David Keating

About David Keating

David Keating focuses his practice on matters involving technology and data and co-leads the Privacy, Cyber & Data Strategy Team. He has advised clients on privacy and security issues arising along the entire data lifecycle for more than 20 years. He assists clients with compliance strategies, policy development and implementation, data monetization and data use analyses, new product development, privacy and security issues in transactions, and privacy enforcement matters.

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California AG Announces $1.4 Million Settlement with Mobile App Provider for Alleged CCPA Violations

December 1, 2025 By Maki DePalo, David Keating and Hyun Jai Oh

On November 21, 2025, California Attorney General (AG) Rob Bonta announced a $1.4 million settlement with Jam City, Inc. (company), a mobile game app company, for alleged failures to enable in-app opt-outs from the sale and sharing of personal information across many of the company’s mobile apps as required by the California Consumer Privacy Act […]

California Finalizes New and Amended CCPA Regulations

September 24, 2025 By David Keating, Dorian Simmons and Anna von Spakovsky

On September 23, 2025, the California Privacy Protection Agency (“CPPA”) announced that the California Office of Administrative Law (“OAL”) had approved the new and amended California Consumer Privacy Act regulations that the CPPA delivered to OAL for approval following the CPPA’s July 24, 2025 Board meeting. This was the last step under California law to […]

Multistate Privacy Investigative Sweep Targeting Website Global Privacy Control (GPC) Noncompliance

September 10, 2025 By David Keating, Daniel Felz and Hyun Jai Oh

On September 9, 2025, the California Privacy Protection Agency (CPPA) announced a joint investigation sweep targeting businesses that may be failing to honor consumers’ opt-out requests submitted via Global Privacy Control (GPC) signals, in coordination with the Attorneys General of California, Colorado, and Connecticut. The CPPA’s announcement underscores a growing trend of multi-jurisdictional collaboration among […]

State Regulators Form Privacy Law Implementation and Enforcement Group

April 17, 2025 By David Keating and Dorian Simmons

Eight state regulators have established a coalition called the Consortium of Privacy Regulators to collaborate on the implementation and enforcement of their privacy laws. According to announcements from the California Privacy Protection Agency (“CPPA”) and California Attorney General Rob Bonta, the Consortium aims to coordinate enforcement efforts, share priorities, and discuss developments in privacy law. […]

California Attorney General Targets Location Data in New Investigative Sweep

March 12, 2025 By David Keating and Hyun Jai Oh

This week California Attorney General Rob Bonta announced a new investigative sweep under the California Consumer Privacy Act (CCPA). We have anticipated this sweep for some time based on the focus and the direction of a number of inquiries, investigations, and enforcement proceedings initiated by Attorney General Bonta’s office over the past 12-24 months. The […]