Michael Eskenasy v. LinkedIn Corporation, et al.

District Court, N.D. California·Decided July 8, 2026·No. 5:26-cv-06047·Unknown

Opinion

MICHAEL ESKENASY, Case No. 26-cv-06047-VKD

Plaintiff, ORDER GRANTING APPLICATION TO PROCEED IN FORMA PAUPERIS; v. STAYING SERVICE OF PROCESS; AND SCREENING COMPLAINT LINKEDIN CORPORATION, et al., PURSUANT TO 28 U.S.C. § 1915 Defendants. Re: Dkt. Nos. 1, 2

On June 18, 2026, plaintiff Michael Eskenasy, who is representing himself, filed a complaint and application to proceed in forma pauperis (“IFP”). Dkt. Nos. 1, 2. The Court grants Mr. Eskenasy’s IFP application. Having screened Mr. Eskenasy’s complaint pursuant to 28 U.S.C. § 1915(e), however, the Court finds that the complaint fails to state sufficient facts supporting federal subject matter jurisdiction and fails to state a claim for relief. The Court stays service of process and gives Mr. Eskenasy until August 7, 2026 to file an amended complaint that addresses the deficiencies identified in this order. If Mr. Eskenasy fails to file an amended complaint in time, or if the amended complaint fails to cure the defects described in this order, the Court may issue an order reassigning the case to a district judge with a recommendation that the complaint be dismissed for lack of federal subject matter jurisdiction and failure to state a claim. A court may allow a plaintiff to prosecute an action in federal court without prepayment of fees or security if the plaintiff submits an affidavit showing that he or she is unable to pay such the payment of the filing fee whenever it determines that the action “(i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B)(i)-(iii). The screening requirement of § 1915(e) applies to all in forma pauperis complaints, not just those filed by prisoners. Calhoun v. Stahl, 254 F.3d 845 (9th Cir. 2001) (“[T]he provisions of 28 U.S.C. § 1915(e)(2)(B) are not limited to prisoners.”); Castro v. Pascual, No. 20-cv-01090-BLF, 2020 WL 733127, at *1 (N.D. Cal. Feb. 13, 2020) (same). Mr. Eskenasy’s IFP application indicates that he satisfies the economic eligibility requirement of 28 U.S.C. § 1915. The Court therefore grants his IFP application. A. Legal Standard While pro se pleadings are liberally construed, a complaint does not state a claim if it fails to set forth “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007); see also Fed. R. Civ. P. 12(b)(6). A complaint must include facts that are “more than labels and conclusions, and formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Only plausible claims for relief will survive a motion to dismiss. Id. at 679. A claim is plausible if the facts pled permit the court to draw a reasonable inference that the defendant is liable for the alleged misconduct. Id. As a threshold matter, the Court must examine whether it has jurisdiction over the claims alleged before considering whether the complaint states any claims on which relief may be granted. See Sinochem Int’l Co. v. Malaysia Int’l Shipping Corp., 549 U.S. 422, 430-31 (2007) (“[A] federal court generally may not rule on the merits of a case without first determining that it has jurisdiction over the category of claim in suit (subject-matter jurisdiction) and the parties (personal jurisdiction).”). B. Mr. Eskenasy’s Claims Human Cognitive Infrastructure system and body of work focused on context preservation, coordination, memory, judgment, professional execution, and the operational problem created by fragmented digital tools and platforms.” Dkt. No. 1 ¶ 3. Defendants are LinkedIn Corporation (“LinkedIn”), Microsoft Corporation (“Microsoft”), and 25 Doe defendants. Id. ¶¶ 21-27. Mr. Eskenasy alleges that he “observed third-party LinkedIn content that appeared relevant to authorship, provenance, framework, terminology, language, or comparison issues involving ChefreyOS and Human Cognitive Infrastructure.” Id. ¶ 5. Mr. Eskenasy alleges that the record “raises a serious authorship/provenance concern.” Id. ¶ 8. Mr. Eskenasy further alleges that when he “attempted to address the authorship/provenance concern, [p]laintiff encountered LinkedIn account-access friction.” Id. ¶ 66. Specifically, Mr. Eskenasy claims that LinkedIn temporarily restricted his access to his LinkedIn account and made him undergo “a security check” and “identity verification as a condition of account access.” See id. ¶¶ 67-74. He further alleges that he encountered errors when attempting to verify his identity. Id. ¶¶ 75-79. Mr. Eskenasy alleges that LinkedIn’s identity verification process “imposed a sensitive burden on [p]laintiff and created a barrier to account access.” Id. ¶ 83. According to the complaint, Mr. Eskenasy “does not allege at this stage that copying, theft, misappropriation, retaliation, suppression, or intentional misconduct has already been proven,” and he “does not allege as established fact that LinkedIn intentionally suppressed, shadow-banned, or visibility-limited [p]laintiff.” Id. ¶¶ 7, 86; see also id. ¶¶ 190-200. Rather, Mr. Eskenasy claims that he “brings this action to preserve the record” and that LinkedIn’s and Microsoft’s records are “necessary to determine what happened.” Id. ¶¶ 8, 16. Mr. Eskenasy alleges that Microsoft, as the parent or corporate affiliate of LinkedIn, “may possess, control, receive, govern, supervise, access, or have remediation authority over relevant LinkedIn systems, data, records, policies, affiliate systems, infrastructure, account systems, identity-verification systems, legal systems, support systems, or platform governance.” Id. ¶ 23. The complaint asserts ten claims: (1) breach of contract against LinkedIn; (2) breach of implied covenant of good faith and fair dealing against LinkedIn; (3) violation of California’s declaratory relief against LinkedIn and Microsoft; (5) injunctive and equitable relief against LinkedIn and Microsoft; (6) equitable record review/accounting/preservation against LinkedIn and Microsoft; (7) negligent platform process/negligent handling against LinkedIn; (8) negligence/equitable relief regarding identity-verification process against LinkedIn and Doe defendants; (9) business, professional, and reputational harm according to proof against LinkedIn and Microsoft; and (10) protection of confidential ChefreyOS materials. Id. at 6-10. Mr. Eskenasy seeks damages, declaratory relief, injunctive relief, and pre- and post- judgment interest. Id. at 10-11.1 C. Subject Matter Jurisdiction For a case to proceed in federal court, the Court must have subject matter jurisdiction over the claims alleged. “It is a fundamental precept that federal courts are courts of limited jurisdiction.” Owen Equip. & Erection Co. v. Kroger, 437 U.S. 365

Michael Eskenasy v. LinkedIn Corporation, et al., (N.D. Cal. 2026).

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