July 10, 2025
State attorneys general and regulatory agencies continue to enforce against violations of comprehensive state privacy laws, as demonstrated by recent enforcement actions by the California and Connecticut Attorneys General and the California Privacy Protection Agency to target violations related to online tracking technologies, opt-outs, and privacy notice violations. Organizations should assess their vendor contracts, consumer-facing notices, online advertising practices and consent mechanisms, as well as the backend processes supporting those mechanisms, as website violations continue to provide low-hanging fruit for privacy regulators.
Connecticut AG Fines TicketNetwork for Privacy Notice Violations
On July 8, 2025, Connecticut Attorney General (“AG”) William Tong announced an $85,000 settlement with TicketNetwork, Inc. for violations of the Connecticut Data Privacy Act (CTDPA). In addition to the fine, the settlement requires TicketNetwork, an online ticket marketplace, to comply with CTDPA requirements, maintain consumer rights request metrics, and report the metrics to the Attorney General.
CA AG Issues Largest CCPA Fine to Date for Violations Related to Online Surveillance and Tracking Tech
On July 1, 2025, California AG Rob Bonta announced a $1.55 million settlement with Healthline Media LLC (“Healthline”) for violations of the California Consumer Privacy Act (CCPA) related to online tracking technology, marking the largest CCPA settlement to date. As part of the proposed settlement, Healthline agreed to pay $1.55 million in civil penalties and comply with injunctive measures. The settlement is pending final approval from the court.
According to the AG, Healthline is a health and wellness information website, is one of the top 40 most visited websites in the world, and generates revenue by showing ads to readers, including personalized ads generated by third parties with whom readers’ health-related data was collected and shared via online trackers.
CPPA enforcement efforts: The California Privacy Protection Agency (“CPPA”) has also taken significant enforcement actions against various companies, including numerous data brokers. In May, the CPPA fined clothing retailer Todd Snyder for violations related to opt-out procedures. As in the Healthline complaint, according to the CPPA, Todd Snyder’s consent banner and cookie preferences settings did not function properly, also impacting its Global Privacy Control function, and the retailer improperly requested extensive verification steps when processing opt-outs. The enforcement action included a $345,178 fine and various compliance measures.
The CPPA’s recent initiatives include increased coordination on cross-border enforcement: the agency joined the Consortium of Privacy Regulators in April, along with state attorneys general from California, Colorado, Connecticut, Delaware, Indiana, New Jersey, and Oregon, with the goal of sharing resources, expertise, and coordinating investigations related to privacy enforcement. Later in April, the CPPA and the UK Information Commissioner’s Office (“ICO”) signed a declaration of cooperation to enhance international privacy protections. This the CPPA’s third such collaboration with international regulators, having announced a similar collaboration with the Republic of Korea's data protection authority (PIPC) in January 2025 and the French data protection authority (CNIL), in June 2024.
Narrowing exemptions: Companies should also prepare for the potential for increased regulatory scrutiny on financial institutions and financial data, as roughly 25 percent of states with comprehensive privacy laws will soon lack a broad entity-level exemption for financial institutions subject to GLBA. California has never provided such an exemption, Connecticut and Montana will eliminate the GLBA entity-level exemption starting in October 2025, and Oregon and Minnesota have drastically limited the exemption.
AI enforcement on the horizon: Rounding out the current enforcement landscape, companies should also prepare for potential AG enforcement related to AI practices in states with comprehensive AI laws, as a hotly debated federal moratorium on state AI laws ultimately failed to be passed by the U.S. Congress.
These materials have been prepared for informational purposes only and are not legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Internet subscribers and online readers should not act upon this information without seeking professional counsel.