On November 18, 2022, WLF filed its second comment with the California Privacy Protection Agency (CPPA), which recently modified its proposed privacy regulations under the California Privacy Rights Act. In response to WLF’s August 17 comment, the CPPA removed 19 of the 46 compliance burdens flagged by WLF. While WLF commends the CPPA for eliminating these 19 compliance burdens, the administrative and procedural defects identified by WLF remain for the 27 remaining burdens highlighted by WLF. As WLF explains, these burdens should be eliminated, or else their procedural and administrative defects remedied, before final notice and comment. WLF’s supplemental comment was drafted with the pro bono assistance of David Zetoony and Andrea Maciejewski of Greenberg Traurig LLP.
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