Join Coblentz partner Sabrina Larson on May 19, 2026 for “US Trademark Searching and Filing Strategies” during the Practising Law Institute’s Trademark Law Workshop 2026. Sabrina’s session will cover how to clear a mark for use and registration, implement searching practice tips based on analysis of hypothetical mark, prepare USPTO applications to pass muster (both use-based and intent-to-use), develop strategies for Examiner refusals, and assess acceptable specimens for applications and maintenance filings. For more details, please click here.

 

 

Join Caitlin Connell and Kiana Araghi on Friday, May 15, 2026 for “Lease Guaranties in California Commercial Real Estate: Structuring, Drafting, and Enforcement” during the California Lawyers Association’s 2026 Real Property Law Retreat. Caitlin and Kiana will examine guaranty structures, the California Civil Code waivers every practitioner should include, due diligence on guarantors, and bankruptcy considerations. They will also discuss how landlords are using creative guaranty structures to attract emerging AI and technology companies without sacrificing meaningful protection. For more details, please click here.

Join Coblentz special counsel Angel Saunders on Wednesday, April 1, 2026 for the EntreArchitect Network webinar “Fundamentals of Estate Planning and Probate.” Angel will provide an overview of the essential components of a well-designed estate plan, including wills, revocable living trusts, powers of attorney, and advance health care directives.

An EntreArchitect Network membership is required to attend this program. For more details, please click here.

 

Join Coblentz partner Jennifer Scharre on Wednesday, April 1, 2026 for the California Lawyers Association MCLE webinar “Will All the Real Billionaires Please Stand Up.” Jennifer will explore the proposed Billionaire’s Tax initiative in California and discuss how net worth is calculated, how the tax may impact clients, planning opportunities, and potential constitutional challenges. For more details, please click here.

A roundup of news and multimedia from the Unfamiliar Terrain team:

San Francisco

Proposed waterfront tower could test California’s power to override S.F. height restrictions (SF Chronicle): A proposed waterfront tower project shows how new high-rise development proposals are reshaping debates over design, density, and growth along San Francisco’s northeastern waterfront.

The Marina Safeway may be SF NIMBYs’ last stand (SF Standard): A controversial proposal to redevelop the Marina Safeway site into a high-rise housing complex has become a focal point for debates about neighborhood opposition and the growing influence of California’s pro-housing state laws.

Scaled-back Potrero Yard plan clears way for 100 affordable homes in S.F. (SF Chronicle): SFMTA has scaled back the redevelopment plan (reduced from 465 to 100 units) for the Potrero Yard bus facility, with a nonprofit developer building the new affordable housing on the Bryant Street side of the site, rather than on top of the bus yard facility as originally planned.

Office-to-housing conversion planned for historic downtown S.F. building (SF Business Times): Local conversions of office buildings to housing have been much-discussed but rarely proposed; now a proposal 901 Market Street will test whether regulatory changes will help these projects pencil.

S.F. leaders propose cutting city’s transfer tax to spur stalled housing projects (SF Chronicle): A proposal by San Francisco leaders to reduce the city’s real estate transfer tax seeks to revive stalled housing projects and catalyze new residential development.

Here’s how much it costs to buy S.F.’s Transamerica Pyramid (SF Chronicle): Transamerica is under contract to sell for approximately $700 million, likely at a loss for its current owners after a costly renovation, but the deal suggests renewed global investor interest in San Francisco’s highest-end office properties despite the city’s relatively weak broader office market.

Bay Area

The Napa town where it’s easier to win a Michelin star than build an apartment (SF Standard): The debate over the proposed Yountville Commons workforce housing project intensified after celebrity chef Thomas Keller publicly criticized the town’s plans, arguing local workers need larger units and more parking.

California Forever Eyes New Trump Initiative to Bring Its Shipbuilding Plans to Life (KQED): California Forever proposes to use a recent “Maritime Prosperity Zone” initiative to secure federal support and incentives for a regional shipbuilding revival in the California Delta, tied to its broader Solano County development plans.

Chevron’s HQ left California. A developer now plans to add thousands more homes in its place (SF Chronicle): Sunset Development proposes to turn Chevron’s former San Ramon headquarters and surrounding office park into a mixed-use community with thousands of new homes, retail, and other amenities, reflecting a broader shift away from suburban office campuses in the remote-work era.

Concord rezoning paves the way for 1,000 homes in single-family neighborhoods (SF Business Times): The East Bay city completed rezoning to implement its housing element, avoiding potential “builder’s remedy” projects and creating higher-density opportunities in a traditionally low-density community.

California and Beyond

Senate passes bipartisan housing bill targeting large investors and easing regulations (NPR): The largest federal housing bill in decades has passed the U.S. Senate on an 89-10 vote, focusing on spurring supply and limiting institutional owners’ ability to purchase single-family homes.

L.A. council puts off yet another attempt to rewrite the city’s ‘mansion tax’ (LA Times): A Los Angeles City Council vote to place revisions to the city’s controversial “mansion tax” (Measure ULA) before voters was delayed after officials opted to send the proposal back for further review amid debate over whether the tax is hindering housing development or funding critical homelessness programs.

By Scott Hall and Phillip Wiese

This update is intended as a follow-up to the Coblentz 2025 Mid-Year Privacy Report’s discussion of California privacy enforcement themes.

Since our 2025 mid-year privacy report highlighted the CPPA’s (now CalPrivacy’s) early enforcement playbook (Honda and Todd Snyder) and the California Attorney General’s landmark Healthline settlement, California regulators have kept up the pace into early 2026. Recent enforcement matters confirm that regulators are less interested in “paper compliance” than whether consumer choices actually work across real-world tech stacks, devices, and vendors. They also show expanding attention to (1) streaming/CTV ecosystems, (2) mobile apps (including youth data), (3) job applicant/employee-related data, and (4) data broker obligations under the Delete Act.

Below is a brief summary of new enforcement actions and an analysis of enforcement themes.

Recent Enforcement Actions and Developments

• Disney: “Account-wide” opt-outs across services and devices are expected and required.
  

  In February 2026, the California Attorney General announced a $2.75 million settlement with Disney entities tied to Disney’s streaming ecosystem. The core allegation was functional—namely, that consumers would try to opt out through toggles, a webform, or Global Privacy Control (GPC), but those signals allegedly did not fully propagate across the “bundle” of services and devices tied to the consumer’s account—leaving gaps where sale/sharing continued. This is the clearest statement yet (in enforcement posture) that if a business can link devices/services to a consumer for advertising or measurement, regulators expect it to be able to link those same devices/services to the consumer’s privacy elections—and to do so comprehensively.

• PlayOn Sports: CalPrivacy tackles opt-out mechanisms in high school sports website.
  

  In March 2026, CalPrivacy announced a $1.10 million decision against PlayOn Sports, a media company that sells digital tickets to certain high school events, including football games, theater performances, and school dances. According to CalPrivacy, high school students were required to agree to the use of tracking technology and collection of personal information without a meaningful way to opt out of that data collection in order to use the website. This enforcement action represented CalPrivacy’s first foray into enforcing the CCPA expressly on behalf of minors, describing the high school students as a “uniquely vulnerable population.”

• Ford Motor Co.: Opt-out requests need not be verified.
  

  In March 2026, CalPrivacy also announced a $375,000 decision against Ford Motor Company, finding that the automaker created “unnecessary friction” by improperly processing consumer requests to opt out of the sale or sharing of personal information. In particular, Ford used a standardized form for all CCPA requests, including the right to opt-out, and then required consumers to respond to a follow-up email to verify their identity. While companies can require verification for certain CCPA requests, including the rights to know, correct, and delete, the CCPA does not provide a similar verification process for opting out of data selling or sharing. Companies may consider utilizing different workstreams for opt-out requests and other CCPA-related requests to avoid this issue.

• Tractor Supply Co.: Opt-out mechanisms must work properly.
  

  In September 2025, CalPrivacy announced a $1.35 million decision against rural lifestyle retailer Tractor Supply Company after a single consumer reported the Tractor Supply privacy practices to the agency. CalPrivacy determined that Tractor Supply violated the CCPA in numerous ways. Critically, the CalPrivacy decision stated that Tractor Supply had a webform that did not in practice allow consumers to opt out of the sale or sharing of personal information. According to CalPrivacy, consumers could fill out a webform purporting to allow them to opt out of data sharing/selling, but Tractor Supply took no action to effectuate those requests. Additionally, CalPrivacy stated that Tractor Supply lacked CCPA-compliant contracts with service providers and other third parties, and that Tractor Supply did not provide all requisite notices under the CCPA, including to job applicants. As a result of these issues, Tractor Supply received the largest fine levied to date by CalPrivacy.

• Jam City: Don’t forget about mobile app opt-outs and under-16 protections.
  

  In November 2025, the AG announced a $1.4 million settlement with a mobile app gaming company. The AG’s announcement emphasized two points: (1) if personal information is sold/shared through mobile apps, consumers need compliant opt-out methods in-app, and (2) the CCPA’s heightened protections for consumers under 16 (affirmative opt-in for sale/sharing) are an active enforcement area. This builds directly on the mid-year theme that enforcement is moving from websites into the app ecosystem and is increasingly focused on whether the consumer experience is simple and effective.

• CalPrivacy (CPPA): Delete Act/data broker enforcement.
  

  In January 2026, CalPrivacy announced enforcement actions against a marketing firm and a technology firm for each failing to register as a data broker. CalPrivacy claimed that that the marketing firm was selling personal information about individuals with certain health conditions for targeting advertising and emphasized that simply packaging personal information into “custom audiences” or value-added products does not avoid data broker obligations. This connects to the broader enforcement theme that regulators are looking through form to function: if the business model involves the buying or selling of consumers’ personal information, it must comply with the CCPA and the Delete Act.

Privacy Enforcement Themes to Keep Top of Mind

• Regulators expect “functional” opt-outs, including end-to-end propagation across vendors, devices, and services. These latest enforcement actions make clear that the regulators expect companies to create a straightforward and streamlined consumer opt-out process. If, for example, a consumer opts out of data sharing/selling, that request must be fulfilled across the company’s entire ecosystem unless the consumer specifically limits the request. The company cannot unilaterally exempt certain verticals or parts of the business. Additionally, the opt-out methods must meaningfully allow consumers to opt out of data sharing/selling. Webforms, Global Privacy Controls, and other opt-out methods must be checked regularly to ensure functionality. The regulators have been quick to act where those methods do not work as expected.
• Regulators expect low-friction user experience—and will treat friction as a compliance risk. Both CalPrivacy and the AG have focused on the specific opt-out mechanisms for data collection or data selling/sharing, targeting companies that appear to have made it difficult or impossible to opt out of data sharing/selling and still use mobile apps. For example, the regulators have looked unfavorably on cookie banners that cover critical website functions and that must be accepted before the consumer can use the website. This is especially the case where the user must accept cookies, rather than choosing whether to accept or reject cookies. And on the topic of cookie banners, companies should consider evaluating their cookie banners to ensure symmetry of choice for both allowing and rejecting cookies.
• Youth and sensitive-context data remain high priority. CalPrivacy noted in its announcement of the PlayOn decision that students are “uniquely vulnerable,” and any websites they use should not “fuel advertising and commercial surveillance” at the expense of enhancing their educational opportunities. Similarly, the AG has cracked down on companies allegedly selling children’s information as well as disseminating sensitive consumer health information. Companies should consider reviewing their data collection practices to determine whether they collect, share or sell these types of data, and if so, evaluate whether proper disclosures are in place.

Your Key Next Steps

• Audit your opt-out functionality across all web, mobile, and platform integrations and ensure a consistent and defensible approach. The opt-out process should be straightforward and streamlined.
• Inventory service provider / contractor / third-party contracts for required restrictions and flow-down obligations—especially in advertising and analytics. The regulators continue to monitor the adequacy of the contracts governing these relationships.
• Reassess youth and student-data touchpoints, including age-gating logic, opt-in mechanisms, SDK behavior, retention, and security controls.
• Evaluate data broker status (including “custom audience” and profiling services) and confirm registration/fees where required. Additionally, prepare for an influx of delete request and opt-out platform (DROP) requests. DROP was released to the public in January, and data brokers must begin deleting data within 90 days, starting August 1, 2026.
• Don’t forget about applicant/HR privacy. Because employees and job applicants are covered by the CCPA, take time to review or revise notices and rights processes for those individuals.