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Liisa Thomas

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Liisa Thomas, a partner based in the Chicago and London offices, is Leader of the firm's Privacy and Cybersecurity Practice Group.

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Minnesota has a new law that, beginning a year from now, will require that social media companies warn users of the potential negative mental health effects of social media use each time a user accesses a social media platform. The warning label will need to include specific content, including information about mental health resources (like the national suicide prevention and mental health crisis hotline). The law also specifically prohibits including “extraneous information” in the warning label. It must be on-screen (not in a company’s website terms) and remain on screen until the user either acknowledges and agrees to it, or leaves the site.Continue Reading Minnesota May Be First to Require Social Media Warning Label

Oregon will begin to regulate the use of minors’ information and sale of users’ location data (regardless of age) with an update to its Oregon Consumer Privacy Act. These revisions will go into effect January 1, 2026. As amended, those subject to the law will not be able to profile or serve targeted advertising to anyone under 16. This includes both those the company knows are under that age, as well as those that they should know are under that age. (Currently, restriction that applies to consumers that are at least thirteen but not older than fifteen without their consent.)Continue Reading Oregon’s Privacy Law Update Adds to Patchwork Approach to Minors and Location Data

The US “comprehensive” law landscape continues to expand, with two more states—Tennessee (July 1) and Minnesota (July 31) —joining the “comprehensive” privacy law club. Five of these -Delaware, Iowa, Nebraska, New Hampshire, and New Jersey- took effect in January. As the patchwork of state-level “comprehensive” privacy laws expands, what should business keep in mind? As outlined below, perhaps the biggest takeaway is that the laws add to a patchwork, one which consists of many overlapping requirements. Here are a few highlights from these two latest laws:Continue Reading US Privacy Footprint Continues to Expand: Tennessee and Minnesota Join the State Law Club

Vermont has joined the list of states attempting to regulate the use of children’s information collected online, passing an Age-Appropriate Design Code Act. This law mirrors ones we have seen in other US states as well as the UK, and applies to online services reasonably accessed by minors, that collect personal data. We expect it to be challenged, but if it is not, it would go into effect January 1. Among other things, the law provides the following:Continue Reading Growing List of States Attempting to Regulate Kids’ Online Privacy: Vermont Joins the Group

In ongoing tweaks to state privacy laws, Oregon has amended its state privacy law to cover auto manufacturers. Specifically, those that process or control personal information that they get from a person’s use of a car. As most are aware, the law requires disclosures when collecting personal information, provision of rights to consumers (including the ability to delete and port personal information), and limits on profiling among other things. While the Oregon law, like most state “comprehensive” laws, includes applicability thresholds, there are no thresholds for this new applicability to car manufacturers. The law is slated to go into effect in September of this year.Continue Reading Oregon Extends Privacy Law to Specifically List Auto Makers

North Dakota recently passed a law establishing new rules for certain financial companies operating in the state – specifically “financial corporations.” The new obligations will take effect on August 1, 2025. They will apply to businesses that the North Dakota department of financial institutions regulates. Financial institutions (like banks and loan companies) and credit unions are not regulated by that entity.Continue Reading North Dakota Passes New Data Security Law for “Financial Corporations”

Nebraska’s governor signed a bill into law that, among other things, creates the Parental Rights in Social Media Act. The provisions of the law will go into effect July 1, 2026, unless challenged. The law is similar to several other states, most of which have been challenged (including Arkansas, California, and Utah) and some struck down.Continue Reading Growing List of States Attempting to Regulate Kids’ Social Media Accounts: Nebraska Husks Up

The Michigan Attorney General has filed a complaint against Roku, a popular TV content platform, alleging, among other things, violations of the Children’s Online Privacy Protection Act and the Video Privacy Protection Act (and a similar Michigan law). As most are aware, COPPA requires prior parental consent before collecting information from children online. It gives standing to both the FTC and to states’ attorneys general, but no private right of action. Most cases brought since COPPA’s passage have been brought by the FTC, however, and not by states. This current Michigan case comes after a group of 43 states, including Michigan, sent a letter to the FTC urging it to strengthen and update its COPPA Rule.Continue Reading Michigan AG Sues Roku Over Alleged Privacy Violations

Virginia’s governor recently signed into law a bill that amends the Virginia Consumer Data Protection Act. As revised, the law will include specific provisions impacting children’s use of social media. Unless contested, the changes will take effect January 1, 2026. Courts have struck down similar laws in other states (see our posts about those in Arkansas, California, and Utah) and thus opposition seems likely here as well. Of note, the social media laws that have been struck down in other states attempted to require parental consent before minors could use social media platforms. This law is different, as it allows account creation without parental consent. Instead, it places restrictions on account use for both minors and social media platforms.Continue Reading Virginia Will Add to Patchwork of Laws Governing Social Media and Children (For Now?)