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Areas of Interest
June 22nd, 2022
Calif. Privacy Agency Signals Strength With Rules Proposal
Privacy & Data Security Chair Daniel M. Goldberg is quoted in the article, “Calif. Privacy Agency Signals Strength With Rules Proposal” published by Law360. The article discusses the California Privacy Protection Agency’s first draft of its regulations for the California Privacy Rights Act, a strengthened version of the state's Consumer Privacy Act set to take effect in January 2023. Daniel is quoted saying, "The regulations, as written, impose highly technical contractual and disclosure obligations that differ fundamentally from other privacy laws and will confuse businesses and consumers" and "I hope the CPPA will reduce many of these technical requirements in the next round."
The proposed regulation's mandate that businesses have a process for responding to global opt-out digital signals. Daniel says, “As it's currently drafted, the requirement is way too broad, and there are not enough qualifiers or explanations about what signals need to be recognized."
Daniel concludes by saying, "The purpose of privacy laws like CPRA is to provide individuals with more information about and choice around how their information is being used" and "Where things go wrong is when there are a lot of technicalities and granularities that require businesses to make even more disclosures that may not necessarily help consumers."
Read the full article here. (Behind paywall)
Other Quoted
https://www.law.com/corpcounsel/2025/12/12/ftc-weighs-petition-to-revive-click-to-cancel-rule/
Law.com quoted Holly Melton was quoted in a Law.com in an article discussing the Federal Trade Commission's consideration of a petition to revive the "Click to Cancel" rule. Ms. Melton analyzed the FTC's potential next steps following the rule's invalidation by the Eighth Circuit Court of Appeals. She noted that when Amazon agreed to pay $2.5 billion in September to settle allegations of deceptive Prime subscription practices, the settlement document included language indicating that any future rulemaking on subscription cancellations would supersede the agreement's provisions. Mr. Melton emphasized that this language "reads like a deliberate placeholder—future-proofing the settlement for the reappearance of click to cancel," suggesting the commission anticipates reviving the rule in some form. She advised that businesses should maintain compliance with the rule's underlying principles, stating that "for advertisers and subscription-based businesses, the path forward is clear: provide transparent disclosures, obtain affirmative consent, and make cancellation as effortless as sign-up." Read the full article on the “Click to Cancel” rule here. ( Behind paywall).
December 18 2025
Challenges in Opt-Out Design and Children’s Privacy Highlighted by Sling TV’s Settlement With California AG
Cybersecurity Law Report quoted Daniel Goldberg regarding California AG Rob Bonta's $530,000 settlement with Sling TV for CCPA violations related to opt-out processes and children's privacy protections. Read more.
December 1 2025
Game Companies Must be Flexible to Comply with Changing Laws
Emma Smizer was recently featured as a panelist at GamesBeat Next 2025 and quoted in a GamesBeat article discussing global regulatory compliance and its impact on the gaming industry. Read more.
November 25 2025
