L.W. v. Snap Inc.

CourtDistrict Court, S.D. California
DecidedJune 5, 2023
Docket3:22-cv-00619
StatusUnknown

This text of L.W. v. Snap Inc. (L.W. v. Snap Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
L.W. v. Snap Inc., (S.D. Cal. 2023).

Opinion

7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9

10 L.W., minor child through her legal Case No.: 22cv619-LAB-MDD 11 guardian Jane Doe, on behalf of 12 herself and all others similarly ORDER: situated; et al., 13 (1) GRANTING MOTIONS TO Plaintiffs, 14 DISMISS FIRST AMENDED v. COMPLAINT [Dkt. 51, 53, 54]; 15

SNAP INC.; et al. 16 (2) DENYING AS MOOT Defendants. MOTION TO STRIKE 17 ALLEGATIONS [Dkt. 52]; 18 (3) GRANTING MOTION TO 19 SEAL [Dkt. 64]; AND 20 (4) DENYING MOTION FOR 21 RULE 11 SANCTIONS [Dkt. 67] 22 23 Minor Plaintiffs L.W., C.A., and C.O. (collectively, “Plaintiffs”) commenced 24 this suit against Defendants Snap Inc. (“Snap”), Apple Inc. (“Apple”), and 25 Google LLC (“Google”) (collectively, “Defendants”) for claims stemming from 26 allegations that Snap’s Snapchat application, available for download through the 27 Apple Store and Google Play, is an inherently dangerous software product that 28 Defendants deceptively advertise and promote in a way that facilitates sex crimes 1 against children. Plaintiffs’ First Amended Complaint (“FAC”) asserts ten causes 2 of action against Defendants, including for product liability, fraudulent and 3 negligent misrepresentation, and violation of various state consumer protection 4 laws. 5 Defendants separately filed motions to dismiss the FAC, (Dkt. 51, 53, 54), 6 and Defendant Apple also filed a Motion to Strike Class Allegations, (Dkt. 52). On 7 November 15, 2022, the Court held a hearing on the respective motions to 8 dismiss. Defendant Snap filed a Motion for Rule 11 Sanctions against Plaintiffs, 9 citing certain offending allegations made in the FAC, (Dkt. 67), and requesting 10 further that the Motion for Sanctions be sealed, (Dkt. 64). The Court determined 11 the latter motions would be decided on the papers. (Dkt. 77). 12 The Court has read all materials submitted in support of and in opposition 13 to the respective motions, and rules as follows. 14 I. BACKGROUND 15 Snapchat is a “a widely popular photo sharing application” that allows users 16 to exchange photos and messages and engage in video chats with one another. 17 (FAC ¶ 83). A distinguishing feature of Snapchat is its ephemeral 18 nature—meaning communications automatically disappear after being opened. 19 (Id. ¶ 86). Users can connect with one another by either searching for another 20 user and requesting to add them as a “friend,” or by using the “Quick Add” 21 function, which “suggests that a user add another user as a friend . . . based on 22 who you’re already friends with, who you subscribe to, and other factors.” (Id. 23 ¶ 76). Snapchat can be downloaded on users’ mobile phones through the Apple 24 Store or Google Play, which are “digital distribution platform[s] where individuals 25 can buy and download digital software and applications,” like Snapchat. (Id. 26 ¶¶ 135, 151). 27 When Plaintiff L.W. was 12 years old, “on or about” September 5, 2018, 28 adult Perpetrator B.P. first approached her on Instagram. (Id. ¶¶ 2–3). B.P. asked 1 L.W. to connect with him on Snapchat, and began conversing with her regularly. 2 (Id. ¶¶ 3–4). On September 11, 2018, B.P. “demanded” a nude photograph from 3 L.W. and sent her a picture of his erect penis. (Id. ¶ 6). Over the next two-and-a- 4 half years, and through April 15, 2021, B.P. sexually groomed L.W. by 5 “manipulat[ing] and coerc[ing] her” to send him pornographic images and videos 6 of herself over Snapchat. In turn, he sent her hundreds of pornographic photos 7 and videos of himself. (Id. ¶¶ 7,11). Although L.W. tried to block B.P. on numerous 8 occasions, he was able to resume contact through Instagram or a fake account 9 and ask L.W. to reconnect with him on Snapchat until she yielded to his request. 10 (Id. ¶ 13). Further, B.P. used the app Chitter to distribute the Child Sexual Abuse 11 Material (“CSAM”) of L.W. to others. (Id. ¶¶ 21–23). “B.P. admitted that he solely 12 used Snapchat with L.W.—and not any other social media platform—to gain new 13 CSAM and transmit his pornographic images and videos to her because he 14 ‘kn[e]w the chats [would] go away’ on Snapchat.” (Id. ¶ 14). 15 Plaintiff C.A. was also 12 years old when, in 2021, an adult “perpetrator,” 16 connected with her on Twitter. (Id. ¶¶ 43–44, 47). “The perpetrator 17 [then] . . . connected with her on [S]napchat.” (Id. ¶ 45). The perpetrator had been 18 “charged with serious sexual crimes against minor victims,” but “Snapchat 19 enabled him to make a new account without any issues,” and “[u]pon information 20 and belief . . . knew that this sex offender was using its platform but failed to stop 21 him.” (Id. ¶¶ 49–50). The perpetrator proceeded to request CSAM from C.A. and 22 sent her CSAM depicting other minors, and through manipulation and coercion, 23 obtained 20 to 30 sexually explicit pictures and 10 or 15 sexually explicit videos 24 from her. (Id. ¶¶ 51–54). In March 2021, the perpetrator travelled to C.A.’s state 25 and pressured her to engage in sexual acts with him, which he filmed and later 26 distributed online. (Id. ¶¶ 54–55). “In April 2021, another perpetrator connected 27 with C.A. on Kik, a social media app,” and asked to move their conversations to 28 Snapchat. (Id. ¶¶ 59–60). “On Snapchat, the second perpetrator sent C.A. explicit 1 photos and videos” of himself for the next several weeks. (Id. ¶¶ 61–62). 2 Plaintiff C.O. was 11 years old when, in 2018, a “perpetrator” connected with 3 her on Omegle, “an online video chat room,” and asked for her username. He later 4 connected with her on Snapchat. (Id. ¶¶ 69–70). On Snapchat, the perpetrator 5 pretended to be a minor girl, requested CSAM from C.O., and sent her CSAM 6 from other minors. C.O. eventually sent him nude photographs of herself. (Id. 7 ¶¶ 72–73). “Since 2018 four or five additional perpetrators sought to connect with 8 C.O.[] on Snapchat”—some through Quick Add—“and similarly coerced her to 9 send nude photos and CSAM,” as well as sent her sexually explicit photos and 10 videos of themselves. (Id. ¶¶ 74–75, 77). Upon information and belief,” these 11 perpetrators “downloaded Snapchat using Apple’s and Google’s App Stores.” 12 (Id. ¶¶ 38, 67, 79). 13 Plaintiffs allege ten claims against all three Defendants: (1) strict liability 14 product design and defect; (2) strict product liability (failure to warn); 15 (3) negligence and negligence per se product design and defect; (4) fraudulent 16 misrepresentation and negligent misrepresentation; (5) unjust enrichment; 17 (6) violation of California’s Unfair Competition Law and False Advertising Law; 18 (7) violation of the Colorado Consumer Protection Act; (8) violation of the 19 Kentucky Consumer Protection Act; (9) injunctive relief; and (10) violation of the 20 Trafficking Victims Protection Act (“TVPRA”), 18 U.S.C. §§ 1591, 1595. 21 II. MOTION TO DISMISS 22 A. Legal Standard 23 A motion brought under Federal Rule of Civil Procedure 12(b)(6) tests the 24 sufficiency of a complaint. Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). “To 25 survive a motion to dismiss, a complaint must contain sufficient factual matter, 26 accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft 27 v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 28 544, 547 (2007)). A claim is facially plausible when the factual allegations permit 1 “the court to draw the reasonable inference that the defendant is liable for the 2 misconduct alleged.” Id. While a plaintiff need not give “detailed factual 3 allegations,” a plaintiff must plead sufficient facts that, if true, “raise a right to relief 4 above the speculative level.” Twombly, 550 U.S. at 545.

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