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Filings under California’s Private Attorneys General Act (“PAGA”) hit an all-time high in 2023, with 7,780 PAGA notices filed with the California Department of Industrial Relations. As an attempt to rein in the tidal wave of PAGA litigation, the California legislature and Governor Newsom enacted employer-friendly amendments to PAGA amid the looming threat of a November 2024 ballot initiative that, if approved, would have largely repealed PAGA.