Jensen v. Capital One Financial Corporation

CourtDistrict Court, W.D. Washington
DecidedFebruary 25, 2025
Docket2:24-cv-00727
StatusUnknown

This text of Jensen v. Capital One Financial Corporation (Jensen v. Capital One Financial Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jensen v. Capital One Financial Corporation, (W.D. Wash. 2025).

Opinion

1 2 3

4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 TAMIE JENSEN, CASE NO. C24-0727-KKE 8

Plaintiff(s), ORDER DENYING DEFENDANT’S 9 v. MOTION TO DISMISS AND/OR STRIKE

10 CAPITAL ONE FINANCIAL CORPORATION, 11

Defendant(s). 12

Plaintiff Tamie Jensen received a text message from a contact, containing content prepared 13 by Defendant Capital One Financial Corporation as part of its “Refer a Friend” credit-card 14 promotion. Dkt. No. 1 ¶ 38. Jensen filed this lawsuit against Capital One, claiming that the 15 transmission of this commercial text message violates Washington’s Commercial Electronic Mail 16 Act (“CEMA”) and therefore violates Washington’s Consumer Protection Act (“CPA”) as well. 17 Id. ¶¶ 49–74. 18 Capital One filed a motion to dismiss, contending that Jensen’s claims fail for a number of 19 reasons: (1) because Capital One is immune under Section 230 of the Communications Decency 20 Act (“CDA”) from liability for text messages it did not directly send; (2) because Jensen’s claims 21 seek to interfere with Capital One’s power to advertise and market its credit cards, and are therefore 22 preempted by the National Bank Act (“NBA”); and (3) because Jensen has failed to state a CEMA 23 claim because she has failed to allege that Capital One either initiated the text message or 24 1 substantially assisted in transmitting the message. Dkt. No. 15 at 16–29.1 The Court rejects each 2 of these contentions and will therefore deny Capital One’s motion to dismiss. 3 Capital One’s motion also contains a request to strike Jensen’s class allegations because 4 the proposed class lacks commonality and is improperly defined in “fail-safe” terms. Dkt. No. 15 5 at 29–33. Although the Court is sympathetic to Capital One’s concerns, the Court declines to rule 6 at this time that, as a matter of law, this case cannot be maintained as a class action. Rather, the 7 Court will consider this issue as necessary at the class-certification stage. 8 Accordingly, the Court will deny Capital One’s motion to dismiss and motion to strike. 9 I. BACKGROUND2 10 Capital One is a banking company that offers, among other things, credit cards, and 11 promotes its credit cards via a “Refer a Friend” program. Dkt. No. 1 ¶ 14. The “Refer a Friend” 12 program asks existing credit cardholders to send a text message to their contacts that includes a

13 referral link created by Capital One. Id. ¶ 15. If the friend uses the link to sign up for a credit 14 card, the sender receives a bonus award. Id. 15 The “Refer a Friend” program can be accessed via Capital One’s mobile app or its website. 16 Dkt. No. 1 ¶¶ 16, 18. If users click the referral button on either the app or the website, Capital One 17 then generates a referral link, composes an editable text message, and directs the user to copy and 18 paste that message with the link to their contacts. Id. ¶¶ 16–21. On the app, underneath the referral 19 button reads: “You confirm you have consent to send text messages to each recipient. You may 20 edit the pre-filled message as desired.” Id. ¶ 34. The website referral button is not accompanied 21 22

23 1 This order refers to the parties’ briefing using CM/ECF page numbers.

2 The background facts are taken from the complaint (Dkt. No. 1) and assumed to be true for purposes of this 24 motion. 1 by these statements nor is there any other reference to consent on the website version of the “Refer 2 a Friend” program. Id. 3 Jensen received a “Refer a Friend” text from one of her contacts, and responded “Stop

4 sending me these.” Dkt. No. 1 ¶ 39. The text message she received had not been edited by her 5 contact before she received it; it contained only the pre-filled content composed by Capital One. 6 Id. ¶ 40. She filed this putative class-action lawsuit on behalf of herself and others who received 7 a “Refer a Friend” text message to their cell phone number while residing in Washington without 8 having given advance clear and affirmative consent. See id. ¶ 42. 9 Capital One filed a motion to dismiss and/or strike the class allegations. Dkt. No. 15. After 10 considering the parties’ briefing and the oral argument of counsel, the Court denies the motion for 11 the following reasons. 12 II. ANALYSIS

13 A. Legal Standards on a Motion to Dismiss for Failure to State a Claim 14 In evaluating a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a court 15 examines the complaint to determine whether, assuming the facts alleged are true, the plaintiff has 16 stated “a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) 17 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is plausible if the plaintiff 18 pleads “factual content that allows the court to draw the reasonable inference that the defendant is 19 liable for the misconduct alleged.” Id. 20 B. Capital One Is Not Entitled to Immunity Under Section 230 of the CDA.

21 “Section 230 of the CDA immunizes providers of interactive computer services against 22 liability arising from content created by third parties[.]” Fair Hous. Council of San Fernando 23 Valley v. Roommates.Com, LLC, 521 F.3d 1157, 1162 (9th Cir. 2008) (footnotes omitted). 24 Specifically, the CDA provides that “[n]o provider or user of an interactive computer service shall 1 be treated as the publisher or speaker of any information provided by another information content 2 provider,” and expressly preempts any contrary state law. 47 U.S.C. §§ 230(c)(1), (e)(3). “The 3 majority of federal circuits have interpreted the CDA to establish broad ‘federal immunity to any

4 cause of action that would make service providers liable for information originating with a third- 5 party user of the service.’” Perfect 10, Inc. v. CCBill LLC, 488 F.3d 1102, 1118 (9th Cir. 2007) 6 (quoting Almeida v. Amazon.com, Inc., 456 F.3d 1316, 1321 (11th Cir. 2006)). 7 The “two basic policy reasons” for Section 230 immunity are “to promote the free 8 exchange of information and ideas over the Internet and to encourage voluntary monitoring for 9 offensive or obscene material.” Carafano v. Metrosplash.com, Inc., 339 F.3d 1119, 1122 (9th Cir. 10 2003). 11 In passing section 230, Congress sought to … allow[] [interactive computer services] to perform some editing on user-generated content without thereby 12 becoming liable for all defamatory or otherwise unlawful messages that they didn’t edit or delete. In other words, Congress sought to immunize the removal of user- 13 generated content, not the creation of content[.]

14 Roommates, 521 F.3d at 1163. The text of Section 230 itself explains that it is the “policy of the 15 United States” “to promote the continued development of the Internet and other interactive 16 computer services[,]” “to preserve the vibrant and competitive free market that presently exists for 17 the Internet and other interactive computer services,” and “to remove disincentives for the 18 development and utilization of blocking and filtering technologies that empower parents to restrict 19 their children’s access to objectionable or inappropriate online material[.]” 47 U.S.C.

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