News & Events

Today, Feb. 20, 2026, the Supreme Court of the United States (SCOTUS) issued its much-anticipated decision in the Learning Resources, Inc. v. Trump case, which consolidated the title case and V.O.S. Selections v. Trump, resolving whether the International Emergency Economic Powers Act (IEEPA) authorizes the President to impose the challenged import tariffs.

In the prior two alerts in this series, we explained that California (along with 16 other states) now requires businesses to conduct privacy risk assessments in certain circumstances where consumer privacy may face heightened risk. Our second alert outlined the key threshold questions—WHERE, WHEN, and WHAT—that trigger this obligation. In this alert, we turn to the central issue: how to prepare and structure a privacy risk assessment that meets regulatory expectations while minimizing legal exposure.