Cyber security supply chain risks are growing, and attacks on vendors and other third parties cause severe disruption to businesses. For example, in recent years we have seen many incidents that have involved threat actors compromising third-party software used by a significant number of customers. With that background, on May 7, 2025, the National Cyber […]
Privacy & Cyber Regulatory Enforcement
CPPA Issues Revised Draft CCPA Regulations; Votes to Initiate Public Comment Period
On May 1, 2025, the California Privacy Protection Agency (“CPPA”) Board convened to discuss revisions to the California Consumer Privacy Act (“CCPA”) draft regulations on cybersecurity audits, risk assessments, automatic decisionmaking technology (“ADMT”), insurance, and updates to the existing CCPA regulations. The revisions were informed by comments received by the CPPA during the formal public […]
Additional Cybersecurity Requirements of NYDFS Part 500 Take Effect Today
Today, on May 1, 2025, additional enhanced cybersecurity controls required by the Second Amendment to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) (the “Second Amendment”) take effect. Although the Second Amendment was originally adopted in November of 2023, NYDFS established a multi-year rollout of the Second Amendment’s requirements, […]
Arkansas Enacts Children and Teens’ Online Privacy Protection Act
On April 21, 2025, Arkansas Governor Sarah Huckabee Sanders signed into law the Arkansas Children and Teens’ Online Privacy Protection Act (Act), which will become effective on July 1, 2026. It draws inspiration from the federal Children and Teens’ Online Privacy Protection Act (COPPA 2.0) and provides stronger privacy protections for Arkansas residents under thirteen […]
Ninth Circuit Addresses Personal Jurisdiction Based on E-Commerce Data Collection in En Banc Decision
A recent decision by the Ninth Circuit Court of Appeals in Briskin v. Shopify, Inc., No. 22-15815, could impact the scope of personal jurisdiction over e-commerce and other entities that utilize cookies to collect personal information from visitors to the entities’ websites, particularly in California. Although the impact of the case remains to be seen, […]