Photo of Laura Hamady

Laura serves as counsel in the firm’s Privacy + Cyber practice. She brings more than 15 years of experience in privacy and cybersecurity related matters. Laura is an industry-experienced privacy leader and has served in senior privacy leadership positions at a variety of large companies across various industry spaces, including Twitter, Visa, PayPal, Chronicle (a Google company), Groupon, Levi’s Takeda Pharmaceuticals, and more.

Key point: The California attorney general announced a $2.75 million fine against a company for CCPA violations for failing to honor requests to opt out of the sale or sharing of personal information across all devices and services associated with consumer accounts.

On February 11, 2026, the California attorney general (AG) announced a settlement with a multiplatform entertainment company, resolving alleged California Consumer Privacy Act (CCPA) violations based on gaps in the company’s opt-out procedures. This is the second public CCPA enforcement settlement arising from the California Department of Justice’s 2024 investigative sweep of streaming services. This also is the largest CCPA settlement amount to date, and is roughly five times the amount of the first enforcement action and more than $1 million more than the prior largest settlement by the AG. These actions reflect an escalating enforcement trajectory as the AG and the California Privacy Protection Agency develop a body of precedent that increasingly functions as operational compliance guidance for businesses. Notably, every CCPA enforcement action to date has involved, in some way, the right to opt out and demonstrates that the AG’s expectations for what constitutes compliant opt-out implementation are becoming both more granular and more demanding with each successive action.

Key point: The Connecticut Office of the Attorney General issued the third annual enforcement report under the Connecticut Data Privacy Act, focusing on the office’s privacy and security efforts, consumer complaints, data breaches, and enforcement priorities.

The Connecticut Office of the Attorney General (OAG) issued its 2025 enforcement report under the Connecticut Data Privacy Act (CTDPA) last week. This is the third report since the CTDPA went into effect in July 2023. The report provides an update on (1) privacy-related consumer complaints, (2) data breach notice review and enforcement, and (3) enforcement efforts and priorities. Importantly, the OAG emphasized that protecting “kids online remains a topmost priority” and that it would continue to pursue investigations and enforcement actions focused on companies that offer online services, products, or features to consumers under 18.

In the report, the OAG also outlined recent amendments to the CTDPA, which will take effect on July 1, 2026. For more information regarding these amendments, see the recording of our webinar on 2025 Key Updates on State Privacy and AI Laws.

This article summarizes the OAG’s report and the positions the OAG takes on various issues. While the report highlights the OAG’s strong pro-consumer stance and illustrates the OAG’s expansive view of the CTDPA and its provisions, in breaking down the report, this article takes no position on the substance of those positions.

Key point: The California AG’s fifth CCPA-related enforcement action focuses on the CCPA’s right to opt out of sales/shares and on children’s privacy provisions and, with respect to the right to opt out, it should trigger businesses to reevaluate their procedures, especially as it relates to the treatment of account holders and mobile apps.

On October 30, 2025, the California attorney general (AG) announced a settlement with a streaming services provider[1] over violations of the California Consumer Privacy Act (CCPA). Pursuant to the proposed final judgment and permanent injunction, the company will pay a $530,000 fine and implement several injunctive relief requirements. According to the press release, the settlement arose from a 2024 investigative sweep of streaming services.

The complaint alleges two CCPA violations: (1) failure to provide easy-to-execute methods for consumers to opt out of the selling and sharing of their personal information; and (2) failure to provide sufficient privacy protections for children. Given that these are distinct issues, we will address them in two separate articles. This first article provides a brief background of the enforcement action, an analysis of the right to opt-out violations, and a summary of the injunctive relief requirements. The next article will analyze the children’s privacy violations.

Key point: California’s new Digital Age Assurance Act will likely create significant compliance challenges for many businesses.

On October 13, 2025, California Governor Gavin Newsom signed AB 1043 — the Digital Age Assurance Act — into law. In doing so, California joins Louisiana, Texas, and Utah, in passing laws this year requiring app developers to receive age bracket signals. While California’s law is more operational in nature, and in key respects narrower than the content-focused nature of the laws passed by Louisiana, Texas, and Utah, when AB 1043 goes into effect on January 1, 2027, the law will likely require companies to consider unique implementation strategies and may frustrate approaches to creating a uniform age-assurance compliance program. Further, the law will likely affect almost every app developer operating in California, including many that have never dealt with age verification requirements.

In the below article, we provide background and a summary of the law, discuss how it compares with other similar-in-kind laws, and outline some implications businesses will need to consider.

On June 2, the Texas legislature passed the Texas Responsible Artificial Intelligence Governance Act, (TX AI Act or bill) which heads to the governor for his signature or veto. The bill will take effect January 1, 2026, if the governor signs it into law. It is the most comprehensive piece of AI governance legislation to pass a state legislature to date. If enacted, Texas will become the fourth state after Colorado, Utah, and California to pass AI-specific legislation.