Callahan v. PeopleConnect Inc.

District Court, N.D. California·Decided May 20, 2024·No. 3:20-cv-09203·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ALICIA NOLEN, Case No. 20-cv-09203-EMC

8 Plaintiff, ORDER RE STATUS REPORT 9 v.

10 PEOPLECONNECT, INC., Docket No. 276 11 Defendant.

12 13 14 Previously, the Court ordered the parties to meet and confer regarding (1) class definition 15 and (2) class notice. See Docket No. 256 (order conditionally granting class certification, filed on 16 12/14/2023); Docket No. 267 (order re class definition and class notice, filed on 1/19/2024). 17 Following several months of exchanges, the parties have finally submitted a status report. The 18 parties have reached agreement on some issues, but not others. 19 I. CLASS DEFINITION 20 Ms. Nolen proposes the following class definition1:

21 All persons residing in the State of California: (1) who are not, and have never been, registered users of Classmates.com; (2) who have 22 never donated a yearbook to Classmates.com; and (3) for whom a search of their name, using the search bar on the Classmates.com 23 website, yields at least one record corresponding to the class member from a yearbook that Classmates.com first made publicly 24 available on or after December 18, 2018. 25 Status Rpt. at 3. The parties have three disputes related to this proposed definition. 26 27 1 A. Element (3) 2 PeopleConnect takes issue with the third element in the proposed definition, asserting that 3 it suffers from both vagueness and overbreadth problems. According to PeopleConnect, the third 4 element is vague because “the only way to determine who is ‘searchable,’ and therefore is a 5 member of a class, is to undergo a burdensome, individualized manual process for all class 6 members”; and the third element is overbroad because it “include[s] individuals who do not have 7 meritorious claims” – i.e., because they are not reasonably identifiable. Status Rpt. at 4. 8 Neither argument is persuasive. As to vagueness, PeopleConnect has not explained why 9 class members could not self-identify. The Court’s class-certification order addressed self- 10 identification, albeit in a slightly different context (i.e., a class member representing that she is not 11 a registered user, as registered users are excluded from the class). See Docket No. 256 (Order at 12 30-32). Any concern about fraudulent self-identification is also tempered here because the 13 legitimacy of a self-identification can easily be tested; this is not a situation where, e.g., a 14 consumer may not have kept a receipt showing that she purchased a product. 15 As for overbreadth, the Court previously rejected (in its class certification order) 16 PeopleConnect’s contention that reasonable identifiability could not be determined without 17 overwhelming individualized inquiries. PeopleConnect is essentially asking the Court to 18 reconsider without having filed a motion for leave to file a motion for reconsideration as required 19 by the District’s Local Rules. See Civ. L.R. 7-9. 20 Even if PeopleConnect had so moved and the Court given leave to file a motion to 21 reconsider, PeopleConnect would not obtain a more favorable result. As the Court noted in its 22 class certification order, “a person is usually identifiable by their name, especially when viewed in 23 context of having attended a particular school in a particular year.” Docket No. 256 (Order at 21). 24 PeopleConnect has still failed to show that the problem of, e.g., a same or similar name “is . . . 25 extensive or pervasive . . . , especially when the confusion must occur within the same school 26 within a given year.” Docket No. 256 (Order at 25). In the absence of a such problem, any 27 confusion of identity can be worked out without having individualized inquiries overwhelm 1 defendant substantiates . . . an individualized issue . . . , the district court must determine . . . 2 whether a class-by-class-member assessment of the individualized issue will be unnecessary or 3 workable”). For example, as Plaintiffs contend, if there are multiple individuals with the same 4 name, other information available in the yearbook can likely be used to distinguish them – or may 5 show that the names all refer to the same person. See also Docket No. 256 (Order at 25) (stating 6 that PeopleConnect “has not demonstrated that any confusion of identity cannot be easily 7 resolved”).2 8 Moreover, although a person must be reasonably identifiable in order to prevail on a § 9 3344 claim, should that issue present a larger concern, it could be reserved for a later stage in the 10 proceedings, i.e., when damages are to be determined. “Rule 23 specifically contemplates the 11 need for . . . individualized claim determinations after a finding of liability.” Briseno v. ConAgra 12 Foods, Inc., 844 F.3d 1121, 1131 (9th Cir. 2017); see also Docket No. 256 (Order at 26 n.12) 13 (noting that Federal Rule of Civil Procedure 23(c)(4) allows for issues to be determined on a 14 classwide basis; “what is before the Court is something akin to a separation of liability and 15 damages issues – i.e., Ms. Nolen will rely on common evidence to show that PeopleConnect used 16 people’s names and photos for a commercial purpose; if she is successful, then the only remaining 17 step for a person to claim statutory damages of $750 is to show that their name was readily 18 identifiable”). 19 2 In Van, there was a more significant problem of individualized inquiries compared to that here. 20 The defendant was a company that sold clothing to purchasers through fashion retailers in all fifty states. It “allegedly charged sales tax to these purchasers based on the location of the retailer, 21 rather than the location of the purchaser, which resulted in some online purchasers being charged, and having paid, sales tax when none was owed.” Van, 61 F.4th at 1058. Some retailers, 22 however, gave discounts to offset the improper sales tax. There was evidence that there were 13,680 discounts out of 72,373 transactions total, and “at least eighteen of the 13,680 discounts 23 provided to class members were provided for the [express] purpose of offsetting the improperly assessed sales tax.” Id.; see also id. at 1068 n.13. The Ninth Circuit noted: 24

[The defendant’s] evidence, even though it consisted of only a small 25 number of invoices, was sufficient to prove that an inquiry into the circumstances and motivations behind each of the 13,680 discounts 26 might be necessary. This inquiry, which could potentially involve up to 13,680 depositions and months of trial, certainly cannot be 27 described as de minimis. 1 The Court therefore rejects PeopleConnect’s challenge to element (3). That being said, the 2 Court modifies element (3) to provide some additional clarity and, as discussed below, to limit the 3 definition to California yearbooks. The class definition approved by the Court is as follows (with 4 the modifications highlighted for the convenience of the parties only). 5 All persons residing in the State of California: (1) who are not, and 6 have never been, registered users of Classmates.com; (2) who have never donated a yearbook to Classmates.com; and (3) for whom a 7 search of their name, using the search bar to search a California yearbook made available for viewing on the Classmates.com 8 website, yields at least one record corresponding to the class member from a California yearbook that Classmates.com first made 9 publicly available on or after December 18, 2018. 10 B. Additional Element re Consent 11 PeopleConnect argues next that a fourth element should be added to the proposed 12 definition.

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