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To Delete or Not to Delete: Can 23andMe Really Sell Genetic Data Via Bankruptcy?

On March 23, 2025, 23andMe Holding Co. (“23andMe”) filed for bankruptcy in the Eastern District of Missouri, potentially setting in motion the sale of genetic data collected from more than 15 million people.  This has led to...more

New York Passes Health Privacy Law – Your Questions Answered

The New York State legislature passed the Health Information Privacy Act (“NYHIPA”) on January 22, 2025, marking the second state to introduce a comprehensive consumer health data law. If passed, the NYHIPA imposes more...more

Virginia Legislature Passes Second US AI Governance Act Behind Colorado: Comparing the AI Acts

On February 20, 2025, the Virginia legislature passed the High-Risk Artificial Intelligence Developer and Deployer Act (House Bill 2094, the “VA AI Act”) that mandates developers and deployers of high-risk artificial...more

State AGs Publish Guidance on How State Laws Apply to AI

On December 24, 2024 and January 13, 2025, the Oregon Attorney General’s Office and the California Attorney General’s Office published advisories (collectively, “Advisories”) explaining how existing statutes may be used to...more

DeepSeek Grabs Headlines – but Could it Be Unlawful by April? Considerations for Companies from Recent US Data Regulations

Late last week, a new generative AI large language model called DeepSeek was publicly launched by two Chinese entities, the Hangzhou and Beijing DeepSeek Artificial Intelligence Cos. Ltd.  DeepSeek is currently driving...more

Top Ten Takeaways from California AG’s Healthcare AI Advisory

On January 13, 2025, California Attorney General (“AG”) Rob Bonda issued an advisory describing providers’ and businesses’ obligations related to the development, sale, and use of artificial intelligence (“AI”) and automated...more

Key Points for DHS Playbook for Public Sector GenAI Deployment

On January 7, 2025, the Department of Homeland Security released its first “Playbook for Public Sector Generative Artificial Intelligence Deployment (“Playbook”) to serve as a comprehensive guide for DHS and other public...more

New York Attorney General Investigates Companies for Website Tags, Publishes Guidelines on Online Tracking Technologies

On July 30, 2024, the New York Attorney General Letitia James announced she had completed an investigation into the tracking technology practices of popular websites, and used this to create website privacy guides on online...more

More Guidance from HHS on Online Tracking Technologies but Questions Remain

Health and Human Services (“HHS”) released updated guidance yesterday on the use of online tracking technologies (like cookies, pixels, software development kits (SDKs), etc.) by HIPAA Covered Entities (the “Updated...more

Colorado AG Publishes Shortlist of Universal Opt-Out Mechanisms

On November 21, 2023, the Colorado Attorney General (the “AG”) published a shortlist of potential universal opt-out mechanisms (“UOOMs”) that the AG is considering recognizing as binding under the Colorado Privacy Act (the...more

FTC Launches Investigation into Creator of ChatGPT

In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more

California Privacy Protection Agency Publishes Updated CPRA Regulations

Yesterday, October 17, 2022, the California Privacy Protection Agency (“CPPA”) published its first set of Modified Proposed Regulations under the California Privacy Rights Act (“CPRA”).  The Modified Regulations have been...more

New Privacy Browser Extension Released under CCPA Global Do Not Sell Rules

On October 7, 2020, an organization named Global Privacy Control (“GPC”) issued a press release announcing an initiative to make a new “global privacy control” available to consumers as contemplated by the CCPA Regulations. ...more

BREAKING: Location and Mobile Data in the Fight against COVID-19 – An Overview of U.S. and Global Efforts

Governments are increasingly seeking to leverage consumer geolocation and other mobile device data to assist with fighting the spread of COVID-19, as cases continue to mount globally. Location data can be of significant...more

California Attorney General Issues Second Round of Modifications to CCPA Regulations

At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act...more

The Updated CCPA Regulations: 30 Potentially Material Business Impacts

California Attorney General Xavier Becerra has released updated regulations to the California Consumer Privacy Act (CCPA) that contain a number of material modifications to the initial CCPA regulations released in October...more

The Draft CCPA Regulations: 21 Potentially Significant Business Impacts

Our Privacy & Data Security Team summarizes the portions of California’s proposed regulations for the California Consumer Privacy Act (CCPA) that are likely of material interest to companies across industries and highlights...more

CCPA Carve-Out for Online Advertising? Proposed Amendment Exempts Certain Advertising Data from Do-Not-Sell Restrictions

California passed the California Consumer Privacy Act (CCPA) in September 2018, and the CCPA enters into force on January 1, 2020. One of the CCPA’s core elements is a right for consumers to know when a company is selling...more

An English-Language Primer on Germany’s GDPR Implementation Statute: Part 1 of 5

Over the past year, the German government has been working on legislation to implement the EU’s General Data Protection Regulation (GDPR). On July 6, 2017, Germany did so by passing a statute titled the Data Protection...more

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