In a complaint filed on Monday involving an alleged data breach, Barnes v. Hanna Andersson, the California Consumer Privacy Act (CCPA)—the State’s comprehensive privacy law that went into effect on January 1, 2020—was cited for what appears to be the first time in a lawsuit.  Importantly, however, the plaintiff in this case has not asserted a claim under the CCPA or alleged a violation of the CCPA as a predicate for a claim under the California Unfair Competition Law (UCL).  This might be because, according to the complaint, the alleged data breach occurred between September­–November 2019, before the CCPA went into effect.