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December 1st, 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. Goldberg noted this is "the first CCPA settlement involving a connected TV" and indicates that connected TV is now a priority for privacy enforcement. Goldberg predicted future settlements are more likely to reach seven or eight figures as investigations progress. He explained that companies struggle to operationalize opt-outs across different platforms because many rely heavily on consent management platform vendors that often cover only cookie-based activity and don't connect to the backend systems that actually drive targeted advertising.
On children's privacy, Goldberg highlighted the CA AG's aggressive stance, noting that although Sling TV didn't collect age data, the AG concluded they still had knowledge of minors through child-directed channels, notifications from programmers, demographic inferences purchased from data brokers, and ad-targeting segments that included children. He observed this "arguably expands the notion of 'actual knowledge' under the CCPA." Goldberg advises companies to map out data flows and opt-out signals across every environment and audit vendor configurations to ensure the tools actually work. Read the full article on children’s privacy protections here. (Behind a 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
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
Copyright Guide or Policy Change? Project Divides IP Attys
Law360 quoted Jacqueline Charlesworth on the controversy surrounding the American Law Institute’s copyright restatement project. Read more.
November 19 2025
