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.
Blank Rome partner Jeffrey N. Rosenthal, along with professionals at Baker Botts, Carter Ledyard & Milburn, and Haynes Boone, examine the circumstances surrounding the settlement, offers four biometric law compliance considerations, and discusses regulatory and litigation risk factors highlighted by the case.
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"Texas AG’s Billion-Dollar Settlement With Google Highlights Biometric Data Use Compliance Considerations," by Matt Fleischer-Black was published in the Cybersecurity Law Report on May 21, 2025.