Penalty Amount
$18,500,000
Target settled a multi-state enforcement action for a 2013 data breach that exposed payment card information of over 40 million customers due to inadequate security. The $18.5 million settlement requires Target to implement advanced security measures, and California receives over $1.4 million.
Target must pay $18.5 million and implement a comprehensive information security program, including appointing an executive to oversee security, encrypting payment card data, and adopting other technological measures as recommended in the Attorney General's Data Breach Reports.
In-house legal teams should review vendor agreements for data security obligations, ensuring they mandate compliance with standards like PCI DSS and include audit rights and incident response requirements. Customer agreements must be assessed for adequate breach notification clauses, including timelines and scope of affected data. Employee agreements and internal policies should cover data handling protocols, access controls, and encryption. Updates may be needed to incorporate specific security measures, regular vulnerability assessments, and clearer liability provisions for payment card data breaches, aligning with multi-state enforcement expectations.
Entity
Target
Industry
RetailOfficial Press Release
Final Judgment and Permanent Injunction
https://oag.ca.gov/system/files/attachments/press_releases/Final%20Judgment%20and%20Permanent%20Injunction.pdf
Complaint for Injunctive and Other Relief
https://oag.ca.gov/system/files/attachments/press_releases/Complaint%20for%20Injunctive%20and%20Other%20Relief.pdf
California Attorney General Enforcement Page
https://oag.ca.gov/privacy/privacy-enforcement-actions
A coalition of 12 state attorneys general, led by Colorado AG Phil Weiser, obtained a temporary restraining order from a federal court in California to halt the proposed $110 billion merger of Warner Bros. Discovery, Inc. by Paramount Skydance Corporation. The lawsuit alleges the merger violates Section 7 of the Clayton Act by substantially lessening competition in film distribution, anticipated blockbuster film distribution, and licensing cable TV channels.
The California Privacy Protection Agency (CalPrivacy) joined a coalition of 18 Attorneys General and state agencies in opposing the proposed SECURE Data Act, a federal privacy bill that would preempt stronger state privacy laws like the CCPA. The coalition argues the bill would weaken consumer privacy protections, limit enforcement remedies, and undermine California's Delete Request and Opt-out Platform (DROP).
$12.8M
California Attorney General Rob Bonta, along with multiple district attorneys and the California Privacy Protection Agency, announced a $12.75 million settlement with General Motors for illegally selling hundreds of thousands of Californians' location and driving data to data brokers Verisk and LexisNexis without notice or consent. The settlement includes the largest CCPA penalty to date, a five-year ban on selling driving data to consumer reporting agencies, and requirements to delete retained data and implement a robust privacy program.
The California Privacy Protection Agency Board voted to support two bills (AB 1542 and SB 1106) and took a 'support if amended' position on a third bill (AB 883). These bills aim to strengthen privacy protections by expanding sensitive data protections, improving deletion rights under the Delete Act, and providing expedited deletion for elected officials and judges.
The California Privacy Protection Agency sent a letter to Congress opposing the SECURE Data Act, a federal bill that would preempt state privacy laws like the CCPA and Delete Act. The letter argues the bill would eliminate rights for 40 million Californians, including the DROP platform and opt-out preference signal requirements, and urges Congress to set a floor rather than a ceiling on privacy protections.
California Attorney General Rob Bonta, joined by attorneys general from seven other states, filed a lawsuit to block the $6.2 billion merger between Nexstar Media Group and Tegna Inc. The lawsuit alleges the merger violates Section 7 of the Clayton Act by reducing competition in local TV markets, leading to higher prices, less local news, and job losses.