2023 was an active year for data protection-related litigation. Plaintiffs continued to advance creative theories of liability against businesses, using both older and more established privacy laws (such as the Telephone Consumer Protection Act and the Biometric Information Privacy Act) and newer laws (such as the California Consumer Privacy Act). Plaintiffs also continued to bring lawsuits against companies after data breaches, while also looking to explore causes of action related to companies’ use of web trackers.