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A CCPA Private Right of Action on the Horizon

Class Action Complaints Test Whether Plaintiffs Can Sue for Any Violation of the CCPA

This article provides an overview of how the CCPA addresses private rights of action, summarizes recent class action complaints that attempt to use CCPA violations as the basis for class-wide claims, and provides suggestions for prioritizing activity in CCPA compliance programs in this new litigation environment.

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While much of the privacy community has been focused — for good reason — on the COVID-19 public health emergency, plaintiffs’ counsel have started to lay the groundwork for a broad private right of action under the California Consumer Privacy Act (CCPA), Cal. Civ. Code §§1798.100 to 1798.198.

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