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In order for an entity to be considered a business, and hence regulated by the CCPA, it must satisfy at least one of three thresholds. One such threshold is whether the business has “annual gross revenue in excess of twenty-five million dollars.”[1]

The CCPA does not specify whether the gross revenue threshold refers to revenue generated by a business in the state of California, or revenue generated by a business from any location. The Office of the Attorney General was asked to clarify how businesses should compute their gross revenue and, in response, indicated that the CCPA “does not limit the revenue threshold to revenue generated in California or from California residents.” The Attorney General further refused to consider regulations which would limit the revenue calculation to California stating that “[a]ny proposed change to limit the threshold to revenue generated only in California or from California residents would be inconsistent with the CCPA.”[2]

[1] Cal. Civil Code 1798.140(c)(1)(A) (Oct. 2020).

[2] FSOR Appendix A at 1 (Response 5).