Insights

CCPA Privacy Law Harry Richt November 6, 2025

California AG Secures $530,000 Settlement with Sling TV: A New Phase in CCPA Enforcement

California Attorney General Rob Bonta recently announced a $530,000 settlement with Sling TV, marking the fifth enforcement action by the Attorney General’s office and the eighth overall under the California Consumer Privacy Act (CCPA) since its enactment (See other enforcement actions against: Honda, Todd Snyder, Healthline, among others). The official press release detailing the case is available on the California OAG’s website, and the …

Blockchain Technology Law Harry Richt October 20, 2025

SEC’s DoubleZero No-Action Letter: A Potential Turning Point for Decentralized Infrastructure Networks

In a significant development that may reshape the regulatory landscape for decentralized physical infrastructure networks (DePIN), the Securities and Exchange Commission’s Division of Corporation Finance issued a groundbreaking no-action letter to DoubleZero Foundation on September 29, 2025. This decision represents one of the most comprehensive analyses of cryptocurrency token distributions under federal securities laws in …

Cryptocurrency Technology Law Harry Richt October 10, 2025

The Salomon Brothers Bitcoin Dusting Campaign: Novel Legal Theory or Speculative Overreach?

A Legal Analysis of Constructive Possession Claims, Abandoned Property Law, and Self-Custodial Digital Assets Executive Summary In summer 2025, an unknown client of Salomon Brothers Securities Inc. executed an unprecedented campaign, sending over 41,000 OP_RETURN messages to dormant Bitcoin wallets controlling approximately 2.3 million BTC (roughly 11% of Bitcoin’s circulating supply). These messages claimed “constructive …

CCPA Privacy Law Harry Richt October 4, 2025

CPPA’s $1.35 Million Tractor Supply Settlement: Major CCPA Enforcement Lessons on Opt-Out Rights and Privacy Compliance

On September 26, 2025, the California Privacy Protection Agency (CPPA) Board adopted a Stipulated Final Order imposing a $1.35 million administrative fine against Tractor Supply Company for multiple violations of the California Consumer Privacy Act (CCPA). This enforcement action, announced by the CPPA, represents one of the agency’s most significant settlements to date and offers …

Marketing Law TCPA Harry Richt October 4, 2025

Texas Defends SB 140: What the State’s Opposition Brief Means for SMS Marketers

On September 26, 2025, the Texas Attorney General’s office filed its opposition to the preliminary injunction motion in the federal constitutional challenge to Texas SB 140. While the State’s position may provide some comfort to SMS marketers operating consent-based programs, businesses should understand both what the filing says—and what risks remain despite it. December 2025 …

Marketing Law Pricing Harry Richt September 25, 2025

FTC Secures Historic $2.5 Billion Settlement Against Amazon for Prime Subscription Violations

The Federal Trade Commission has secured a monumental $2.5 billion settlement against Amazon.com, Inc., marking one of the largest consumer protection settlements in FTC history and sending a clear message to companies about the importance of subscription transparency and easy cancellation processes. The Settlement Details This historic settlement stems from allegations that Amazon engaged in …

Privacy Law Harry Richt September 24, 2025

Meta Loses Post-Trial Bid in Landmark CIPA Case Involving Flo Health App

A landmark jury verdict against Meta Platforms, Inc. in a California privacy class action was recently upheld by the United States District Court for the Northern District of California. The case, Frasco v. Flo Health, Inc., involved allegations that Meta, through its integration of the Facebook SDK in the popular Flo Period and Ovulation Tracker app, unlawfully obtained and …

COPPA Privacy Law Harry Richt September 21, 2025

FTC Intensifies Children’s Privacy Enforcement With Major COPPA Settlements

The Federal Trade Commission has demonstrated renewed vigor in its enforcement of children’s privacy protections, announcing two significant proposed settlement orders in September 2025 that underscore the agency’s commitment to safeguarding minors’ personal information online. These enforcement actions signal a broader trend toward heightened scrutiny of companies’ compliance with children’s privacy laws and highlight the …

Marketing Law TCPA Harry Richt September 20, 2025

Washington Court Expands CEMA to Cover Recruitment Text Messages

Executive Summary The Washington Court of Appeals has significantly expanded the scope of the state’s Commercial Electronic Mail Act (CEMA) in a decision issued on September 15, 2025 (for PDF version, click here), which will impact how businesses communicate with potential workers and contractors. In Aaland v. CRST Home Solutions, LLC, the court ruled that …

Marketing Law TCPA Harry Richt September 17, 2025

Federal Constitutional Challenge Filed Against Texas SB 140 SMS Marketing Regulations

On September 1, 2025, a coalition of e-commerce businesses and industry advocates filed a federal lawsuit in the Western District of Texas challenging the constitutionality of Texas Senate Bill 140 (SB 140). The plaintiffs, Ecommerce Innovation Alliance, Flux Footwear, and Postscript, argue that the new law’s expansive regulations on text message marketing violate fundamental constitutional …

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