In re Facebook Biometric Information Privacy Litigation

CourtDistrict Court, N.D. California
DecidedFebruary 26, 2021
Docket3:15-cv-03747
StatusUnknown

This text of In re Facebook Biometric Information Privacy Litigation (In re Facebook Biometric Information Privacy Litigation) 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
In re Facebook Biometric Information Privacy Litigation, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 IN RE FACEBOOK BIOMETRIC Case No. 15-cv-03747-JD INFORMATION PRIVACY LITIGATION 8 ORDER RE FINAL APPROVAL, 9 ATTORNEYS’ FEES AND COSTS, AND INCENTIVE AWARDS 10 Re: Dkt. Nos. 499, 517 11

12 By any measure, the $650 million settlement in this biometric privacy class action is a 13 landmark result. It is one the largest settlements ever for a privacy violation, and it will put at 14 least $345 into the hands of every class member interested in being compensated. At the Court’s 15 request, the parties jointly developed an innovative notice and claims procedure that generated an 16 impressive claims rate. The settlement attracted widespread support from the class, and drew only 17 three objections out of millions of class members. 18 All of this was achieved in the context of a new and untested statute, the Illinois Biometric 19 Information Privacy Act (BIPA), 740 Ill. Comp. Stat. 14/1 et seq. (2008). The case raised several 20 complicated and intensely litigated issues, including the question of whether a statutory privacy 21 injury was sufficiently “real” and concrete to establish an injury in fact for standing under 22 Article III and the BIPA. The Court determined that it was, and two other courts -- the Illinois 23 Supreme Court and the Ninth Circuit -- reached the same conclusion. The standing issue makes 24 this settlement all the more valuable because Facebook and other big tech companies continue to 25 fight the proposition that a statutory privacy violation is a genuine harm. In a pending Supreme 26 Court case about the Fair Credit Reporting Act, which is unrelated to this action, Facebook, 27 Google, and eBay filed an amicus brief that points to this settlement and asks the Court to reverse 1 Curiae eBay, Inc. et al. Supporting Petitioner at 4, Trans Union LLC v. Ramirez, No. 20-297 (U.S. 2 Feb. 8, 2021). This underscores the considerable legal risks both sides would have faced had this 3 case continued on. 4 Overall, the settlement is a major win for consumers in the hotly contested area of digital 5 privacy. Final approval of the class action settlement is granted. Attorneys’ fees and costs, and 6 incentive awards to the named plaintiffs, are also granted, although in lesser amounts than 7 requested. 8 BACKGROUND 9 This case has traveled a long and winding road since it was filed in 2015, and the Court 10 focuses here on the key events most pertinent to final approval and the fees award. A heavily 11 litigated class certification motion was resolved in favor of certification of a class of Facebook 12 users located in Illinois for whom Facebook created and stored a face template after June 7, 2011. 13 Dkt. No. 333 at 15. The certified class, which is also the class for the settlement, Dkt. No. 468, 14 Ex. A at 5-6 (¶ 1.7), challenged Facebook’s “Tag Suggestions” program, which looks for and 15 identifies people’s faces in photographs uploaded to Facebook to promote user tagging. The class 16 members alleged that Facebook collected and stored their biometric data -- namely digital scans of 17 their faces -- without prior notice or consent, thereby violating Sections 15(a) and 15(b) of the 18 BIPA, 740 Ill. Comp. Stat. 14/15(a)-(b). 19 After substantial briefing and argument, the Court concluded that a violation of the BIPA 20 was enough to establish an injury in fact for purposes of Article III standing. See Dkt. No. 294. 21 This was not the only serious disagreement between the parties in the early stage of the case. 22 A significant battle was also fought over a choice-of-law provision in Facebook’s user agreements, 23 and whether California law applied to the exclusion of a claim under the BIPA, as Facebook 24 argued. The Court held an evidentiary hearing to help resolve that dispute, and concluded that 25 Illinois law applied. See Dkt. No. 120. But the injury-in-fact issue stands out both because it was 26 a threshold issue for the litigation as a whole, and because it became a central issue in Facebook’s 27 discretionary appeal to the Ninth Circuit of the Court’s certification of the class. See Dkt. 1 Dkt. No. 416. The Supreme Court denied Facebook’s petition for certiorari. Dkt. No. 426. While 2 these events were unfolding in federal court, the Illinois Supreme Court published a decision in 3 another BIPA case that cited and adopted the Court’s construction of the statute on the question of 4 who counts as an “aggrieved” person with a right of action under the statute. See Rosenbach v. Six 5 Flags Entm’t Corp., 129 N.E.3d 1197 (Ill. 2019). 6 The settlement of the case was its own long chapter in this litigation. Three days before a 7 trial setting conference, the parties advised that a settlement in principle had been reached. Dkt. 8 No. 427. The Court denied preliminary approval of the initial settlement proposal over concerns 9 about the discount on statutory damages under the BIPA, a conduct remedy that did not appear to 10 require meaningful changes by Facebook, over-broad releases by the class, and the form of notice 11 to class members. Dkt. No. 456. 12 The parties responded substantively to the Court’s concerns. After another round of 13 negotiations, they revised the proposed settlement in several significant ways. To start, Facebook 14 agreed to increase its settlement payment by $100 million, which brought the total amount of the 15 non-reversionary common fund to $650 million. The settlement administration expenses, taxes, 16 and class representative incentive awards and attorney’s fees and costs will be paid from this fund, 17 and the balance will be distributed on a pro rata basis to each class member who submits a valid 18 claim. Dkt. No. 468, Ex. A at 10 (¶ 1.31). The parties also clarified the changes that Facebook 19 will implement. For all users who have not affirmatively opted in or consented to biometric scans, 20 Facebook will set its “Face Recognition” default user setting to “off,” and it will delete all existing 21 and stored face templates for class members unless Facebook obtains a class member’s express 22 consent after a separate disclosure about how Facebook will use the face templates. Id. at 13-14 23 (¶ 2.9). It will also delete the face templates of any class members who have had no activity on 24 Facebook for three years. Id. at 14 (¶ 2.9(c)). At the preliminary approval hearing, Facebook’s 25 product manager for the Face Recognition program stated under oath that this change to the Face 26 Recognition default setting to “opt in” would be not just in Illinois or the United States, but 27 “global.” Dkt. No. 470 at 10:11-17. 1 For the notice and claims procedures, the parties maximized outreach to class members by 2 leveraging Facebook’s direct access to users and using other internet channels. Facebook advised 3 the Court that it would deploy “the most aggressive methods that we use to reach users in the ways 4 that we best can at Facebook,” and the Court further encouraged the parties to optimize outreach 5 by consulting a behavioral economist or psychologist to provide expert advice on techniques. Dkt. 6 No. 470 at 19:19-21; 25:13-25. The claim form was easy to complete online or by mail, and 7 required only basic information about class members’ Facebook accounts, and in the event their 8 email address was not found in Facebook’s records, the class member’s “approximate dates and 9 addresses where you lived in Illinois” for at least 6 months during the class period. See Dkt. 10 No. 468, Ex. A (Ex. A). Class members had their choice of four payment options: paper check, 11 Zelle, PayPal, or direct deposit. Id. These measures generated a claims rate of approximately 12 22%, a result that vastly exceeds the rate of 4-9% that is typical for consumer class actions. See 13 Fed.

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Bluebook (online)
In re Facebook Biometric Information Privacy Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-facebook-biometric-information-privacy-litigation-cand-2021.