Many modern data privacy statutes rely heavily on regulatory enforcement. The amount of civil penalty that a regulator can see for violations differs between and among the states. It should also be noted, there may be ambiguity within certain states regarding how violations are “counted.” For example, a business might consider the inadvertent selling of

The California Consumer Privacy Act provided plaintiffs with a private right of action to pursue statutory damages following data security breaches that impact certain sensitive categories of information and are caused by a business’s failure to institute reasonable and appropriate security. Although the CCPA does not permit private suits with respect to alleged violations of