State Legislatures

On March 26, 2025, Utah Governor Spencer Cox signed into law SB 142, the App Store Accountability Act (the “Act”), enacting the country’s first state law that requires app store providers to verify the age of all users and places obligations on app developers. An “app store provider” is defined as “a person that owns, operates, or controls an app store that allows users in [Utah] to download apps onto a mobile device.” A “developer” is defined as “a person that owns or controls an app made available through the app store in the state.”

The law goes into effect on May 7, 2025, and the obligations on app store providers and developers are not effective until May 6, 2026. Some key provisions are outlined below.Continue Reading Utah Enacts App Store Accountability Act

On June 22, 2023, the Oregon state legislature passed the Oregon Consumer Privacy Act, S.B. 619 (the “Act”).  This bill resembles the comprehensive privacy statutes in Colorado, Montana, and Connecticut, though there are some notable distinctions.  If passed, Oregon will be the twelfth state to implement a comprehensive privacy statute…

Continue Reading Oregon Legislature Passes Consumer Privacy Act

On March 28, Governor Kim Reynolds signed into law SF 262, making Iowa the sixth state to enact a comprehensive consumer privacy law.  The new law will take effect on January 1, 2025.

As we discuss here, Iowa’s privacy law shares a number of key similarities to existing…

Continue Reading Iowa Enacts Comprehensive Consumer Privacy Law

The Colorado Department of Law issued draft rules implementing the Colorado Privacy Act.  The proposed draft rules will be published in the Colorado Register and available for comment on October 10, 2022.

Continue Reading Colorado Attorney General Issues Draft Rules Under the Colorado Privacy Act

On September 16, the Fifth Circuit issued its decision in NetChoice L.L.C. v. Paxton, upholding Texas HB 20, a law that limits the ability of large social media platforms to moderate content and imposes various disclosure and appeal requirements on them.  The Fifth Circuit vacated the district court’s preliminary injunction, which previously blocked the Texas Attorney General from enforcing the law.  NetChoice is likely to ask the U.S. Supreme Court to review the Fifth Circuit’s decision.Continue Reading Fifth Circuit Upholds Texas Law Restricting Online “Censorship”

Today, the California Attorney General announced the first settlement agreement under the California Consumer Privacy Act (“CCPA”).  The Attorney General alleged that online retailer Sephora, Inc. failed to disclose to consumers that it was selling their information and failed to process user requests to opt out of sale via user-enabled global privacy controls.  The Attorney General also alleged that Sephora did not cure these violations within the cure period. Continue Reading California Attorney General Announces First CCPA Settlement

The Connecticut legislature passed Connecticut SB 6 on April 28, 2022.  If signed by the governor, the bill would take effect on July 1, 2023, though the task force created by the bill will be required to begin work sooner.

The bill closely resembles the Colorado Privacy Act, with a few notable additions.  Like the Colorado Privacy Act, the bill adopts “controller” and “processor” terminology, provides consumers with rights to access, correct, delete, obtain a copy, and opt-out of certain types of processing of their personal data, and requires consent for certain activities.
Continue Reading Connecticut Legislature Passes Comprehensive Privacy Bill

Utah appears poised to be the next state with a comprehensive privacy law on its books, following California, Virginia, and Colorado.  On March 2nd, the Utah House of Representatives voted unanimously to approve an amended version of the legislative proposal, and the Senate concurred with the House amendment on the following day.  Formalities are now being completed to send the bill to Governor Spencer Cox for signature.

The Utah Consumer Privacy Act (“UCPA”) provides for consumer rights and responsibilities for controllers and processors.  Although the bill generally tracks the comprehensive privacy law passed in Virginia last year, the VCDPA, there are some notable differences.  Key provisions in the bill include the following:
Continue Reading Utah Legislature Passes Comprehensive Privacy Bill