01. Excessive verification for opt-outs
Honda required information beyond what CCPA allows just to honor a Do Not Sell or opt-out request.
California's $632,500 Honda settlement focused on dark patterns: opt-out flows that asked for more information than CCPA allows, mishandled authorized agent requests, and friction that the AG described as designed to discourage exercising rights.
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Technical failure modes
Honda required information beyond what CCPA allows just to honor a Do Not Sell or opt-out request.
Valid authorized-agent requests were refused or routed back to the consumer for direct verification.
Opt-in was a single click while opt-out required navigating a multi-step flow — a textbook dark pattern.
The cookie consent UI did not clearly surface the CCPA right to limit sale or sharing.
Remediation path
More enforcement analysis
Next step
Honda is the dark-patterns case. The AG made it clear that requiring extra information to opt out, refusing authorized agent requests, and burying the opt-out link are all forms of consumer-facing friction that violate CCPA — even when the underlying data flows are otherwise legitimate.
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