John  C. Gray, CIPP/US

John C. Gray, CIPP/US

Of Counsel vCard
602.262.5331 AZ
201 East Washington Street
Suite 1200
Phoenix, AZ 85004
655 North Central Avenue
Suite 2300
Glendale, CA 91203

John Gray is Of Counsel in the firm’s Litigation practice group. With more than a decade of experience in Arizona, California, and other forums across the nation, John has handled a wide range of cases and litigated well over 100 matters to final resolution, including numerous class actions, various complex commercial cases, and bet-the-company disputes. In those matters, John has represented clients in a number of industry sectors, including financial services, tech, retail, manufacturing, national defense, energy, construction, tourism, entertainment, healthcare, education, and government. John’s practice, however, focuses on the four areas detailed below: cybersecurity and data privacy; labor and employment disputes; financial services and insurance disputes; and government investigations.

Cybersecurity and Data Privacy

John’s primary area of focus is cybersecurity and data privacy. In this field, John represents clients in cybersecurity and data-privacy investigations and litigation matters, including data-breach class actions. He also advises clients on compliance with the California Consumer Privacy Act (CCPA), the EU’s General Data Protection Regulation (GDPR), and various other laws and regulations pertaining to data privacy and protection.

Before joining the firm, John worked in the Consumer Protection & Advocacy Section of the Arizona Attorney General’s Office, where he served as Senior Litigation Counsel, FinTech Sandbox Counsel, and Data Privacy Team Leader. 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 attorneys 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.

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). Having begun his legal career with an international law firm in Los Angeles, John also has extensive experience litigating employment matters in California state and federal courts, including both putative class actions and individual matters.

In addition, John has advised clients regarding employee handbooks, potential terminations, and severance agreements; he has litigated trade-secret, confidentiality, and non-compete claims involving former employees; he has obtained temporary restraining orders against threatening former employees; he has litigated matters before the California Labor Commissioner; and he has handled internal investigations under Title VII and the California Fair Employment and Housing Act. 

Financial Services and Insurance Disputes

John represents financial institutions, insurance companies, and related parties in a variety of litigation and arbitration matters. In particular, he has extensive experience defending broker-dealers and investment advisors in arbitrations before the Financial Industry Regulatory Authority (FINRA), and he has successfully moved to compel such arbitration in multiple matters originally filed in state or federal courts. In addition, John has represented financial services and insurance clients in securities class actions, bankruptcy matters, probate and garnishment actions, actions to enforce judgments, and cases alleging fraudulent lending practices and/or wrongful foreclosure.

Government Investigations

As former Senior Litigation Counsel with the Arizona Attorney General’s Office, John has significant experience in government investigations relating to alleged consumer fraud or unfair, deceptive, and abusive acts and practices (UDAP) claims. At the Arizona Attorney General’s Office, John led one of the largest multi-state consumer-fraud investigations in recent years, and he served on several other executive committees for multi-state investigations involving hundreds of millions or billions of dollars at issue. He is therefore well-positioned to defend clients who may be under investigation by state or federal authorities, and he has a keen understanding of both the procedural and substantive issues involved in such matters.

Memberships & Affiliations

  • International Association of Privacy Professionals
  • Sedona Conference, Working Group 11

Representative Matters

  • Currently representing Fortune 500 healthcare company as local counsel in multiple putative class actions regarding alleged data breaches.
  • Representing group of underwriters as local counsel in securities class actions filed in both state and federal court.
  • Defending state agency against constitutional claims seeking, among things, to invalidate agency’s enforcement statute.
  • 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.
  • 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 (later reversed on appeal litigated by separate firm); obtained denial of class certification for related rest-break claims; and obtained favorable class settlement of related overtime claims.
  • 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.

Related News


  • Speaker, "USPQ Seminar - CCPA & Privacy by Design," CLE Presentation, Lewis Roca Rothgerber Christie LLP, February 2020
  • 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

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