On October 19, the European Court of Justice ("ECJ") issued a decision recognizing that a website visitor's dynamic internet protocol ("IP") address constitutes personal data, as long as a website operator can obtain from an internet access provider additional information enabling the operator to identify the visitor. Previously, the ECJ held that IP addresses constituted personal data only with respect to internet access providers, which, unlike website operators, have access to both IP addresses and additional information enabling the identification of individuals.
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