Texas AG’s Billion-Dollar Settlement With Google Highlights Biometric Data Use Compliance Considerations

Make room, Biometric Information Privacy Act. This month, the Texas AG used the state’s biometric law (CUBI) to help secure a $1.375‑billion settlement with Google, resolving two privacy complaints centered on the tech giant’s use of individuals’ biometric, geolocation and incognito-mode search data. CUBI allows $25,000 in damages per violation. The settlement, which echoes the billion-dollar settlement with Meta in 2024, highlights the AG’s broad interpretation of CUBI’s provisions. With insights from experts at Baker Botts, Blank Rome, Carter Ledyard & Milburn and Haynes Boone, this article examines the circumstances surrounding the settlement, offers four biometric law compliance considerations, and discusses regulatory and litigation risk factors highlighted by the case. See “What Texas’ Record $1.4‑Billion Deal With Meta Portends for Biometric Data Capture and Use” (Aug. 21, 2024).

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