The Federal Trade Commission (FTC) and the Los Angeles County District Attorney on July 9, 2024, announced a complaint and proposed stipulated order against NGL Labs, LLC, and two NGL co-founders concerning the “NGL: ask me anything” anonymous messaging app. The complaint alleges that NGL marketed the app to children and teens despite awareness of
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Cybersecurity for Lawyers: A Series
By Andrew Pak & Emma Roberts
Introduction
If you are an attorney covering cybersecurity, not only do you have to stay on top of ever-evolving legal obligations and risks, you have to be able to speak competently with your technical counterparts. While there are plenty of technical resources, very few are geared to the needs of cybersecurity counsel. With that said,…
Illinois’ Plan to Limit Privacy Violation Damages Opens New Door
Changes to Illinois’ Biometric Information Privacy Act are awaiting Gov. J.B. Pritzker’s (D) signature. The legislation offers much-needed clarity for businesses but has raised questions about whether courts would apply the changes retroactively to past or ongoing lawsuits.…
CPPA Regulatory Delays and Enforcement Updates: Takeaways from July Board Meeting
On July 16, the California Privacy Protection Agency (CPPA) held a public meeting of its Board (the Board). Four days before the meeting, the CPPA released revised draft rulemaking totaling several hundred pages—including a revised combined draft rulemaking package on risk assessment regulations, cybersecurity audit regulations, and automated decision-making technology (ADMT) regulations.
The meeting…
“Biometric Identifiers Must Identify”: The Ninth Circuit Clarifies the Scope of BIPA
The U.S. Court of Appeals for the Ninth Circuit issued an opinion in Zellmer v. Meta Platforms, Inc., on June 17, 2024, affirming dismissal of a putative class action filed under the Illinois Biometric Information Privacy Act. In what is expected to be an influential opinion, the panel held that the “face signatures” at issue were not…
A Midsummer State Privacy Law Update
APRA Cancellation, Rhode Island’s Privacy Act, and CPPA’s International Cooperation
In an active summer on the privacy front, we share a few recent updates:
Cancellation of APRA House Markup
On the morning of June 27, 2024, as congressional staffers and audience members prepared to hear the latest updates on the American Privacy Rights Act (APRA),…
FCC Proposes New Internet Routing Security Rules for Telecoms
Building on its renewed jurisdictional authority over broadband internet access service providers following the reinstatement of net neutrality, the Federal Communications Commission has adopted proposed internet routing security rules in a notice of proposed rulemaking designed to prevent foreign manipulation of internet traffic.
Texas AG Turns Up the Heat on Privacy and Data Security
The Texas Data Protection and Security Act goes into effect on Monday, July 1, 2024. Eliminating any speculation that this omnibus consumer privacy law might sit on the cupboard shelf, unenforced, the Texas attorney general announced that his office has formed a task force to enforce the TDPSA, along with Texas’ several other data privacy…
California Attorney General Announces Children’s Privacy Settlement with Mobile Game
On June 18, 2024, the California Attorney General announced a settlement with Tilting Point Media LLC, the developer and publisher of the mobile game “SpongeBob: Krusty Cook-Off” (SpongeBob app), resolving allegations of unauthorized disclosure of children’s personal information under the federal Children’s Online Privacy Protection Act (COPPA) and the California Consumer Privacy Act (CCPA), as…
Minnesota’s Unique Spin on Consumer Data Privacy
Minnesota’s governor signed the Minnesota Consumer Data Privacy Act (MNCDPA or the Act) into law at the end of May, making Minnesota the 18th state to enact a comprehensive consumer privacy law. The MNCDPA will take effect for most covered entities on July 31, 2025. The law provides a 30-day cure period, which will sunset…