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Kyle Fath

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On December 23, 2025, a federal judge enjoined enforcement of Texas’ App Store Accountability Act (SB 2420) by Texas Attorney General, Ken Paxton. The law, which was slated to go into effect on January 1, 2026, would have imposed onerous age assurance and parental consent obligations on app stores and app developers, which our expert panelists analyzed in depth in a webinar last month (and which we detailed in a FAQ).

Continue Reading Federal Judge Enjoins Enforcement of Texas App Store Age Verification Law

The last several weeks have been eventful for online safety and age assurance, particularly with respect to U.S. app store age verification laws: Apple and Google unveiled some of their plans for addressing these laws on Oct. 8; Governor Newsom signed the Digital Age Assurance Act into law on October 13; and on October 16, an industry organization lodged a constitutional challenge against Texas’ law (SB2420).  Below, we provide a handy FAQ with questions and answers on issues that many likely have regarding these laws, the app stores’ guidance, and the legal challenge to the Texas law.

Mobile app operators: take note. Regardless of your company’s target audience, you will be required to take technical and operational steps to comply with these laws.

Continue Reading App Store Age Verification Laws: Your Questions, Answered.

On September 25, the California Privacy Protection Agency (CPPA) Board advanced OAL-approved updates to the California Consumer Privacy Act (CCPA), the process of which we covered in detail here and here, that include long-awaited regulations on cybersecurity audits, risk assessments, and automated decision-making technology (ADMT). The CPPA Board also approved a $1.35 Million settlement with Tractor Supply Company, officially announced this week. At last week’s meeting, staff reported that there were hundreds of investigations and enforcement actions in progress, many of which were at a stage that the applicable businesses were not yet aware that they are a target. 2026 will bring new privacy obligations for businesses and greater repercussions for half-baked compliance efforts.

Continue Reading California Privacy Agency Rolls Out New Regulations and Approves $1.35 Million Penalty in Latest CCPA Enforcement Action

In another settlement of a cookie-related state consumer privacy law enforcement action, California reinforces contract requirements for making personal information available and raises questions about the scope of purpose limitation requirements, especially where the nature of the data and/or its use could run counter to consumer expectations. 

On July 1, 2025, the California Office of the Attorney General (OAG) announced a settlement against Healthline, which included the largest CCPA settlement to date – $1.55 million – and many “firsts” for public CCPA enforcement: the first involving a publisher, the first health information-related enforcement action, and the first time the purpose limitation principle has been invoked by California’s (or any other state’s) regulators in a public regulatory enforcement context. This enforcement action came just a week before Connecticut’s attorney general announced an $85,000 settlement under the Connecticut state privacy law explored in more detail here.

Continue Reading California AG Issues Highest Fine to Date for CCPA Violations

State consumer privacy enforcers have been turning up the heat on recalcitrant data controllers that have incomplete, inadequate or broken consumer privacy law (CPL) protection programs.  On July 8, the Office of the Attorney General of Connecticut (CT OAG) announced a settlement with TicketNetwork, Inc related to deficiencies in the company’s privacy notice and non-compliance with consumer rights requirements. This came just a week following California’s announcement of its largest consumer privacy law settlement to date — US $1.55 million, involving an online publisher known as Healthline. A post breaking that case down will follow shortly.  Today we look at the Connecticut case.

Continue Reading Connecticut’s Recent Privacy Settlement Shows that Organizations Should Remain Cognizant of Privacy Law Obligations Outside of California

In late June, Governor Abbott signed into law SB 2121 and SB 1343, two bills that amend the existing Texas Data Broker Act. The amendments broaden the definition of “data broker” and alter the applicability thresholds (SB 2121), and provide enhanced notice and registration statement requirements regarding how consumers can exercise their privacy rights (SB 1343). As we discuss below, companies that previously assessed and decided that Texas’ data broker law may not apply to them should likely review and re-evaluate this decision in view of these amendments, which become effective September 1, 2025.

Continue Reading Texas Legislature Amends Data Broker Law to Broaden Definition, Arguably Narrow Applicability Thresholds

As companies begin to move beyond large language model (LLM)-powered assistants into fully autonomous agents—AI systems that can plan, take actions, and adapt without human-in-the-loop—legal and privacy teams must be aware of the use cases and the risks that come with them.

What is Agentic AI?
Agentic AI refers to AI systems—often built using LLMs but not limited to them—that can take independent, goal-directed actions across digital environments. These systems can plan tasks, make decisions, adapt based on results, and interact with software tools or systems with little or no human intervention.

Agentic AI often blends LLMs with other components like memory, retrieval, application programming interfaces (APIs), and reasoning modules to operate semi-autonomously. It goes beyond chat interfaces and can initiate real actions—inside business applications, internal databases, or even external platforms.

For example:

  • An agent that processes inbound email, classifies the request, files a ticket, and schedules a response—all autonomously.
  • A healthcare agent that transcribes provider dictations, updates the electronic health record , and drafts follow-up communications.
  • A research agent that searches internal knowledge bases, summarizes results, and proposes next steps in a regulatory analysis.

These systems aren’t just helping users write emails or summarize docs. In some cases, they’re initiating workflows, modifying records, making decisions, and interacting directly with enterprise systems, third-party APIs, and internal data environments. Here are a handful of issues that legal and privacy teams should be tracking now.

Continue Reading What is Agentic AI? A Primer for Legal and Privacy Teams

Companies in all industries take note: regulators are scrutinizing how companies offer and manage privacy rights requests and looking into the nature of vendor processing in connection with application of those requests. This includes applying the proper verification standards and how cookies are managed. Last month, the California Privacy Protection Agency (“CPPA” or “Agency”) provided…

Though attempts to pass comprehensive federal consumer privacy legislation again stalled in 2024, efforts targeted at addressing national security-related privacy concerns had more success. Along with the Protecting Americans from Foreign Adversary Controlled Applications Act, Congress passed the Protecting Americans’ Data from Foreign Adversaries Act (“PADFA”) as part of a sweeping foreign aid bill, which was subsequently signed into law by President Biden on April 23, 2024. PADFA, which went into effect on June 24, 2024, followed President Biden’s Feb. 2024 Executive Order 14117 “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” (“EO”), under which the Department of Justice was directed to establish and implement regulations (initially reported by SPB here). The DOJ’s rulemaking process, which began in late fall of last year, culminated in the issuance of a final rule (“Bulk Data Regs”) on December 27, 2024, and publication of the same in the Federal Register on January 4, 2025. The Bulk Data Regs largely become effective 90 days after publication in the Federal Register, on April 4, with certain provisions going into effect 270 days following publication.

Continue Reading Transferring U.S. Data Overseas? Consider Whether the DOJ’s Bulk Data Regulations or PADFA May Apply to Your Organization