John  C. Gray, CIPP/US

John C. Gray, CIPP/US

Of Counsel vCard
201 East Washington Street
Suite 1200
Phoenix, AZ 85004

John Gray is Of Counsel in the firm’s Litigation practice group.

As a Certified Information Privacy Professional, John focuses on data privacy and cybersecurity, but his experience is wide ranging. He has litigated well over 100 matters to final resolution, including financial-services, investment-management, insurance, securities, consumer-fraud, labor-and-employment, intellectual-property, antitrust, healthcare, and construction disputes. In those matters, John has represented various financial institutions and clients in numerous other industries and sectors, including tech, retail, manufacturing, government, energy, tourism, and education.

John began his legal career at an international law firm in Los Angeles and later worked in the Consumer Protection & Advocacy Section of the Arizona Attorney General’s Office, where he served as Sr. Litigation Counsel, Data-Privacy Team Leader, and FinTech Sandbox Counsel. In 2019, he also co-chaired the Technology Futures Subgroup of the Arizona Cybersecurity Team, working with commercial, academic, government, and community leaders to assess cybersecurity threats and opportunities associated with new and emerging technologies.

Memberships & Affiliations

  • International Association of Privacy Professionals

Representative Matters

  • Led 32-state consumer-protection investigation against global tech company, involving hundreds of millions of dollars at issue.
  • Served on executive committee for first-ever multi-state HIPAA data-breach enforcement action by state attorneys general.
  • 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.
  • Represented international defense contractor in litigation brought by parts supplier, resulting in complete defense verdict at trial.
  • Represented financial advisor in FINRA arbitration and related litigation brought by former NFL athlete, resulting in dismissal of all claims against client in both actions.
  • Obtained summary judgment in favor of Fortune 50 retailer in individual wrongful-termination litigation; obtained denial of class certification for related rest-break claims; and obtained favorable class settlement of related overtime claims.
  • Represented international tech manufacturer in patent litigation brought against primary competitor, resulting in favorable settlement for client.
  • 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.


  • 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 2019, March 2019
  • Panelist, "Bridging the Expertise Gap between Technologists and State AGs," 2019 AGTech Forum, Berkman Klein Center for Internet & 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


  • 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.

Other Info


J.D., University of Southern California, Gould School of Law, 2009
B.S., magna cum laude, Arizona State University, 2006

Bar Admissions

Arizona, 2011
California, 2009, currently inactive

Court Admissions

U.S. District Court, District of Arizona
U.S. District Court, Central District of California
U.S. District Court, Eastern District of California
U.S. District Court, Northern District of California
U.S. District Court, Southern District of California