2025 Brings Heightened Focus On Location Data And Online Tracking Through Increased Enforcement And Litigation

If the first quarter of 2025 tells us anything about privacy litigation and enforcement trends for the remainder of the year, it is that there will be increased attention on companies' use of online tracking technologies and geolocation data. So far this year, consumers brought the first federal class action complaint under the Washington My Health My Data Act (MHMDA), Honda entered into a settlement with the California Privacy Protection Agency (CPPA) over privacy violations, the CPPA announced an investigative sweep of the location data industry, and the Texas Attorney General brought his first enforcement action under the state's broadly applicable consumer privacy law.

These developments underscore the need for companies to periodically evaluate their compliance practices related to tracking technologies and the collection and use of location data. Because such technologies and practices are critical business tools, companies should create a process to implement