I don’t know why you’re being so pedantic:

- the conduct Lambda School engaged in became unlawful on Jan 1

- Lambda School continued engaging in that contact well-past Jan 1

- The state called them out and a settlement (favorable to CA) was quickly reached

It is far more likely that a settlement was reached because the conduct was clearly unlawful but not deeply damaging - so worth enforcing but not worth an ugly legal brawl.

I sincerely don’t know why you’re pretending Lambda was “actually trying to follow this new law” and insinuating there’s something suspicious about anything here - it is not an onerous regulation and Lambda had plenty of warning. Clearly they weren’t trying to follow the law! (probably more out of bad management than nefariousness)

Regardless: companies do not get an implicit grace period between when a law comes into force and when the company is actually required to obey it. In certain cases the law can be unconstitutionally coercive or unfair but obviously not here.

> Part of my point, that I did not make clear, is that this law came into effect January 1st. A 3 month turn-around between something becoming illegal, and a "settlement" being reached, feels awfully fast to me, and implies that everyone involved was actually trying to follow this new law.

Not really, I’d say it more implies:

(1) regulators were ready to start enforcement, at least of easy cases, on day 1 (unsurprising, as non-emergency laws in CA have a significant delay between passage and going into effect, both to prepare for enforcement and to give people subject to them sufficient notice to comply), and

(2) Lambda either didn’t want to comply or was lackadaisical (or they would have stopped before the law went into effect, since, again, there was notice) and

(3) the violation was open-and-shut leaving no room for denial, it was settle or lose for Lambda, with no upside for fighting.

The law passed in August. It took effect in January so businesses could fix violations before. And the practices were always deceptive.

Wouldn't someone truly "trying to follow the new law" have started following the law beginning from the date it's in effect? (Of course mistakes happen, and yes it is probably a sign that they weren't trying to fight it too much, but that's a low bar assuming it is legally clear)

That would make it sound like Lambda School did it proactively. It would obscure the claims were deceptive irrespective of California law. And it would obscure Lambda School acknowledged the claims were misleading.