hiQ Labs, Inc. v. Linkedin Corporation

CourtDistrict Court, N.D. California
DecidedApril 19, 2021
Docket3:17-cv-03301
StatusUnknown

This text of hiQ Labs, Inc. v. Linkedin Corporation (hiQ Labs, Inc. v. Linkedin Corporation) 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
hiQ Labs, Inc. v. Linkedin Corporation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 HIQ LABS, INC., Case No. 17-cv-03301-EMC

8 Plaintiff, ORDER DEFERRING IN PART AND 9 v. DENYING IN PART PLAINTIFF’S MOTION TO DISMISS AND STRIKE 10 LINKEDIN CORPORATION, COUNTERCLAIMS 11 Defendant. Docket No. 182

12 13 14 This case arises out of Plaintiff hiQ Labs, Inc.’s access to and use of public profiles of 15 Defendant LinkedIn Corp.’s users. hiQ initiated this lawsuit against LinkedIn, bringing claims 16 for, inter alia, declaratory relief, tortious interference, and unfair competition. In response, 17 LinkedIn has asserted counterclaims, including violation of the federal Computer Fraud and Abuse 18 Act, breach of contract, and misappropriation. Currently pending before the Court is hiQ’s motion 19 to dismiss the counterclaims. Having considered the parties’ briefs and accompanying 20 submissions, the Court hereby DEFERS in part and DENIES in part hiQ’s motion. 21 I. FACTUAL & PROCEDURAL BACKGROUND 22 LinkedIn is a company that provides a social network for professionals. See Countercl. ¶ 23 20. Members of LinkedIn “create individual profiles that serve as their professional profiles 24 online.” Countercl. ¶ 21. Today, the company has more than 700 million members worldwide. 25 See Countercl. ¶ 21. 26 LinkedIn gives its members numerous privacy protections and privacy choices. For 27 example: 1 will permanently delete the account and all of the data that the member posted to 2 LinkedIn within 30 days.” Countercl. ¶ 56 (alleging that this “helps ensure that 3 members are the ones who have ultimate control over [their information]”). 4 • Members can choose to have all or part of their profiles exempt from indexing by 5 well-known search engines such as Google, Bing, and Duck Duck Go. See 6 Countercl. ¶ 55. 7 • When members update information in their profiles, they can choose whether to 8 broadcast that change on LinkedIn. See Countercl. ¶ 57 (alleging that, if a member 9 chooses the “Do Not Broadcast” setting, the “changes that the member makes to his 10 or her profile will be visible, but the fact that the member made a change will not 11 be broadcast to his or her LinkedIn connections or to anyone else”); see also 12 Countercl. ¶ 58 (alleging that this feature was put in place “in response to feedback 13 from LinkedIn members who were hesitant to update their profiles for fear that 14 their co-workers or employers would suspect they were searching for a new job or 15 otherwise thinking of leaving their current jobs”). 16 “LinkedIn’s website and servers are not unconditionally open to the general public.” 17 Countercl. ¶ 25. “This is because LinkedIn’s servers are protected by sophisticated defenses . . . 18 that evaluate whether to grant each request made to LinkedIn’s servers.” Countercl. ¶ 25. These 19 defenses “currently block hundreds of millions of requests to access guest profiles per day from 20 bots and scrapers, which constitute the majority of the requests made to LinkedIn’s servers for 21 guest profiles.” Countercl. ¶ 25. 22 Examples of LinkedIn’s defenses include the following: 23 • The Sentinel system. “Through Sentinel, LinkedIn maintains a list of IP addresses 24 that are not permitted to make calls on LinkedIn’s servers because they either have 25 in the past or are engaged in abuse.” Countercl. ¶ 27. 26 • LinkedIn’s “robots.txt” file. The file “provides a set of instructions to any 27 automated technologies visiting the LinkedIn site, as well as an explicit warning 1 prohibited.” Countercl. ¶ 33. The file “does permit some webcrawlers (e.g., search 2 engines such as Google or Bing) to crawl and index the site.” Countercl. ¶ 33; see 3 also Countercl. ¶ 55 (alleging that that LinkedIn’s “Privacy Policy expressly 4 informs members that search engines may index and display information in their 5 profiles” but “LinkedIn limits such indexing to well-known search engines, such as 6 Google, Bing and Duck Duck Go”; furthermore, “LinkedIn permits members to 7 choose the parties of their profiles that search engines index, or to opt out of this 8 feature entirely”). 9 • LinkedIn’s “custom rules.” LinkedIn applies “over 200 custom rules . . . to 10 requests made to its servers to determine whether the requests is from a human or 11 bot.” Countercl. ¶ 30. Some of the rules fall under LinkedIn’s Guest Request 12 Scoring System and Member Request Scoring System. The Guest Request Scoring 13 System “monitors and limits page requests made by users who are not logged into 14 LinkedIn. If unusual patterns or high levels of activity are detected, the user is 15 redirected to LinkedIn’s log-in page and is prevented from viewing additional 16 LinkedIn pages while not logged in.” Countercl. ¶ 32. “The Member Request 17 Scoring System monitors page requests made by LinkedIn members while logged 18 into their accounts. If high levels of activity are detected for certain types of 19 accounts, the member is logged out and may either be warned, restricted, or 20 challenged with a CAPTCHA in order to log back into LinkedIn.” Countercl. ¶ 31. 21 • Password barrier. “Much of the information on LinkedIn’s website is behind a 22 password barrier. Periodically, LinkedIn will prevent ‘logged-out’ users from 23 viewing more than a certain number of pages before being asked to enter a user 24 name and password to see more.” Countercl. ¶ 34. 25 • The FUSE system. “FUSE scans and imposes a limit on the activity that an 26 individual LinkedIn member may initiate on the site. This limit is intended to 27 prevent would-be data scrapers utilizing automated technologies from quickly 1 In addition to the above defenses, LinkedIn’s User Agreement “prohibits accessing and 2 scraping of LinkedIn’s website through automated software and other technologies.” Countercl. ¶ 3 36; see also Countercl. ¶ 49 (citing § 8.2 of the User Agreement). Members of LinkedIn are 4 subject to the User Agreement but so too are users and visitors of the LinkedIn website. See 5 Countercl. ¶ 37. For example, “[t]he relevant version of the User Agreement, effective October 6 23, 2014, states that ‘You agree that by clicking “Join Now[,]” “Join LinkedIn” “Sign Up” or 7 similar[] registering, accessing, or using our services . . . , you are entering into a legally binding 8 agreement (even if you are using our Services on behalf of a company).’” Countercl. ¶ 37. 9 Notwithstanding these measures, hiQ accesses and aggregates publicly available profiles 10 on LinkedIn and uses the data for the data analytic tools it sells. 11 A. hiQ’s First Amended Complaint (“FAC”) 12 In its FAC, hiQ asserts the following claims for relief: 13 (1) A declaratory judgment that hiQ has not violated and will not violate the Computer 14 Fraud and Abuse Act of 18 U.S.C. § 1030 by accessing LinkedIn public profiles. 15 (2) A declaratory judgment that hiQ has not violated and will not violate the Digital 16 Millennium Copyright Act, 17 U.S.C. § 1201, by accessing LinkedIn public 17 profiles. 18 (3) A declaratory judgment that hiQ has not committed and will not commit common 19 law trespass to chattels by accessing LinkedIn public profiles. 20 (4) A declaratory judgment that hiQ has not violated and will not violate California 21 Penal Code § 502(c) by accessing LinkedIn public profiles. 22 (5) Intentional interference with contract. 23 (6) Intentional interference with prospective economic advantage. 24 (7) Unfair competition in violation of California Business & Professions Code § 25 17200. 26 (8) Unlawful competition in violation of § 17200. 27 (9) Fraudulent competition in violation of § 17200. 1 B.

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hiQ Labs, Inc. v. Linkedin Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hiq-labs-inc-v-linkedin-corporation-cand-2021.