Plaintiffs’ counsel have started to lay the groundwork for a broad private right of action under the California Consumer Privacy Act (CCPA).

The first part of this article provides an overview of how the CCPA addresses private rights of action. The second section summarizes recent class action complaints that attempt to use CCPA violations as the basis for classwide claims, either via claims asserted directly under the CCPA or through the California Unfair Competition Law. The third and final part provides suggestions for prioritizing activity in CCPA compliance programs in this new litigation environment.