John Gray is the Chair of Womble Bond Dickinson’s Privacy, Cybersecurity, and AI Litigation Team. He also serves on the firm’s Editorial Board, Innovation Board, and AI Committee.
As a litigator, John has more than 15 years of experience in California, Arizona, and other forums across the nation. He has handled a wide range of cases and has litigated hundreds of matters to final resolution, including numerous class actions, various other complex commercial cases, bet-the-company disputes, and appeals. As detailed below, John’s primary area of focus is data privacy and cybersecurity, but he also represents clients in other types of disputes and in a number of industry sectors.
Data Privacy and Cybersecurity
As Chair of the Privacy, Cybersecurity, and AI Litigation Team, John represents clients in various regulatory investigations, class actions, and arbitration matters relating to privacy or data-protection issues, including claims under the California Consumer Privacy Act (CCPA) and the California Invasion of Privacy Act (CIPA). He also regularly advises clients on CIPA risk mitigation and compliance with the CCPA and various other laws and regulations pertaining to data privacy and protection.
Before joining the firm, John worked in the Consumer Protection and Advocacy Section of the Arizona Attorney General’s Office, where he served as data privacy team leader, fintech sandbox counsel, and senior litigation counsel. As data privacy team leader, John was responsible for dozens of data privacy investigations and litigation matters, many of which involved millions of data subjects and tens or hundreds of millions of dollars at issue. He also drafted significant portions of Arizona’s updated data breach notification law and new virtual coin offering law in 2018, and he led a group of more than 80 lawyers from more than 25 states and territories in the training and certification process to become Certified Information Privacy Professionals with the International Association of Privacy Professionals.
As a Certified Information Privacy Professional and a member of the Sedona Conference Working Group on Data Security and Privacy Liability, John has spoken and written extensively about privacy and security issues. In 2019, he also served as co-chair of the Technology Futures Subgroup of the Arizona Cybersecurity Team, where he worked with commercial, academic, government, and community leaders to assess cybersecurity threats and opportunities associated with new and emerging technologies.
Government Investigations and Consumer-Protection Actions
As former senior litigation counsel with the Arizona Attorney General’s Office, John has significant experience in government investigations and litigation actions relating to alleged consumer fraud or unfair, deceptive, and abusive acts and practices (UDAP) claims, and he has a keen understanding of both the procedural and substantive issues involved in such matters. Indeed, John led one of the largest multistate consumer-protection investigations in recent years, and he served on several other executive committees for multistate investigations and cases involving hundreds of millions or billions of dollars at issue.
Since returning to private practice in 2020, John has regularly represented businesses subject to government investigations across the country and has litigated numerous class actions, in state and federal courts, alleging various consumer-protection claims. In such matters, clients trust not only John’s legal acumen and litigation skills but also his judgment and understanding of the significant operational implications, including government and regulatory affairs, public relations, and business continuity.
Appeals
John has represented clients in appellate matters throughout the country. In those matters, John has briefed appeals before the Ninth Circuit Court of Appeals, the California Court of Appeal, the Nevada Supreme Court, and the New York Supreme Court, Appellate Division. He has also briefed and argued several cases before the Arizona Supreme Court and Arizona Court of Appeals. While in law school, John honed his appellate writing and advocacy skills serving as a Legal Research, Writing, and Advocacy Fellow and studying under former Ninth Circuit Judge Paul J. Watford.
Labor and Employment Disputes
John represents employers in various industries and has defended clients against claims relating to the federal Fair Labor Standards Act (FLSA), overtime, meal breaks, rest breaks, wage statements, waiting time penalties, discrimination, retaliation, harassment, eavesdropping, wrongful termination, off-the-clock work, rounding, alternative workweeks, and the California Private Attorney General Act (PAGA). In particular, John has extensive experience litigating employment matters in California state and federal courts, including both class actions and individual matters. John has also advised clients regarding employee handbooks, potential terminations, and severance agreements; he has litigated trade-secret, confidentiality, and non-compete claims involving former employees and contractors; and he has handled internal investigations under Title VII and the California Fair Employment and Housing Act.
Representative Matters
Any result the lawyer or law firm may have achieved on behalf of clients in other matters does not necessarily indicate similar results can be obtained for other clients
- Representing retail service provider in multiple state attorney general investigations involving hundreds of thousands of consumers.
- Defending consumer-services company in several class actions filed in state and federal courts alleging various consumer-protection claims.
- Defending clients against putative collective-action and class-action employment claims under the FLSA and New York, Florida, and Arizona law.
- Representing online retailer in arbitration proceedings involving privacy claims under CIPA and related causes of action.
- Representing nationwide door-to-door-sales and pest-control company in numerous litigation matters, including claims against former contractors for misappropriation of trade secrets and related data-protection claims.
- Advising numerous clients regarding compliance with CCPA and various other privacy laws and regulations.
- Handled several nationwide cybersecurity incident response matters in connection with ransomware events and attacks against vendors.
- Served as local counsel to Fortune 500 healthcare company in multiple putative class actions regarding alleged data breaches.
- Settled numerous CIPA and related privacy claims for less than nuisance value.
- Obtained order dismissing, on the pleadings, claims against fintech and cryptocurrency relating to purchase of internet domain.
- Served as local counsel to multiple publicly listed entities and related financial institutions in securities class actions filed in both state and federal courts.
- Defended state agency against constitutional claims seeking to invalidate agency’s enforcement statute.
- Represented multiple Fortune 500 companies in confidential state attorney general investigations.
- Obtained order vacating multimillion-dollar arbitration award fraudulently issued against national hotel organization.
- Led 32-state consumer protection investigation against global tech company involving hundreds of millions of dollars at issue.
- Recovered millions of dollars for State of Arizona and residents in consumer protection and data privacy investigations and litigation.
- Drafted Arizona data breach notification law and virtual coin offering law.
- Obtained favorable settlement for Fortune 50 retailer in purported consumer fraud class action after plaintiff’s first amended complaint was dismissed.
- Obtained favorable settlement on eve of trial for auto parts manufacturer in bet-the-company litigation brought by former private equity investors.
- Represented mortgage trustee in series of cases alleging “wrongful foreclosure”; obtained dismissal on the pleadings in more than a dozen cases, with others settled for less than nuisance value.
Professional & Civic Engagement
- International Association of Privacy Professionals
- Sedona Conference, Working Group 11
Thought Leadership
- "States Turn to Outside Firms to Generate Big Privacy Settlements," Quoted, Bloomberg Law, October 9, 2025
- Speaker, "The Ever-Evolving Landscape: Key Developments in Data Privacy, Cybersecurity, and AI Law," AZ Last Chance CLE, June 25, 2025
- Speaker, “From Data to Decisions: Navigating Privacy and Litigation Risks in the AI Era,” Womble Bond Dickinson’s AI Intensive: Playbook for Innovation and Risk Mitigation Virtual Summit, May 20, 2025
- Drafting Team Leader and Panelist, “Individual Liability for Data Security Failures,” The Sedona Conference, Working Group 11 Annual Meeting, May 7, 2025
- Guest Lecturer, “Privacy and AI,” Sandra Day O'Connor College of Law at Arizona State University, February 19, 2025
- Speaker, "Generative AI and Legal Ethics: I’m Afraid I Can’t Do That," AZ Last Chance CLE, June 27, 2024
- Commentary on U.S. Sanctions-Related Risks for Ransomware Payments, 25 SEDONA CONF. J. 617 (2024), The Sedona Conference
- States, Wild Cards & Time: Hurdles Facing Privacy Law Push, Quoted, Law360, April 10, 2024
- Lender Wins $44M Award In Shanghai Real Estate Feud, Mentioned, Law360, March 25, 2024
- Shopify Ruling May Support Personal-Jurisdiction Defenses, Co-Author, Law360, January 3, 2024
- Speaker, "Recent Developments in Data-Privacy and Cybersecurity Law," AZ Last Chance CLE, June 29, 2023
- Speaker and Host of Bay Area Chapter, CISO Executive Network, 2022-2024
- Speaker, "Recent Developments in Data-Privacy and Cybersecurity Law, AZ Last Chance CLE, June 28, 2022
- Speaker, “Legal Update,” CISO Executive Network Virtual Roundtable, September 2021
- Panelist, "Staying Ahead of Privacy Regulations - Cybersecurity Webinar," September 21, 2021
- Co-presenter, "The Threat Within: Addressing and Limiting Legal Risks Posed by Internal Cybersecurity and Data Privacy Vulnerabilities,” CLE Presentation, July 2021
- Remote Working and Data Protection: A Pandemic Year in Review, Phoenix Business Journal, June 23, 2021
- Speaker, “Legal Update,” CISO Executive Network Virtual Roundtable, May 2021
- Co-presenter, "Responding to Ransomware: Ethical Considerations and Implications,” CLE Presentation, April 2021
- Co-presenter, "Remote Working and Data Protection – A Pandemic Year in Review," CLE Presentation, April 27, 2021
- Invisible Risks: Insurance, Legal and Tech Professionals Can Limit Web Liability, San Fernando Valley Business Journal, April 12, 2021
- Co-moderator, “Cyber Legal Roundtable,” January 2021
- Co-presenter, “The Ethics of Ransomware Payments,” CLE Presentation, December 21, 2020
- Speaker, “CPRA Highlights,” CISO Executive Network Virtual Roundtable, December 2020
- Co-presenter, "2020 Ethics in Cybersecurity Virtual Event - Rule of Law," University of Colorado, Colorado Springs, November 2020
- Speaker, “Legal Update,” CISO Executive Network Virtual Roundtable, October 2020
- Speaker, “GDPR: Data Protection Officers,” CISO Executive Network Virtual Roundtable, April 2020
- Speaker, "USPQ Seminar - CCPA and Privacy by Design," CLE Presentation, February 2020
- Anti-Ransomware Strategies Must Evolve With Threat, Author, Law360, January 17, 2020
- Speaker and Host of Phoenix Chapter, CISO Executive Network, 2019-present
- Speaker, "CCPA and Privacy by Design," CISO Executive Network Breakfast Roundtable, December 2019
- Panelist, “The Impact of Emerging Legislation and Regulations on Practitioners’ Security/Privacy Considerations and Operations,” 2019 Cybersecurity Lunch Forum, Arizona Technology Council, December 2019
- Panelist, “How are regulators looking at protecting consumers in this new era?” Symantec CalPrivacyCon, March 2019
- Panelist, "Bridging the Expertise Gap between Technologists and State AGs," 2019 AGTech Forum, Berkman Klein Center for Internet and Society at Harvard University, February 2019
- Speaker, "HB2154, Arizona’s New Data Breach Notification Law," CLE Presentation, Office of the Arizona Attorney General, August 2018
Honors & Awards
- At the Arizona Attorney General's Office, John was recognized as the 2019 Civil Litigation Division Emerging Star.
- While in law school, John was selected as a first year summer fellow and as a legal research, writing, and advocacy fellow.
- Prior to law school, John graduated from the Barrett Honors College at Arizona State University, where he was recognized as the Finance Department's Outstanding Graduating Senior and was elected the inaugural president of the Undergraduate Investment Management Fund.
