I hope everyone had a Happy Thanksgiving. Last week, the Court of Appeal (Fourth Appellate District, Division One) issued two more unpublished opinions on Prop. 64 retroactivity. Both are consistent with that Division's prior rulings. Privacy Rights Clearinghouse v. JetBlue Airways Corp., no. D045568 (Nov. 22, 2005); Bivens v. Gallery Corp., no. D045557 (Nov. 22, 2005). In a third case before that Division, the Prop. 64 retroactivity issue was raised but not decided. Gutierrez v. Nick Pecoraro Painting & Decorating, Inc., no. D044666 (Nov. 23, 2005).