H. v. Meta Platforms, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 12, 2024
Docket3:23-cv-04784
StatusUnknown

This text of H. v. Meta Platforms, Inc. (H. v. Meta Platforms, 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
H. v. Meta Platforms, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 E. H. and C.S., Case No. 23-cv-04784-WHO

8 Plaintiffs, ORDER ON MOTION TO DISMISS v. 9 Re: Dkt. No. 34 10 META PLATFORMS, INC., Defendant. 11

12 This case is one of many pending in this District and around the country against defendant 13 Meta Platforms, Inc. (“Meta”) over the use of its “pixel” tracking technology. According to 14 plaintiffs here and in the other cases, Meta encourages operators of websites and applications 15 (“apps”) to install its pixel technology and then, unbeknownst to users of those websites and apps 16 (here Cerebral, an online mental telehealth provider, Compl. ¶ 36), the users’ sensitive healthcare 17 information is transmitted to Meta. Here, named plaintiffs E.H. and C.S. are residents of 18 Oklahoma and Massachusetts respectively and do not have Facebook accounts. Yet they allege 19 their data was intercepted and transmitted to Meta. See Compl. ¶¶ 7, 11, 12. 20 Meta acknowledges my prior Orders in In Re Meta Healthcare Pixel Litigation: while 21 preserving its arguments, it does not challenge in the motion to dismiss in this case plaintiffs’ 22 Federal Wiretap Act,1 CIPA,2 and unjust enrichment claims. Instead, it challenges plaintiffs’ 23 claims for: invasion of privacy; violation of California’s Unfair Competition Law (“UCL,” Cal. 24 Bus. & Prof. Code § 17200 et seq.); violation of California’s Consumers Legal Remedies Act 25 26 1 18 U.S.C. §§ 2510, et seq. 27 1 (“CLRA,” Cal. Civ. Code § 1750 et seq.); and conversion.3 Its motion to dismiss is DENIED. 2 LEGAL STANDARD 3 Under FRCP 12(b)(6), a district court must dismiss a complaint if it fails to state a claim 4 upon which relief can be granted. To survive a Rule 12(b)(6) motion to dismiss, the plaintiff must 5 allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. 6 Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible when the plaintiff pleads facts 7 that “allow the court to draw the reasonable inference that the defendant is liable for the 8 misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation omitted). There must 9 be “more than a sheer possibility that a defendant has acted unlawfully.” Id. While courts do not 10 require “heightened fact pleading of specifics,” a plaintiff must allege facts sufficient to “raise a 11 right to relief above the speculative level.” Twombly, 550 U.S. at 555, 570. 12 In deciding whether the plaintiff has stated a claim upon which relief can be granted, the 13 court accepts the plaintiff’s allegations as true and draws all reasonable inferences in favor of the 14 plaintiff. See Usher v. City of Los Angeles, 828 F.2d 556, 561 (9th Cir. 1987). However, 15 the court is not required to accept as true “allegations that are merely conclusory, unwarranted 16 deductions of fact, or unreasonable inferences.” In re Gilead Scis. Sec. Litig., 536 F.3d 1049, 17 1055 (9th Cir. 2008). If the court dismisses the complaint, it “should grant leave to amend even if 18 no request to amend the pleading was made, unless it determines that the pleading could not 19 possibly be cured by the allegation of other facts.” Lopez v. Smith, 203 F.3d 1122, 1127 (9th Cir. 20 2000). In making this determination, the court should consider factors such as “the presence or 21 absence of undue delay, bad faith, dilatory motive, repeated failure to cure deficiencies by 22 previous amendments, undue prejudice to the opposing party and futility of the proposed 23 amendment.” Moore v. Kayport Package Express, 885 F.2d 531, 538 (9th Cir. 1989). 24 3 Meta asks me to take judicial notice of its Business Tools Terms and its Commercial Terms, 25 because these documents are “available on publicly available websites” and under the doctrine of incorporation because “plaintiffs’ complaint depends on the contents of the documents.” Dkt. No. 26 34-1 at 1. The request is DENIED. It is not appropriate to take judicial notice of documents for the purpose Meta seeks (to consider the contents and meaning of those documents) merely because 27 they are available online. The passing reference in one paragraph of the Complaint out of 200 to 1 DISCUSSION 2 I. PRIVACY CLAIMS 3 Meta argues that plaintiffs’ invasion of privacy claims based on the California constitution 4 and common law intrusion on seclusion fail because these plaintiffs do not identify any specific, 5 sensitive information that they believe Meta received about them. I accept plaintiffs’ allegations 6 in the Complaint as true and disagree with Meta. 7 In the Complaint, plaintiffs allege that they provided specific categories of information to 8 Cerebral, a mental telehealth provider. As part of creating an account on Cerebral to receive 9 mental health services, plaintiffs disclosed personally identifying information, as well as responses 10 to questions regarding their mental health in the past few weeks. See Compl. ¶ 37 (the information 11 received by Meta included that each plaintiff “had created an account, first name, last name, phone 12 number, email, and zip code. This type of account creation data is in and of itself identifiable 13 health information, as accounts were only created by people seeking treatment from Cerebral 14 (rather than casually browsing its site)”); id. ¶ 38 (“But the Pixel also intercepted answers to intake 15 questionnaires that Cerebral patients had to complete as part of the sign-up process, such as how 16 often in the previous two weeks they had felt ‘down, depressed, or hopeless.’ Like the account 17 creation data, the questionnaire responses showed that Plaintiffs were actively using Cerebral’s 18 services, while also broadcasting Plaintiffs’ specific symptoms directly to Meta.”). 19 Meta contends that these allegations are deficient, pointing in part to my September 2023 20 Order in the In re Meta Healthcare Pixel Litigation case. There, I dismissed the privacy-based 21 claims and required plaintiffs to “amend to describe the types or categories of sensitive health 22 information that they provided through their devices to their healthcare providers. That basic 23 amendment (which can be general enough to protect plaintiffs’ specific privacy interests) will 24 allow these privacy claims to go forward.” Doe v. Meta Platforms, Inc., No. 22-CV-03580-WHO, 25 2023 WL 5837443, at *8 (N.D. Cal. Sept. 7, 2023). In that case, plaintiffs had alleged that both 26 unprotected and protected healthcare information had been intercepted, but had not identified the 27 type of sensitive healthcare information they provided to their healthcare provider that they 1 This case is different. Cerebral is not simply a healthcare provider; it is a mental health 2 services provider. Plaintiffs affirmatively allege that they were not simply surfing the web seeking 3 information about routine or general healthcare topics. Instead, the information (including 4 otherwise somewhat innocuous information like name and zip code) was secured by Meta from 5 Cerebral in the process of accounts being created “by people seeking treatment from Cerebral 6 (rather than casually browsing its site).” Compl. ¶ 37.

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H. v. Meta Platforms, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/h-v-meta-platforms-inc-cand-2024.