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 bipartisan coalition of 33 state attorneys general, led by Minnesota AG Keith Ellison, began trial against Meta Platforms, Inc., alleging the company knowingly designed and deployed harmful features on Facebook and Instagram that drive children and teens to use the platforms compulsively, while falsely assuring parents and the public that its platforms were safe for young users. The states also allege Meta illegally collected personal information from children under 13 without parental consent, violating COPPA. The trial opened before Judge Yvonne Gonzalez Rogers in the U.S. District Court for the Northern District of California, with the states seeking monetary penalties and injunctive relief.
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).
A bipartisan coalition of state attorneys general began trial against Meta Platforms, Inc., alleging the company knowingly designed addictive features on Facebook and Instagram that harm children and teens, deceived parents about platform safety, and illegally collected personal information from children under 13 without parental consent in violation of COPPA. The states seek monetary penalties, an injunction to stop unlawful practices, and other relief. The trial is being litigated in the U.S. District Court for the Northern District of California.
$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.