While the rest of the world has been grappling with the COVID-19 pandemic, the California attorney general published on March 11 a second set of revisions to its proposed regulations for the California Consumer Privacy Act (CCPA). As the March regulations bring further clarity (and, some in instances, confusion) to the CCPA landscape, litigation is also beginning to shape the CCPA. Consumer rights lawsuits have been filed in California federal courts that could clarify and test the limitations of the CCPA’s private right of action.

3 Key Changes to Proposed CCPA Regulations

The new changes to the proposed regulations, while not as sweeping and comprehensive as the last round issued in February, are still significant, particularly with the July 1 deadline for finalizing those regulations quickly approaching. Among the substantive and stylistic changes, three key modifications are highlighted below.