Logan v. Meta Platforms, Inc.

CourtDistrict Court, N.D. California
DecidedOctober 25, 2022
Docket3:22-cv-01847
StatusUnknown

This text of Logan v. Meta Platforms, Inc. (Logan 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
Logan v. Meta Platforms, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 DON RAMEY LOGAN, Case No. 22-cv-01847-CRB

9 Plaintiff,

ORDER GRANTING MOTION TO 10 v. DISMISS

11 META PLATFORMS, INC., 12 Defendant.

13 I. BACKGROUND 14 Plaintiff Don Logan initiated this suit as a putative class action against Defendant 15 Meta Platforms, Inc. (“Meta”), asserting various copyright-related claims revolving around 16 Facebook’s embedding tool. Logan’s First Amended Complaint (“FAC”) (dkt. 18) sets 17 forth three sets of factual allegations. First, Logan alleges that Facebook’s embedding tool 18 enables third parties to infringe his copyrighted photos uploaded onto his Facebook 19 account by embedding them to third-party websites. Logan argues that Meta, by providing 20 the tool, is secondarily liable for the infringement. Second, Logan alleges that Meta itself 21 directly infringed his photos by embedding them from other websites onto Facebook and 22 saving them on Facebook’s servers. Third, Logan brings claims under the Lanham Act, 15 23 U.S.C. § 1125(a), and the Digital Millennium Copyright Act (“DMCA”), 17 U.S.C. 24 § 1202, alleging that Meta removed his copyright information from his photos and 25 replaced it with information misrepresenting the photos as its own. 26 Meta moves to dismiss the FAC. The Court, finding this mater suitable for 27 resolution without oral argument pursuant to Civil Local Rule 7-1(b), GRANTS the A. Factual Background 1 1. Two Types of Embedding 2 Broadly, Logan alleges that Meta is liable for two types of embedding activity: (1) 3 third parties embedding content from Facebook users’ pages onto third-party websites, and 4 (2) Meta embedding content from other websites onto Facebook. 5 Generally, embedding is a process that enables websites to incorporate other 6 websites’ original content—“links, images, video, gifs and other content”—onto their own 7 sites. FAC ¶¶ 3, 35. For example, Facebook users can upload original content onto 8 Facebook; the content is stored on Facebook’s servers1 and assigned “unique hypertext 9 markup language (‘HTML’) code.”2 Id. ¶ 3. Non-Facebook users can use other websites’ 10 embedding function to “add” the Facebook content’s corresponding HTML code to the 11 third-party website. Id. ¶ 33; Mot. (dkt. 23) at 3. The “embed” code “directs the [third- 12 party] browser to the Facebook servers to retrieve the photo or video,” allowing the 13 external website to display the photo or video hosted on Facebook’s servers. FAC ¶¶ 33, 14 35; Mot. at 3. 15 The FAC also alleges that Meta itself can embed content from third-party websites 16 onto Facebook. FAC ¶¶ 3, 18, 33, 35. According to the FAC, the embedding website— 17 whether a third-party website or Facebook—can save the embedded content onto its own 18 server using the “same [embedding] route,” should it choose to do so. See id. ¶¶ 3, 33, 35. 19 Meta owns a “unique script tool known as ‘safe image.php’ that it [allegedly] uses to take 20 URL[s] and store them on Facebook’s servers.” Id. ¶ 20. 21 2. The Complaint’s Factual Allegations 22 Logan is a California resident and Facebook user. Id. ¶ 4. He is also the creator 23 and copyright owner of various “high-quality photographs” that depict scenic or landmark 24 coastal areas around the country. Id. ¶¶ 4, 56. Meta is a Delaware company headquartered 25 26 1 “A server is . . . a computer connected to the Internet.” Mot. at 3. 27 2 “The HTML code allows for the arrangement of text and/or images and/videos on a page . . . . 1 in Menlo Park, California, and the parent company of Facebook, Inc. (“Facebook”). Id. 2 ¶ 5. Facebook “is a social media and social networking service company” that operates 3 through the Internet. Id. ¶ 1. 4 a. Meta’s Indirect Infringement Through Facebook’s Embedding Tool 5 At an unspecified point in time, Logan created a Facebook account and agreed to 6 Meta’s Terms of Use.3 Id. ¶¶ 4, 46; Mot. at 2. Under the Terms of Use, users grant Meta 7 “a nonexclusive license to publicly reproduce and display the content the user uploads to 8 Facebook.” Mot. at 2; see also Declaration of Annie A. Lee (dkt. 23-1) ¶ 2; Ex. 1 (dkt. 23- 9 2). Logan then began posting photos on his presumably public Facebook account. FAC 10 ¶ 4; see Mot. at 3 (“Only public posts can be embedded; private posts cannot.”). 11 On July 1, 2013, Facebook introduced its embedding tool. FAC ¶ 72. The tool 12 allows any third-party website to embed images from Logan’s Facebook account onto its 13 own site. Id. ¶¶ 32–34, 38–47, 54–56, 58–66. Logan alleges that third-party websites 14 embedded various of his copyrighted photos, including “some” unspecified photos from a 15 list of twenty-six photos provided in the FAC. Id. ¶ 56. Logan further alleges that third 16 parties infringed his exclusive copyright rights by embedding photos from his Facebook 17 account to external websites “all over the internet.” Id. ¶¶ 3, 43. 18 b. Meta’s Direct Infringement by Embedding Photos from 19 Wikimedia Commons 20 Logan separately alleges that at an unspecified point in time, Meta itself embedded 21 and thereafter displayed some of Logan’s photos from Wikimedia Commons 22 (“Wikimedia”) and saved them onto Facebook’s servers. Id. ¶¶ 1, 3, 17–20, 22–30, 37, 41, 23 3 In reviewing a motion to dismiss, “[a] court may . . . consider . . . documents incorporated by 24 reference in the complaint.” United States v. Ritchie, 342 F.3d 903, 908 (9th Cir. 2003); see also 25 Tellabs, Inc. v. Makor Issues & Rts., Ltd., 551 U.S. 308, 322. Documents are subject to incorporation by reference if the plaintiff refers to them “extensively,” or they form the basis of 26 the complaint. Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1002 (9th Cir. 2018). The FAC alleges that “Facebook[’s] terms of use implied to Plaintiff and members of the Class that 27 Facebook would not allow unauthorized use of copyrighted works through its ‘embed’ feature.” 1 56; see also id. ¶ 22 n.1 (providing the link of a Newport Beach photo originally posted on 2 Wikimedia and allegedly saved onto Facebook’s servers). Logan published the photos on 3 Wikimedia under a “Creative Commons” license, which permits licensees to “reproduce, 4 publicly display and distribute copies” of the photos under certain restrictions, including 5 attributing Logan as the author. Id. ¶¶ 25–26. Logan alleges that Meta stripped the photos 6 of all identifying information and falsely identified itself as the owner by displaying its 7 “copyright tag on the bottom of each Facebook user page,” contravening the Creative 8 Commons license. Id. ¶¶ 3, 17–20, 48–50. 9 B. Procedural Background 10 Logan filed the Complaint on February 16, 2022, in the Southern District of New 11 York. Compl. (dkt. 1). On March 21, 2022, the parties stipulated to transfer the action to 12 this District. Stipulation and Order (dkt. 9). On March 24, 2022, the Clerk of Court 13 transferred the case to this District and assigned it to Judge Gonzalez Rogers. District 14 Transfer (dkt. 11). On April 5, 2022, the Court ordered the case related to Hunley v. 15 Instagram, LLC, 3:21-cv-03778-CRB,4 and reassigned the case to this Court. Order 16 Relating Case (dkt. 14); Case Reassigned (dkt. 15). 17 On May 16, 2022, Logan filed the FAC. The FAC asserts the following claims: (1) 18 Lanham Act false advertising under 15 U.S.C.

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Logan v. Meta Platforms, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/logan-v-meta-platforms-inc-cand-2022.