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
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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