bonta’s office announcing its second public enforcement action, this time against delivery service provider...more

Consent Has Never Been More ‎Important: Take-Aways From the FTC Settlement Relating to ‎‎Tracking Technologies

Litigation over tracking tools, such as cookies and pixels, has become commonplace over the past few years. In general, plaintiffs’ claims revolve around the collection and sharing of data through session replay and/or...more

Beware Common Website Technology Tools That Can Lead to Wiretap Claims

Knowing how consumers behave while on a website can provide businesses with valuable information. Frequently businesses employ “session replay” tools to analyze what users do on their website. “Session replay” is software...more

The CPRA: A Missed Deadline Gives ‎Companies a Break

The California Privacy Rights Act of 2020 (“CPRA”), which voters approved in November 2020, expanded consumers’ protections under the California Consumer Privacy Act of 2018 (“CCPA”). While the CPRA introduced new consumer...more

California Privacy Enforcement Will Heat up This Summer as the Agency Takes Control

The California Privacy Rights Act (the “CPRA”), which substantially amended the California Consumer Privacy Act (the “CCPA”), took effect January 1, 2023. Beginning July 1, 2023, the newly formed California Privacy Protection...more

CFPB’s Data Access Rulemaking ‎Process: A Heads-Up to Covered Data Providers

On October 27, 2022, the Consumer Financial Protection Bureau (“CFPB”) began the process needed to implement a much anticipated rule regarding section 1033 of the Dodd-Frank Act by releasing an outline providing initial...more

CCPA Enforcement: The Sephora Settlement Is Just the Start

Flexing considerable enforcement muscle, California Attorney General Rob Bonta (“AG”) recently announced a $1.2 million settlement with beauty retailer Sephora, Inc. (“Sephora”) under the landmark California Consumer Privacy...more

“Trust the Process”? – Privacy and Cybersecurity Issues With Court Service of Process via NFT

Recently courts in New York and London granted orders in two unrelated cases – LCX AG v 1.274M U.S. Dollar Coin and D’Aloia v Binance Holdings & Others – authorizing the claimants to serve proceedings on anonymous defendants...more

Are You Ready for the BIPA Tsunami? The New Wave of Biometric Statutes

The Illinois Biometric Information Privacy Act (“BIPA”) has steadily become one of the most important and influential privacy statutes in the United States. Indeed, the collection, use, and storage of the biometric...more

The Supreme Court’s Ramirez Isn’t Standing in the Way of Standing in Recent Data Breach and Privacy Cases

Despite the much-anticipated impact of TransUnion LLC v. Ramirez (“Ramirez”), the Supreme Court decision has not prevented data breach and privacy class actions from proceeding past the pleading stage in federal courts across...more

Business as Usual – so Far – for Data Breach Cases After TransUnion LLC v. Ramirez

The Supreme Court’s June 2021 decision in TransUnion LLC v. Ramirez led many to believe that data breach plaintiffs were going to have a difficult time establishing standing. After all, the Court suggested that exposure to...more

New York Biometric Privacy Update: Scanning Your Face as You Walk the City?

New York’s recent steps to protect biometric privacy are well worth your attention. The “Biometric Identifier Information” Law (BIIL) was passed by the New York City Council and will be effective July 9, 2021 in New York...more

Firmer Footing for Data Breach Standing, Thanks to the Second Circuit

Instead of identifying traditionally “tangible” injuries, data breach plaintiffs typically point to the fact that they may be the victim of identity theft at some point in the future. Prior to late April 2021, the federal...more

A Big Win for Walmart Helps Further Define the Scope of Data Breach Class Actions: ‎Gardiner v. Walmart, Inc.‎

Litigants have been looking forward to guidance regarding the limits of data breach claims since the California Consumer Privacy Act (“CCPA”) took effect on January 1, 2020. Now some of the questions are starting to be...more

Taking Stock of Non-Monetary Settlement Provisions

Since the passage of the California Consumer Privacy Act and because of the continued interest in the Illinois Biometric Information Privacy Act, there has been a focus on the amount of money class members may expect to...more

What’s in Store for Future CCPA Settlements After the Hanna Andersson Class Action

The first class action alleging a violation under the California Consumer Privacy Act ("CCPA"), which was filed against ‎Hanna Andersson, LLC has now been resolved for $400,000 subject to court approval. The settlement...more

The Murky Waters of the CCPA's Private Right of Action: Real and Perceived Ambiguities Complicating Litigation

The California Consumer Privacy Act (“CCPA”) gives individuals the right to seek statutory damages against a business in limited circumstances involving the CCPA’s reasonable security obligation. See Cal. Civ. Code §...more

The Murky Waters of the CCPA’s Private Right of Action: Real and Perceived Ambiguities Complicating Litigation

The California Consumer Privacy Act (“CCPA”) gives individuals the right to seek statutory damages against a business in limited circumstances involving the CCPA’s reasonable security obligation. See Cal. Civ. Code §...more

When Half a Billion Dollars is Not Enough: What the Facebook Settlement Can Teach Us

On July 23, 2020, the U.S. District Court for the Northern District of California signaled that a $650 million settlement of claims against Facebook, Inc. for alleged violations of the Illinois Biometric Information Privacy...more

An Overview of Key Issues in Privacy and Cyber Litigation

“Recent inventions and business methods call attention to the next step which must be taken for the protection of the person, and for securing to the individual . . . the right ‘to be let alone.’” Samuel Warren and Louis...more

HUD Face-to-Face Meeting Requirement: Fourth Circuit Holds That a Bank Office That Conducts No Mortgage-related Business Does Not...

On April 20, 2020, the United States Court of Appeals for the Fourth Circuit became the first Circuit Court of Appeal in the United States to hold that a mortgage lender must have a “branch office” that conducts at least some...more

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