On September 13, 2019, the California State Legislature passed
Assembly Bill No. 1202 (the "Bill"),
amending the California Consumer Privacy Act ("CCPA") to
require certain businesses to register as data brokers with the
State Attorney General's Office. The Legislature believes that
a California data broker registry will provide greater transparency
on the issue of third parties that may have access to their
personal information (companies that they do not have a first party
relationship with the consumer) and allow consumers to
prospectively opt out of the "sale" of this personal
information. The CCPA defines "sale" in a very broad
fashion, such that it includes the "selling, renting,
disclosing, disseminating, making available, transferring, or
otherwise communicating orally, in writing, or by electronic or
other means, a consumer's personal information by the business
to another business or third party for monetary or other valuable
consideration." In practice, this
