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2022 CCPA Litigation and Enforcement Report

Posted on April 12, 2023June 24, 2025 by Dissent

By: Natasha G. Kohne, Michelle A. Reed, Molly E. Whitman, Lauren E. York, Rachel Claire Kurzweil, Shelly A. Kim, Tina M. Jeffcoat, Joseph Hold of Akin Gump

Our annual CCPA Litigation and Enforcement Report looks back at the third year of civil litigation and administrative enforcement related to the California Consumer Privacy Act (CCPA) and distilling salient points from more than 300 actions into key takeaways for businesses to evaluate and mitigate risks. The report also previews emerging trends in U.S. consumer litigation and regulatory enforcement in 2023.

Key findings include:

  • More than 80% of CCPA suits brought in 2022 corresponded to a breach notice filed with the California attorney general (AG). Businesses that report a data breach to the AG have about a 15% chance of subsequently facing consumer litigation.
  • Large data breaches were the source of the majority of the CCPA lawsuits, with more than half of the CCPA actions initiated in 2022 stemming from data breaches allegedly impacting the personal information of 100,000 or more people.
  • For the third year in a row, businesses in the financial services industry are the most likely to face a CCPA claim, with one-third of all CCPA claims initiated in 2022 targeting the industry.

Request the report here.

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