Recital 30 specifically calls out IP addresses: https://gdpr-info.eu/recitals/no-30/ https://gdpr-info.eu/recitals/no-30/ While the wording of the Recital leav

Recital 30 specifically calls out IP addresses: https://gdpr-info.eu/recitals/no-30/ https://gdpr-info.eu/recitals/no-30/ While the wording of the Recital leaves some ambiguity as to whether an IP is automatically Personal Data under the GDPR, its specific call-out would make arguing that it is not difficult. This would particularly be the interpretation of American lawyers, who tend to assume that no connection is too tenuous to be held against their client by a shrewd prosecutor or regulator and will thus advise their client to treat all IPs in all situations as Personal Data.