The California Privacy Protection Agency (CPPA) flexed its CCPA enforcement muscle last month when it entered into a stipulated settlement (Order) with American Honda Motor Co. The CPPA’s inaugural enforcement action, which required the automobile distributor to pay a $632,500 fine, signals the agency’s stance on CCPA compliance – one that balances a strict reading of the statute with, perhaps, a more practical focus on readily provable violations. This article, with insights from Kelley Drye & Warren, Manatt and ZwillGen, examines the Order and its implications, evaluates the CPPA’s enforcement approach, and offers practical compliance lessons for companies. See “Outgoing CPPA Board Member Discusses Rulemaking and Looming Privacy Issues” (Sep. 25, 2024).