Michael A. Signorelli

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Michael Signorelli, co-chair of the Technology and Innovation Group, focuses his practice on advising and representing clients on issues related to data privacy and security. Mike regularly advises companies on compliance with relevant Internet, cybersecurity, advertising, and marketing regulations, as well as responding to data breaches. He represents clients in federal and state data-related legislative issues, rulemaking proceedings, and other matters before the Federal Trade Commission (FTC), Federal Communications Commission (FCC), Federal Election Commission (FEC), the U.S. Department of Commerce, and other U.S. federal and state agencies.

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On June 18, 2024, California Attorney General (AG) Rob Bonta announced a third CCPA enforcement settlement, this one with Tilting Point Media LLC. Tilting Point was allegedly using its mobile app game “SpongeBob: Krusty Cook-Off” to collect, share, and sell the data of minors, in violation of the California Consumer Privacy Act (CCPA), California’s Unfair Competition Law (UCL), and the Children’s Online Privacy Protection Act (COPPA). Tilting Point agreed to pay a $500,000 civil penalty and implement certain measures to address the alleged violations. The settlement is notable for combining enforcement of COPPA alongside the CCPA, targeting similar practices but different age groups under each law. Also notably, the AG investigated Tilting Point after the Children’s Advertising Review Unit (CARU) of BBB National Programs issued findings alleging that Tilting Point’s practices violated COPPA. The AG alleged that Tilting Point failed to correct its practices following the investigation by CARU. The case illustrates the risks of ignoring industry self-regulatory reviews and provides a roadmap other states can use to leverage multiple laws against the same activities.

The AG’s complaint focused on the key allegations outlined below:Continue Reading California Attorney General’s Recent Enforcement of CCPA and COPPA