Heeger v. Facebook, Inc.

CourtDistrict Court, N.D. California
DecidedDecember 24, 2020
Docket3:18-cv-06399
StatusUnknown

This text of Heeger v. Facebook, Inc. (Heeger v. Facebook, 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
Heeger v. Facebook, Inc., (N.D. Cal. 2020).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8 9 BRETT HEEGER et al., Case No. 18-cv-06399-JD

10 Plaintiffs, ORDER RE MOTIONS TO DISMISS v. 11 Re: Dkt. No. 76 12 FACEBOOK, INC., Defendant. 13

14 BRENDAN LUNDY et al., Case No. 18-cv-06793-JD Plaintiffs, Re: Dkt. No. 82 15 v. 16

17 FACEBOOK, INC., Defendant. 18

19 These cases are related putative class actions by Facebook users, who challenge Facebook, 20 Inc.’s collection of personal location data. Facebook’s motion to dismiss in Heeger, Case No. 18- 21 6399, is granted, and its motion to dismiss in Lundy, Case No. 18-6793, is granted and denied in 22 part. 23 BACKGROUND 24 In both cases, the first amended class action complaints are the operative pleadings. See 25 Case No. 18-6399, Dkt. No. 74 (“Heeger FAC”); Case No. 18-6793, Dkt. No. 80 (“Lundy FAC”). 26 While the allegations in the complaints overlap to a considerable degree, Lundy presents some 27 material variations that warrant a different outcome for the motion. Facebook is the sole named 1 The Heeger FAC added three named plaintiffs -- Zachary Henderson, Caleb Rappaport, 2 and Elizabeth Pomiak -- to plaintiff Brett Heeger, who filed the original complaint. Heeger FAC 3 ¶¶ 14-17. As alleged in the FAC, Facebook “describ[es]” the “Location History” feature in its 4 mobile app, and the “Location Services” setting on users’ cell phones, as “settings through which 5 Facebook users can purportedly control location tracking.” Id. ¶¶ 4-5. But Facebook “collects 6 users’ location data without those users’ consent, regardless of their settings.” Id. ¶ 5. Facebook 7 then “highlights the detail and specificity of that data” to its advertisers, and “uses th[e] data to 8 precisely target its advertiser customers’ advertisements to Facebook users.” Id. The FAC alleges 9 California state law claims on behalf of a putative class of “[a]ll Facebook users in the United 10 States who turned off ‘Location History’ or ‘Location Services’ or both, during the applicable 11 limitations period,” for: (1) violation of the California Invasion of Privacy Act, Cal. Pen. Code 12 § 630 et seq. (“CIPA”); (2) violation of California’s constitutional right of privacy; (3) intrusion 13 upon seclusion; and (4) unjust enrichment. Id. ¶¶ 67, 81-107. 14 The Lundy FAC was brought by two plaintiffs: Brendan Lundy and Myriah Watkins. 15 Lundy FAC ¶¶ 10-19. The FAC alleges that they “never granted Facebook permission to access 16 [their] location data through [their] Location Services or Facebook App settings,” and that they 17 specifically had their “Location History” Facebook app setting turned to “off.” Id. ¶¶ 11, 16. 18 Plaintiffs allege that “[c]ontrary to plaintiffs’ device settings selections, and contrary to 19 Facebook’s Privacy Policy in effect during the relevant time period, Facebook tracked plaintiffs’ 20 locations using their IP addresses and enhanced location determination techniques.” Id. ¶ 5. 21 Facebook is said to have “bundled this location information with plaintiffs’ other personal 22 information,” and then “monetized these bundled packages . . . for targeted advertising purposes, 23 thus enriching itself” in the amount of “hundreds of millions of dollars from increased advertising 24 revenue.” Id. 25 Unlike Heeger, the Lundy plaintiffs limit their claims to the time period before April 19, 26 2018. See id. ¶ 99 (alleging the lawsuit is brought on behalf of persons “who were users of 27 Facebook prior to April 19, 2018 who did not give Facebook permission to collect and use their 1 privacy policy” which disclosed “that Facebook will collect location data using IP addresses, even 2 without user permission.” Id. ¶¶ 25-26. The Lundy FAC quotes the revised policy, which 3 expressly advised users that “[y]ou can control whether your device shares precise location 4 information with Facebook Company Products via Location Services,” but also that “[w]e may 5 still understand your location using things like check-ins, events, and information about your 6 internet connection.” Id. ¶ 26. It agrees that this revised policy, unlike the prior version, “advises 7 users that it will collect their location information, including location information derived from IP 8 addresses without user consent, and bundle this location information, with ‘information about 9 [their] interests, actions and connections,’ to deliver personalized advertising and sponsored 10 content.” Id. ¶ 27. 11 The complaint in Lundy also differs from Heeger in the claims alleged against Facebook. 12 The Lundy plaintiffs make claims for: (1) violation of article I, section 1 of the California 13 constitution; (2) intrusion upon seclusion; (3) intentional misrepresentation and omission; 14 (4) deceit by concealment or omission, Cal. Civ. §§ 1709 & 1710; (5) breach of contract; 15 (6) breach of implied covenant of good faith and fair dealing; (7) negligent misrepresentation; and 16 (8) unjust enrichment. Id. ¶¶ 108-96. 17 Facebook has moved to dismiss both amended complaints under Rules 12(b)(1) and 18 12(b)(6) of the Federal Rules of Civil Procedure. Heeger Dkt. No. 76; Lundy Dkt. No. 82.1 19 DISCUSSION 20 I. FACEBOOK’S MOTION TO DISMISS IN HEEGER 21 This is the second round of pleadings motions in Heeger. The Court granted Facebook’s 22 initial motion to dismiss, with leave to amend. Dkt. No. 70. In that order, the Court concluded 23 that plaintiff Heeger had established Article III standing to sue on the privacy and other claims. 24 Id. at 2-4. On substantive grounds, the CIPA claim was dismissed because the complaint did not 25 plausibly allege the use of an “electronic tracking device” as required by California Penal Code 26 § 637.7(a). Id. at 4. The privacy claims for intrusion upon seclusion and violation of the 27 1 California constitutional right to privacy were dismissed because the complaint did not “provide 2 enough facts to undertake the context-specific inquiry into the plausibility of the privacy 3 expectation or the offensiveness of the intrusion.” Id. at 5-6. The Court determined that the 4 complaint “does not state the precision of the location data Facebook is alleged to have collected 5 after users turned off ‘Location History.’” Id. at 6. The Court underscored that “[t]his is 6 important because a generalized location, such as one that locates a user no more precisely than 7 within several city blocks, may not implicate much in the way of privacy concerns,” whereas 8 “[h]ighly specific location data . . . that identifies a user’s pinpoint comings and goings would 9 likely present substantially greater concerns.” Id. 10 Plaintiffs amended the complaint, but with scant improvement. The Heeger FAC now 11 reads like a book report that simply summarizes third-party news stories about Facebook’s 12 ostensible capacity to “discern precise locations” from user data. See, e.g., Heeger FAC ¶¶ 8, 48- 13 50, 53 & nn.4-5, 29-31.2 Few facts are alleged without the caveat of “on information or belief,” or 14 without hedging on whether Facebook actually does what Heeger accuses, or simply has the 15 ability to do it. See, e.g., id. ¶ 49 (alleging that “Facebook can also match IP addresses taken from 16 users who have turned Location Services and Location History off with IP address information 17 taken from users who have not limited Facebook’s ability to access their location and who have 18 given Facebook access to extremely precise location data, like Wifi access points or GPS”) (first 19 emphasis added); id. & n.29 (citing an article entitled, How Others Compromise Your Location 20 Privacy: The Case of Shared Public IPs at Hotspots, and alleging “upon information and belief, 21 Facebook does this in order to obtain precise location data about all its users, without disclosing 22 this practice.”).

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Bluebook (online)
Heeger v. Facebook, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/heeger-v-facebook-inc-cand-2020.