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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