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ARTICLE · 17 FEBRUARY 2026

Takeaways From The Disney CCPA $2.75 Million Settlement

Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
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Frankfurt Kurnit Klein & Selz PC

Frankfurt Kurnit Klein & Selz PC

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On February 11, the California Attorney General's Office announced a settlement with Disney for alleged violations of California privacy law.

United StatesTechnology

On February 11, the California Attorney General's Office announced a settlement with Disney for alleged violations of California privacy law. At $2.75 million, the settlement is the largest CCPA penalty to date. The monetary penalty, however, is only part of the story. Below are my key observations. You can read the complaint here and the settlement here.

1. Cost of Noncompliance

While $2.75 million is the largest CCPA penalty to date, the penalty is only a fraction of the total cost. The cost required to respond to an investigation of this complexity and bring a company of this size into compliance likely dwarfs the civil penalty. The judgment includes a compliance program with 60-day check-ins until certain requirements are met. The takeaway is straightforward: regulatory enforcement is expensive, even before you factor in penalties. Investigations require engineering time, legal resources, internal audits, vendor coordination, and often architectural changes.

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This post first appeared in Frankfurt Kurnit's Focus on the Data blog (www.focusonthedata.com). It provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

Originally published by the New York Legal Ethics Reporter

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

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