The U.S. Department of Justice’s Bulk Sensitive Personal Data Rule (the “Bulk Rule”) represents one of the most significant regulatory developments in data privacy and national security in recent years. Designed to prevent foreign adversaries from accessing large volumes of Americans’ sensitive personal data, the Bulk Rule has introduced sweeping new restrictions on a range of data transactions. Since the Bulk Rule’s final provisions took effect in October 2025, its impact has been felt across industries, particularly among organizations with international operations or ties to designated countries of concern.
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Notably, the Bulk Rule has given rise to a growing wave of class action litigation, with plaintiffs leveraging the Electronic Communications Privacy Act (“ECPA”) to pursue claims against companies alleged to have transferred covered data to foreign entities. The most significant development since the Bulk Rule took effect is a rise of high-damage class action claims related to alleged violations of the Bulk Rule claim.
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