Callahan v. PeopleConnect Inc.

CourtDistrict Court, N.D. California
DecidedJune 14, 2022
Docket3:20-cv-09203
StatusUnknown

This text of Callahan v. PeopleConnect Inc. (Callahan v. PeopleConnect Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Callahan v. PeopleConnect Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MEREDITH CALLAHAN, et al., Case No. 20-cv-09203-EMC

8 Plaintiffs, ORDER DENYING DEFENDANT’S 9 v. MOTION FOR JUDGMENT ON THE PLEADINGS OR, IN THE 10 PEOPLECONNECT, INC., ALTERNATIVE, TO CERTIFY IMMEDIATE APPEAL 11 Defendant. Docket No. 99 12 13 14 Plaintiffs Meredith Callahan and Lawrence Geoffrey Abraham have filed a class action 15 against Defendant PeopleConnect, Inc. According to Plaintiffs, PeopleConnect misappropriated 16 Plaintiffs’ names, photographs, and likenesses and used the same in advertising its products and 17 services, such as “subscription memberships to the website Classmates.com.” Compl. ¶ 2. 18 Currently pending before the Court is PeopleConnect’s motion for judgment on the pleadings or, 19 in the alternative, for leave to file an interlocutory appeal. In essence, PeopleConnect is trying to 20 resuscitate its argument that Plaintiffs are collaterally estopped from arguing that PeopleConnect 21 does not have CDA immunity (as Judge Beeler held in the similar Ancestry case). In the 22 alternative, PeopleConnect argues that the issue of immunity under the Communications Decency 23 Act (“CDA”) should be certified for immediate appeal to the Ninth Circuit. 24 Having considered the parties’ briefs and accompanying submissions, as well as the oral 25 argument of counsel, the Court hereby DENIES PeopleConnect’s motion for relief. 26 I. FACTUAL & PROCEDURAL BACKGROUND 27 Plaintiffs initiated this lawsuit in December 2020. See Docket No. 2 (complaint). 1 Rule of Civil Procedure 12(b)(6). In May 2021, the Court denied the motion to compel 2 arbitration. See Docket No. 40 (order). The following month, PeopleConnect appealed that 3 ruling. 4 Several months later, in November 2021, the Court denied PeopleConnect’s motion to stay 5 pending appeal. The Court also addressed the merits of PeopleConnect’s motion to dismiss. See 6 Docket No. 76 (order). 7 One of the issues raised in the motion to dismiss was whether PeopleConnect had 8 immunity under the Communications Decency Act (“CDA”). See 47 U.S.C. § 230(c)(1) 9 (providing that “[n]o provider or user of an interactive computer service shall be treated as the 10 publisher or speaker of any information provided by another information content provider”); 11 Kimzey v. Yelp! Inc., 836 F.3d 1263, 1268 (9th Cir. 2016) (stating that the statute “‘protects from 12 liability (1) a provider or user of an interactive computer service [e.g., a website] (2) whom a 13 plaintiff seeks to treat, under a state law cause of action, as a publisher or speaker (3) of 14 information provided by another information content provider’”). PeopleConnect argued that it 15 did have CDA immunity – but first asserted that the merits issue need not be decided because 16 Plaintiffs were precluded from contending that PeopleConnect did not have such immunity. 17 PeopleConnect pointed out that Plaintiffs had brought the same basic suit against a different 18 defendant, Ancestry, and that, in that case, Judge Beeler found that Ancestry was protected by 19 CDA immunity. See Callahan v. Ancestry.com Inc., No. 20-cv-08437-LB, 2021 U.S. Dist. LEXIS 20 37811 (N.D. Cal. Mar. 1, 2021) (hereinafter “Ancestry I”); Callahan v. Ancestry, No. 20-cv- 21 08437-LB, 2021 U.S. Dist. LEXIS 112036 (N.D. Cal. June 15, 2021) (hereinafter “Ancestry II”). 22 In other words, PeopleConnect invoked defensive collateral estoppel. See Collins v. D.R. Horton, 23 Inc., 505 F.3d 874, 884 (9th Cir. 2007) (stating that defensive collateral estoppel “‘occurs when a 24 defendant seeks to prevent a plaintiff from asserting a claim the plaintiff has previously litigated 25 and lost against another defendant’”). 26 The Court rejected PeopleConnect’s defensive collateral estoppel argument for two 27 reasons. First, the Court had to apply California law on collateral estoppel and, under California 1 Plaintiffs had appealed Judge Beeler’s decisions). Second, the Court held that, even if the 2 technical requirements of collateral estoppel had been met, “the doctrine is to be applied only 3 where such application comports with fairness and sound public policy.” Docket No. 76 (Order at 4 8) ( internal quotation marks omitted). The Court noted that this was true for offensive collateral 5 estoppel; “[s]imilar concerns should inform defensive collateral estoppel as well.” Docket No. 76 6 (Order at 8) (citing in support a decision from Judge Spero of this District as well as the 7 Restatement (Second) on Judgments). The Court concluded that fairness and sound public policy 8 weighed against application of collateral estoppel because, although Judge Beeler had found CDA 9 immunity applicable in a similar case, “other district courts have reached differing conclusions.” 10 Docket No. 76 (Order at 7). 11 The Court went on to address the merits of the CDA immunity argument. The Court took 12 note of the Ninth Circuit’s decision in Batzel v. Smith, 333 F.3d 1018 (9thCir. 2003), which held 13 that “a service provider or user is immune from liability under § 230(c)(1) when a third person or 14 entity that created or developed the information in question furnished it to the provider or user 15 under circumstances in which a reasonable person in the position of the service provider or user 16 would conclude that the information was provided for publication on the Internet or other 17 ‘interactive computer service.’” Id. at 1033. The Court then concluded that, “at the very least, 18 there is a question of fact as to whether a reasonable person in the position of PeopleConnect (the 19 service provider) would conclude that the yearbook authors/publishers (the information content 20 providers) intended the yearbooks to be published on the internet.” Docket No. 76 (Order at 10). 21 After the Court issued its ruling above (in November 2021), the parties agreed to a stay of 22 proceedings pending PeopleConnect’s appeal of the arbitration decision. PeopleConnect did not 23 ask the Court at that time for an interlocutory appeal with respect its CDA immunity ruling –either 24 with respect to collateral estoppel or with respect to the merits. 25 In the meantime, Plaintiffs’ appeal in the Ancestry case was proceeding. In February 2022, 26 the Ninth Circuit scheduled oral argument for the Ancestry appeal. But just one week later, 27 Plaintiffs voluntarily moved to dismiss their appeal. Although Ancestry opposed the motion, the 1 Mot. at 5-6. Also in March 2022, the Ninth Circuit issued its decision affirming this Court’s order 2 denying PeopleConnect’s motion to compel arbitration. See Docket No. 92 (order). 3 On April 11, 2022, Plaintiffs filed an unopposed motion to lift the stay on proceedings in 4 this case. The Court lifted the stay on the same day. See Docket No. 97 (order). The next day, 5 PeopleConnect filed the currently pending motion. PeopleConnect argues that it is entitled to 6 judgment on the pleadings because of collateral estoppel. PeopleConnect acknowledges the 7 Court’s prior ruling but contends that (1) the Ancestry case is now final for purposes of collateral 8 estoppel since the appeal has been resolved and (2) assuming that it is appropriate to consider 9 equities for defensive collateral estoppel (as opposed to offensive), the equities now weigh in 10 PeopleConnect’s favor because Plaintiffs chose to voluntarily dismiss the appeal in Ancestry even 11 though that would have addressed the issue of whether CDA immunity was appropriate.

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Bluebook (online)
Callahan v. PeopleConnect Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/callahan-v-peopleconnect-inc-cand-2022.