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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.
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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