California has the most comprehensive regulatory framework for online K-12 schools in the nation. Between SOPIPA (student privacy), the Auto-Renewal Law (ARL), CCPA/CPRA (general privacy applied to minors), CLRA (consumer protection), and two-party recording consent, California online schools face more compliance requirements than any other state. If you have even ONE student in California, many of these laws apply.
This guide covers every California-specific law that affects how you enroll families, bill for services, collect student data, record classes, and market your school. Each section includes the statutory citation, practical implications, and specific compliance steps. This is not a summary of federal law -- this is what California adds on top of everything else.
Every private school in California -- including online schools that serve California students -- must comply with the Private School Affidavit requirement. This is the foundational regulatory step that establishes your school's legal existence in the state.
Under California Education Code Section 33190, every private school in the state must file a Private School Affidavit (PSA) with the California Superintendent of Public Instruction. This is an annual filing requirement, not a one-time registration. The filing window is October 1 through October 15 each year, and missing this window means your school is not legally recognized as a private school in California for that academic year.
What Must Be Filed
The Private School Affidavit requires the following information:
- School name and physical address - A mailing address alone is not sufficient; you need a physical location on file
- Names and addresses of school directors or principal - The individuals responsible for the school's operation
- Current enrollment numbers - Total students broken down by grade level
- Grade levels offered - Kindergarten through 12th grade, as applicable
- Whether instruction is conducted in English - Required for all California private schools
- Criminal record statement - Whether the school has obtained criminal background clearances for employees
Required Subjects
While California does not require curriculum approval for private schools, you must teach in the required subject areas as specified in California Education Code Section 51210 and 51220:
- English language arts - Including reading, writing, listening, and speaking
- Mathematics - Appropriate to grade level
- Social studies - Including history, geography, and civics
- Science - Including physical, life, and earth sciences
- Health education - Age-appropriate health instruction
- Physical education - Must be included even for online schools
- Fine arts - Visual and performing arts instruction
Teacher Requirements
California Education Code Section 48222 requires that private school instruction be provided by "persons capable of teaching." This is notably less restrictive than the state certification required for public school teachers. California does not require private school teachers to hold state teaching credentials. However, if you market your teachers as "certified" or "credentialed," you must be able to substantiate those claims.
Online School Considerations
If your online school is incorporated or headquartered outside California but enrolls California students, the PSA requirement still applies if you wish to be recognized as a legitimate private school option for California families. Without a PSA on file, parents who withdraw their children from public school to enroll with you may face truancy enforcement, because your school is not in the state's private school database.
Failure to file the Private School Affidavit means your school is not legally recognized as a private school in California. California families enrolled in your school may be considered truant, because the state has no record of their enrollment in a recognized private school. This can result in truancy letters, investigations, and significant problems for the families you serve.
The PSA is filed online through the California Department of Education's Private School Affidavit portal. The filing window is strictly October 1-15 each year. Late filings may be accepted but will show a late filing date, which may raise questions from parents and local education agencies. Set a calendar reminder for September to prepare your affidavit data.
SOPIPA is California's dedicated student privacy law, and it often imposes stricter requirements than federal COPPA in educational contexts. If your platform is used for K-12 school purposes, SOPIPA applies regardless of where your company is based.
The Student Online Personal Information Protection Act (SOPIPA), codified at California Business and Professions Code Section 22584 et seq., was enacted in 2014 and became effective January 1, 2016. It regulates the operators of websites, online services, and applications that are used primarily for K-12 school purposes. SOPIPA was designed to address concerns about EdTech companies collecting and monetizing student data.
Who Is an "Operator" Under SOPIPA?
SOPIPA defines "operator" broadly as any person or entity that operates a website, online service, online application, or mobile application with actual knowledge that the site or service is used primarily for K-12 school purposes and was designed and marketed for K-12 school purposes. For an online K-12 school, this definition clearly applies to:
- Your Learning Management System (LMS) - Whether you built it or use a third-party platform like Canvas, Google Classroom, or a custom system
- Your video conferencing platform - Zoom, Google Meet, or any tool used for live classes
- Assessment and testing tools - Online quizzes, homework platforms, standardized test prep tools
- Communication platforms - Parent portals, messaging systems, student collaboration tools
- Any EdTech vendor you use - Reading programs, math platforms, science simulations, etc.
What SOPIPA Prohibits
Operators of K-12 school purpose websites and services are prohibited from:
- Targeted advertising - You cannot use student data (including data collected through the educational service) to target advertising to students or their parents
- Building non-educational profiles - You cannot use student information to create a profile about the student for non-educational purposes (marketing, advertising, selling)
- Selling student information - You cannot sell student personal information to third parties under any circumstances
- Using data for non-educational commercial purposes - Data collected through the educational service cannot be used to further commercial interests unrelated to education
What SOPIPA Requires
- Reasonable security procedures - You must implement and maintain reasonable security procedures and practices appropriate to the nature of the student information you hold
- Data deletion on request - When a school or school district requests deletion of student data under its control, you must delete the data within a commercially reasonable time
- Transparency - You must disclose what student information you collect and how you use it
SOPIPA is often MORE restrictive than COPPA in educational contexts. COPPA focuses on parental consent for data collection from children under 13. SOPIPA prohibits certain uses of student data regardless of age or consent. Even if you have parental consent under COPPA to collect a 10-year-old's data, SOPIPA still prohibits you from using that data for targeted advertising. The two laws work together, but SOPIPA adds an additional layer of restriction specific to educational data.
SOPIPA Compliance Table: What You Can and Cannot Do
| Activity | Allowed Under SOPIPA? | Notes |
|---|---|---|
| Use student data to improve educational services | YES | Core educational purpose is permitted |
| Use student data for adaptive learning / personalization | YES | Educational personalization is allowed |
| Share student data with school administrators | YES | Legitimate school operations |
| Use student data for targeted advertising | NO | Explicitly prohibited |
| Sell student personal information | NO | Explicitly prohibited, no exceptions |
| Build non-educational marketing profiles | NO | Cannot profile students for commercial use |
| Share de-identified/aggregated data for research | YES | Must be truly de-identified, not re-identifiable |
| Use student data for third-party marketing | NO | Cannot share with marketers regardless of consent |
| Retain data after school requests deletion | NO | Must delete within commercially reasonable time |
Practical Steps for Online Schools
- Audit your data flows - Map exactly what student data you collect, where it goes, and who has access
- Review all EdTech vendor contracts - Ensure your vendors are SOPIPA-compliant and have contractual obligations to comply
- Disable advertising features - If your LMS or any tool has advertising capabilities, disable them for student-facing surfaces
- Establish a deletion process - Have a documented procedure for deleting student data when requested
- Update your privacy policy - Explicitly address SOPIPA compliance and student data protections
The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), applies to businesses that meet certain thresholds. When your online school handles data from minors, the stakes and penalties increase substantially.
The CCPA/CPRA applies to for-profit businesses that collect California consumers' personal information and meet one or more of the following thresholds:
- Annual gross revenue exceeding $25 million in the preceding calendar year
- Buy, sell, or share personal information of 100,000 or more consumers, households, or devices annually
- Derive 50% or more of annual revenue from selling or sharing consumers' personal information
Many online K-12 schools may not meet these thresholds individually. However, if you are part of a larger corporate family, affiliates' revenue and data may be aggregated. Additionally, if your school is growing rapidly, you should plan for when you will cross these thresholds.
Special Rules for Minors Under 16
The CCPA/CPRA creates heightened protections for minors that are particularly relevant to online schools:
- Children under 13 - A parent or guardian must affirmatively authorize (opt IN to) the sale or sharing of the child's personal information. The default is no sale or sharing.
- Consumers aged 13-15 - The consumer themselves must affirmatively authorize (opt IN to) the sale or sharing of their personal information. Again, the default is no sale or sharing.
- All adults (16+) - Standard opt-OUT right applies. Consumers can request that you stop selling or sharing their data.
For an online K-12 school, this means that for virtually all of your student body (typically ages 5-18), you cannot sell or share personal information without affirmative opt-in consent from either the parent (under 13) or the student (13-15).
California Privacy Protection Agency (CPPA)
The CPRA established the California Privacy Protection Agency, a dedicated enforcement body with rulemaking and enforcement authority over CCPA/CPRA. This is the first state-level privacy enforcement agency in the United States. The CPPA has the power to:
- Investigate complaints and conduct audits
- Issue regulations interpreting the CCPA/CPRA
- Bring enforcement actions with administrative fines
- Coordinate with the California Attorney General on enforcement
Penalties
- $2,500 per unintentional violation
- $7,500 per intentional violation
- $7,500 per violation involving a minor's data - Every violation involving data of a consumer under 16 is treated as intentional
CCPA fines are calculated PER VIOLATION, PER CONSUMER. If you improperly share data of 500 students, that is potentially 500 separate violations at $7,500 each = $3.75 million. The California Privacy Protection Agency has signaled that enforcement actions involving children's data will be a priority. Do not assume your school is too small to attract attention.
Practical Implications for Online Schools
- Do not sell student data - This should be obvious, but "sale" under CCPA is defined broadly and may include sharing data with third-party analytics or advertising platforms
- Review all third-party data sharing - Any transfer of personal information to a third party for monetary or other valuable consideration may constitute a "sale" under CCPA
- Privacy policy requirements - Your privacy policy must disclose categories of personal information collected, purposes, and third parties with whom information is shared
- Data subject access requests - Parents (on behalf of minors) can request to know what data you have, request deletion, and opt out of data sharing
- "Do Not Sell or Share" link - If applicable, your website must include a clear link titled "Do Not Sell or Share My Personal Information"
The CLRA is one of California's most powerful consumer protection statutes. It applies to enrollment agreements, tuition billing, and marketing of educational services. Unlike many consumer protection laws, it provides a private right of action -- meaning parents can sue your school directly.
The Consumers Legal Remedies Act (CLRA), codified at California Civil Code Section 1750 et seq., is a broad consumer protection law that covers transactions involving the sale or lease of goods or services to consumers. Enrollment in an online K-12 school is a consumer transaction for educational services, squarely within the CLRA's scope.
Prohibited Practices Under CLRA
Section 1770 of the CLRA lists 27 categories of prohibited unfair or deceptive practices. The ones most relevant to online schools include:
- Misrepresenting the quality or benefits of services - Overstating what your school provides (e.g., "guaranteed college placement," "certified teachers" when teachers lack certification)
- Representing that services have characteristics they do not have - Claiming accreditation you do not hold, or claiming curriculum aligns with standards when it does not
- Advertising services with intent not to sell them as advertised - Classic bait-and-switch: marketing one program but enrolling families in something different
- Making false or misleading statements about the need for services - Creating artificial urgency ("only 3 spots left!") when that is not true
- Inserting unconscionable provisions in a contract - Contract terms that are so one-sided as to be oppressive (e.g., no refunds under any circumstances, mandatory arbitration with excessive fees)
Remedies Available to Consumers
The CLRA provides significant remedies that make it a powerful tool for aggrieved parents:
- Actual damages - Whatever the parent lost financially
- Statutory damages - Up to $2,500 per violation in class actions
- Injunctive relief - Court order requiring the school to change its practices
- Attorney's fees and costs - The prevailing consumer recovers legal fees, making it economically viable for attorneys to take these cases
- Punitive damages - Available in cases involving willful or knowing violations
The 30-Day Demand Letter Requirement
Before filing a CLRA lawsuit for damages, the consumer must send a demand letter giving the business 30 days to correct the alleged violation. This is a procedural prerequisite, not optional. However, this requirement does NOT apply to claims for injunctive relief. Practically, this means:
- If you receive a CLRA demand letter, take it seriously - You have 30 days to offer an appropriate correction/remedy
- A good-faith correction may limit your exposure - If you adequately address the complaint within 30 days, it limits the damages the consumer can pursue
- Ignoring a demand letter is extremely risky - After 30 days, the consumer can file suit with full damages, attorney fees, and potentially punitive damages
Common Online School Claims vs. CLRA Risk
| Marketing/Contract Claim | CLRA Risk Level | Why |
|---|---|---|
| "Accredited school" (without naming accreditor) | HIGH | Misrepresentation of characteristics |
| "Our graduates get into top colleges" | HIGH | Unsubstantiated outcome claims |
| "Credits transfer to any school" | HIGH | False representation - transfer is up to receiving school |
| "Small class sizes of 10-15 students" | MEDIUM | Must be accurate; if classes regularly exceed stated sizes, it is a misrepresentation |
| "All teachers hold advanced degrees" | MEDIUM | Must be verifiable for every teacher |
| "Personalized learning experience" | LOW | Vague enough to be defensible, but must have some substance |
| "WASC-accredited" (when actually WASC-accredited) | LOW | Truthful, specific, verifiable |
Review every claim on your website, enrollment materials, and advertisements against the CLRA's prohibited practices list. If you cannot substantiate a claim with documentation, remove it. The attorney's fees provision in the CLRA means that even a single parent with a valid complaint can afford to hire a lawyer, because you will pay their legal fees if they win.
California's Auto-Renewal Law is THE strictest in the United States. If your online school uses any form of recurring billing -- monthly tuition, semester auto-renewal, annual subscription -- the ARL applies with full force. Non-compliance does not just result in fines; it makes your entire contract void and unenforceable.
California Business and Professions Code Sections 17600-17606 impose strict requirements on any business that makes an "automatic renewal" or "continuous service" offer to a consumer in California. An "automatic renewal" includes any plan or arrangement where a paid subscription or purchasing agreement renews at the end of a definite term. A "continuous service" includes any plan or arrangement where a paid subscription or purchasing agreement continues until the consumer cancels. Both definitions clearly apply to tuition billing for online schools.
Disclosure Requirements (BEFORE Initial Payment)
Before a California consumer (parent/guardian) provides payment information, you must present the auto-renewal terms in a manner that is "clear and conspicuous." The disclosures must include:
- The automatic renewal offer terms - That the subscription will automatically renew unless the consumer cancels
- The cancellation policy - Exactly how to cancel, in clear language
- The recurring charge amount - The exact dollar amount that will be charged at each renewal
- The renewal frequency - Monthly, quarterly, per semester, annually, etc.
- The length of each renewal term - If the renewal is for a semester, state that; if month-to-month, state that
- The minimum purchase obligation, if any - If the consumer commits to a minimum term, disclose it
Separate Affirmative Consent
You must obtain the consumer's "affirmative consent" to the automatic renewal terms. This means:
- A separate checkbox or consent mechanism - Not buried in general terms of service
- The checkbox must NOT be pre-checked - The consumer must actively select it
- The consent must be specific to auto-renewal - General agreement to terms of service is not sufficient
- The auto-renewal terms must be displayed in proximity to the consent - The consumer should be able to read the terms and provide consent without scrolling or navigating away
Acknowledgment/Receipt
After the consumer enrolls, you must provide a written acknowledgment (email is acceptable) that includes:
- The auto-renewal terms
- The cancellation policy
- Information on how to cancel
- A mechanism to cancel (a link, email address, or other easy method)
Easy Online Cancellation
If the consumer enrolled or subscribed online, they must be able to cancel online. Specifically:
- A direct cancellation mechanism - A cancellation button, form, or clear process accessible through your website
- Cannot require phone calls - If enrollment was online, you cannot require calling to cancel
- Cannot require mailing written notice - If enrollment was online, cancellation must be available online
- Cannot add unnecessary steps or friction - Dark patterns that make cancellation difficult violate the ARL
The Regulatory Stack for Billing
This is the most severe consequence of any state auto-renewal law in the country. If you fail to comply with the ARL's disclosure, consent, or cancellation requirements, the automatic renewal or continuous service provision is considered an "unlawful business practice." The consumer can treat the entire contract as void and unenforceable, and demand a FULL REFUND of ALL payments made under the contract -- not just the renewal payments, but potentially the original enrollment payment too. This is not a theoretical risk: California courts have enforced this remedy.
- Auto-renewal terms are displayed clearly and conspicuously BEFORE the payment form
- A separate, unchecked checkbox specifically consents to auto-renewal terms
- The renewal amount, frequency, and cancellation policy are stated near the consent checkbox
- A confirmation email is sent after enrollment containing auto-renewal terms and cancellation instructions
- An online cancellation mechanism is available (button, form, or clearly accessible process)
- Cancellation is as easy as enrollment -- no extra steps, phone calls, or mailed letters required
- Cancellation takes effect within a reasonable time and a confirmation is sent
- If the renewal price will change, the consumer is notified before the new price takes effect
California is a two-party consent state for recording. This has major practical implications for online schools that record live classes, tutoring sessions, or parent-teacher conferences. Violations are both criminal and civil offenses.
California Penal Code Section 632 makes it a crime to record a "confidential communication" without the consent of ALL parties to the communication. Unlike one-party consent states (where only one participant needs to consent to recording), California requires that every person participating in the conversation agree to being recorded.
What Is a "Confidential Communication"?
A confidential communication is any communication carried on under circumstances that reasonably indicate that any party to the communication desires it to be confined to the parties. An online class with a small group of students where discussion occurs is almost certainly confidential. A large webinar-style broadcast where the audience is passive may be less clearly confidential, but the safest approach is to treat all live sessions as confidential communications.
Criminal Penalties
- Fine of up to $2,500 for each violation
- Imprisonment in county jail for up to one year (misdemeanor)
- For subsequent offenses, enhanced penalties may apply
Civil Liability
- $5,000 per violation in statutory damages - or three times actual damages, whichever is greater
- Attorney's fees and costs to the prevailing plaintiff
- Injunctive relief - court order to stop recording
Practical Guidance for Online Schools with California Students
If even ONE participant in a live class session is located in California, two-party consent applies to the entire recording. Here is how to handle this:
- Include recording consent in your enrollment agreement - Have parents/guardians sign a clause specifically consenting to recording of live class sessions, specifying the purposes (replay, review, quality assurance)
- Announce recording at the start of every class - State at the beginning of each recorded session: "This class is being recorded for [stated purposes]. By continuing to participate, you consent to the recording." This verbal notice serves as additional consent documentation.
- Provide a camera-off / audio-off option - If a family does not consent to recording, offer an alternative where the student can participate with camera and microphone off, or attend an unrecorded session
- Document all consents - Keep records of signed consent forms and class announcements
- Limit retention and access - State how long recordings will be kept and who can access them. Indefinite retention of recordings containing student images and voices raises both recording consent and COPPA concerns
Recording Scenarios and Consent Requirements
| Scenario | Consent Required? | Recommended Approach |
|---|---|---|
| Live class with CA student, cameras on | All parties | Enrollment agreement + class announcement |
| One-on-one tutoring with CA student | Both parties | Separate tutoring consent form |
| Parent-teacher conference (CA parent) | Both parties | Ask before starting recording |
| Pre-recorded lecture (no student participation) | Teacher only | Teacher employment agreement covers this |
| Student submits video assignment | Student/parent | Enrollment agreement covers student submissions |
In an online class with students from multiple states, you must comply with the strictest applicable law. If even one student is in California (or any other two-party consent state), you need all-party consent for the entire recording. The most practical solution is to build all-party consent into your standard enrollment agreement and class announcement procedures, regardless of which states your students are in.
California online schools are subject to oversight from multiple state and federal agencies. Understanding which agency enforces which law helps you prioritize compliance efforts and respond appropriately to inquiries.
| Agency | Jurisdiction | Key Laws Enforced | Typical Trigger |
|---|---|---|---|
| CA Superintendent of Public Instruction | Private school registration | Ed. Code § 33190 (Private School Affidavit) | Annual filing review, parent complaint about school legitimacy |
| California Attorney General | Consumer protection, auto-renewal, general enforcement | CLRA, ARL, UCL (Bus. & Prof. Code § 17200), general consumer protection | Consumer complaints, pattern of complaints, AG sweep of industry |
| California Privacy Protection Agency (CPPA) | Privacy enforcement for CCPA/CPRA | CCPA/CPRA, including minor-specific provisions | Consumer privacy complaints, data breach notification, targeted audits |
| Federal Trade Commission (FTC) | Federal consumer protection and children's privacy | COPPA, ROSCA, FTC Act Section 5 (deceptive practices) | Consumer complaints, industry sweeps, competitor reports, media coverage |
California AG Enforcement Priorities
The California Attorney General's office has been particularly active in enforcing consumer protection laws against educational services and technology companies. Areas of focus include:
- Auto-renewal law violations - The AG has brought multiple enforcement actions against subscription services that failed to comply with ARL disclosure and cancellation requirements
- Student data privacy - The AG has taken interest in how EdTech companies handle student data, particularly regarding SOPIPA compliance
- Deceptive advertising - Claims about educational outcomes, accreditation, and program quality that cannot be substantiated
- Dark patterns - Practices that make it difficult for consumers to cancel subscriptions or exercise their rights
What to Do If You Receive a Regulatory Inquiry
- Do not ignore it - Regulatory inquiries escalate when ignored
- Consult legal counsel immediately - Before responding to any agency inquiry, speak with an attorney experienced in the relevant area
- Preserve all documents - Once you receive an inquiry, you have a legal obligation to preserve relevant documents and communications
- Respond within the stated deadline - Most regulatory inquiries include a response deadline; missing it signals non-cooperation
- Be truthful - Providing false information to a regulatory agency is a separate and serious offense
- Enrollment agreement review
- CLRA risk assessment
- ARL disclosure review
- Refund policy analysis
- Written red flag report
- Recommended revisions
- All documents reviewed
- SOPIPA compliance assessment
- CCPA/CPRA gap analysis
- ARL billing flow review
- CLRA marketing audit
- Recording consent review
- PSA filing verification
- 30-min strategy call
- Custom CA privacy policy
- SOPIPA compliance program
- CCPA/CPRA implementation
- Parental consent forms
- Recording consent system
- Vendor data agreements
- Implementation guidance
SOPIPA (Student Online Personal Information Protection Act) is California's dedicated student privacy law, codified at Cal. Bus. & Prof. Code Section 22584 et seq. It applies to operators of websites, online services, and applications that are used primarily for K-12 school purposes. If you run an online K-12 school, SOPIPA applies to your LMS, video platform, assessment tools, and any other technology used for educational purposes. SOPIPA prohibits using student data for targeted advertising, building non-educational profiles, and selling student information -- regardless of whether you have parental consent for other purposes. It is often more restrictive than federal COPPA in educational contexts.
Yes, if you operate a private school that serves California students. Under California Education Code Section 33190, every private school must file a Private School Affidavit (PSA) annually with the California Superintendent of Public Instruction. The filing window is October 1-15 each year. This applies to online schools that enroll California students, even if the school is headquartered in another state. Without a PSA on file, your school is not recognized as a legitimate private school in California, and your California families may face truancy enforcement because the state has no record of their enrollment in a recognized school.
California's Auto-Renewal Law (Cal. Bus. & Prof. Code Section 17600 et seq.) is the strictest auto-renewal law in the United States. If your school bills on a recurring basis (monthly tuition, semester renewals, annual subscriptions), you must provide clear and conspicuous disclosure of renewal terms before the first payment, obtain separate affirmative consent specifically for auto-renewal (not just general terms agreement), send a post-purchase acknowledgment with renewal terms and cancellation instructions, and provide an easy online cancellation mechanism. The critical consequence: if you fail to comply, the entire contract is deemed void and unenforceable. The consumer can demand a full refund of ALL payments, not just the renewal charges.
The CCPA/CPRA applies to for-profit businesses that meet specific thresholds: annual revenue over $25 million, or data on 100,000+ consumers, or 50%+ revenue from selling personal data. Many smaller online schools may not meet these thresholds individually, but if you are part of a larger corporate group, affiliated entities' revenue may be aggregated. Even if CCPA does not directly apply to you today, the special rules for minors are important to understand: for children under 13, parents must opt IN before any sale or sharing of data, and for teens 13-15, the teen must opt in. Fines are $7,500 per violation involving minors. Plan for compliance before you reach these thresholds.
Yes. Under California Penal Code Section 632, California is a two-party consent state, meaning ALL parties to a confidential communication must consent to the recording. For an online school, this means every participant in a recorded class -- every student, every teacher, every aide -- must consent. Penalties include criminal fines of up to $2,500 and/or imprisonment of up to one year, plus civil damages of $5,000 per violation (or three times actual damages, whichever is greater). If even one student in your class is located in California, you need all-party consent for the recording. Include recording consent in your enrollment agreement and announce recording at the start of each class.
The Consumers Legal Remedies Act (CLRA), Cal. Civ. Code Section 1750 et seq., is one of California's broadest consumer protection statutes. It covers all consumer transactions, including enrollment agreements for educational services. The CLRA prohibits 27 categories of unfair and deceptive practices, including misrepresenting the quality or benefits of services, bait-and-switch tactics, and unconscionable contract terms. What makes the CLRA particularly dangerous for online schools is the private right of action: any parent can sue your school for CLRA violations and recover actual damages, statutory damages (up to $2,500 per violation), attorney's fees, and injunctive relief. The attorney's fees provision makes it economically viable for lawyers to take even small individual cases.
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