Oracle America, Inc. recently has agreed to pay $115 million to settle a class action lawsuit in which it was accused of violating internet users’ privacy by surreptitiously employing tracking techniques to gather their data, and creating and sharing “dossiers” on them. As part of the settlement, Oracle has agreed not to capture certain website data and to implement auditing to ensure compliance with privacy duties. This article discusses, with insights from Proskauer partner Leslie A. Shanklin, key aspects of the litigation and settlement terms, and practical takeaways for the adtech industry. See our four-part series on tracking technologies: “Privacy Regulation, Enforcement and Risk” (Jan. 17, 2024), “A Deep Dive on What They Are and How They Work” (Jan. 31, 2024), “A 360‑Degree Governance Plan” (Feb. 21, 2024), and “Compliance Challenges and Solutions” (Apr. 17, 2024).