Privacy Law

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Key Takeaways:

  • CPPA launched its first major enforcement action in targeting connected vehicle-maker Honda.
  • Connected vehicles often collect various kinds of sensitive driver information, including geolocation, biometric and behavioral data.
  • After the CPPA found Honda in violation of several CCPA provisions, the company agreed to settle the enforcement action for approximately $650,000 while also agreeing to adopt certain remedial measures.
  • Other Connected vehicle-makers have also experienced a spike in regulatory scrutiny, signaling rising enforcement pressure and growing expectations for privacy-by-design.

UPDATE (April 17, 2025): The below reflects a development occurring after our publication of the original post.

On April 11, 2025, the National Security Division (the “NSD”) released several documents setting out initial guidance on how to comply with the Rule, which the NSD refers to as the Data Security…

2024 marked another significant year for privacy law, with new state legislation and high-stakes litigation reshaping the landscape. Legal battles over tracking technologies, biometric data, and children’s privacy intensified, while federal agencies, including the Federal Trade Commission (“FTC”) and the U.S. Department of Health and Human Services Office for Civil Rights (“HHS OCR”), ramped up their efforts through major enforcement actions and high-profile settlements, marking a new era of increased accountability.

  • Amazon faces allegations of unauthorized data collection in violation of federal and state privacy laws, including a first-of-its-kind claim under Washington’s My Health My Data Act (“MHMDA”).
  • The MHMDA restricts businesses from collecting, sharing, or selling any-health related information about a consumer without their consent of “valid authorization”, going
…

On August 29, 2024, the Office for Civil Rights of the United States Department of Health and Human Services (“HHS-OCR”) withdrew its appeal of an order by the United States District Court for the Northern District of Texas’ (“District Court”) declaring unlawful and vacating a portion of an HHS-OCR Bulletin…

Repurposing old laws to challenge new technologies has become the new normal in the privacy space. Plaintiffs continue to bring a kaleidoscope of privacy claims against companies in the tech age, reviving laws like the California Invasion of Privacy Act of 1994 (“CIPA”), Video Privacy Protection Act (“VPPA”), Telephone Consumer Protection Act (“TCPA”), Pennsylvania Wiretapping and Electronic Surveillance Control Act, and Arizona Telephone, Utility, and Communication Service Records Act.

  • There has been a recent surge of privacy class action lawsuits under the Arizona Telephone, Utility, and Communication Service Records Act targeting the use of common email marketing analytics technologies.
  • Defendants are asserting standard defenses including lack of Article III standing as well as challenging the 2007 Arizona law’s applicability to email tracking pixels.