Rodriguez v. Ford Motor Company

CourtDistrict Court, S.D. California
DecidedDecember 3, 2024
Docket3:23-cv-00598
StatusUnknown

This text of Rodriguez v. Ford Motor Company (Rodriguez v. Ford Motor Company) 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
Rodriguez v. Ford Motor Company, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 REBEKA RODRIGUEZ, Case No.: 3:23-cv-00598-RBM-JLB 12 Plaintiff,

13 v. ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S 14 FORD MOTOR COMPANY, a Delaware MOTION TO DISMISS Corporation d/b/a www.ford.com, 15 Defendant. [Doc. 23] 16 17 18 On April 16, 2023, Plaintiff Rebeka Rodriguez (“Plaintiff”), individually and on 19 behalf of all others similarly situated, filed a First Amended Class Action Complaint 20 (“FAC”) for violations of the California Invasion of Privacy Act (“CIPA”), California 21 Penal Code section 630 et. seq., against Defendant Ford Motor Company (“Defendant”). 22 (Doc. 6.) In her FAC, Plaintiff alleged two causes of action for violations of CIPA sections 23 631(a) and 632.7. (Id. at 7–11.) 24 In its March 21, 2024 Order granting Defendant’s motion to dismiss Plaintiff’s FAC 25 (“March 21, 2024 Order”), the Court dismissed Plaintiff’s claims against Defendant for 26 direct liability under CIPA section 631(a) with prejudice (see Doc. 21 at 10, 31) but 27 dismissed Plaintiff’s claims against Defendant for “aiding and abetting” under clause four 28 of CIPA section 631(a) without prejudice (see id. at 11–27, 31). The Court also dismissed 1 Plaintiff’s claim against Defendant for liability under CIPA section 632.7 without 2 prejudice. (See id. at 27–31.) 3 On April 5, 2024, Plaintiff filed a Second Amended Class Action Complaint for 4 Violation of CIPA (“SAC”). (Doc. 22.) In her SAC, Plaintiff alleges one cause of action 5 for violations of CIPA section 631(a). (Id. at 10–12.) 6 On April 19, 2024, Defendant filed a Motion to Dismiss Plaintiff’s SAC (“Motion”). 7 (Doc. 23.) On May 13, 2024, Plaintiff filed a Response in Opposition to Defendant’s 8 Motion (“Opposition”). (Doc. 24.) On May 20, 2024, Defendant filed a Reply in Support 9 of its Motion (“Reply”). (Doc. 25.) 10 The Court finds this matter suitable for determination on the papers and without oral 11 argument pursuant to Civil Local Rule 7.1(d)(1). For the reasons set forth below, 12 Defendant’s Motion is GRANTED IN PART and DENIED IN PART. 13 I. BACKGROUND1 14 In early 2023, Plaintiff visited Defendant’s website, www.ford.com (the “Website”), 15 using a smart phone—“a cellular telephone with integrated computers to enable web 16 browsing”—and had a brief conversation with a customer service representative using the 17 chat feature on the Website. (SAC ¶¶ 4, 31.) “Plaintiff was not advised that the chat was 18 monitored, intercepted, or recorded.” (Id. ¶¶ 4, 32–33.) 19 Unbeknownst to Plaintiff, Defendant enables and allows LivePerson, Inc. 20 (“LivePerson”), an independent third party, to eavesdrop upon and record all such 21 conversations and then “secretly intercept, exploit, and monetize the chat conversations 22 ….” (Id. ¶¶ 9, 11.) “LivePerson’s chat service is an Application Programming Interface 23 that is ‘plugged into’ Defendant’s Website. The chat function runs from the LivePerson’s 24 servers … . … LivePerson runs the Chat service from its own servers, but customers 25 interact with the chat service on Defendant’s Website ….” (Id. ¶ 12.) “Whenever a chat 26

27 1 The Court’s summary of Plaintiff’s allegations reflects Plaintiff’s factual and legal 28 1 message is sent … to Defendant, it is first routed through LivePerson’s server. This enables 2 LivePerson to analyze and collect customer-support agent interactions in real time to create 3 live transcripts of communications as they occur, among other services.” (Id. ¶ 13.) 4 “LivePerson’s product is a type of automatic routing software that automatically 5 acquires and transmits user chat communications to LivePerson without any active input 6 from either Defendant’s employees, agents, or human representatives. LivePerson 7 acquires Website visitors’ chat communications by first having its software route them to 8 LivePerson’s own computer servers that it owns, controls, and maintains. The secret code 9 enables and allows LivePerson to secretly intercept in real time, eavesdrop upon, and store 10 transcripts of consumers’ chat communications they think they are having with Defendant 11 only.” (Id. ¶ 14.) 12 “LivePerson has the capability of using the recorded Website chat interactions 13 between Defendant and visitors to the Website for one or more purposes other than to 14 benefit Defendant, a party to such communications.” (Id. ¶ 16.) “LivePerson’s chat 15 software is ‘integrated’ with subsidiaries or divisions of Meta Platforms, Inc. (doing 16 business as ‘Meta’) like Facebook and WhatsApp.” (Id. ¶ 17.) “This integration allows 17 LivePerson to share data with Meta and its subsidiaries, and thus operate as a unified 18 system.” (Id. ¶ 18.) 19 “First, Meta identifies ‘user interests’ by monitoring a collection of ‘offsite’ user 20 activity, such as the private chat communications between Defendant and visitors to its 21 Website by ‘integrating’ with LivePerson’s software. Second, Meta generates revenue by 22 selling advertising space through its subsidiaries’ ability to identify those offsite user 23 interests. Third and finally, after harvesting the chat transcripts for valuable data, Meta’s 24 brands like Facebook and WhatsApp bombard the unsuspecting Website visitors with 25 targeted advertising.” (Id. ¶ 19.) 26 “[A]ll of the schemers – Defendant, LivePerson, and Meta – all profit from secretly 27 exploiting the private chat data through targeted social media advertising because 28 ‘[t]argeted advertising allows brands to send different messaging to different consumers 1 based on what the brand knows about the customer. The better a brand can demonstrate 2 that it understands what its customers want and need, the more likely customers respond to 3 advertising and engage with the brand. Social media targeting helps brands leverage 4 consumers’ behavior on the web, search engines, and social media sites to present ads that 5 reflect consumer interests.’” (Id. ¶ 20.) 6 “LivePerson’s chat transcripts are automatically created and stored by LivePerson 7 for ‘data harvesting’ purposes, which is the process of extracting personal data for business 8 and marketing purposes.” (Id. ¶ 21.) “Indeed, LivePerson has acknowledged on page 15 9 of its Form-10K filing with the U.S. Securities and Exchange Commission for the fiscal 10 year ended December 31, 2017 (‘2017 Form-10K’), that ‘some states in the United States 11 have enacted legislation designed to protect consumer privacy by prohibiting the 12 distribution of ‘spyware’ over the Internet …. If … the scope of the previously mentioned 13 ‘spyware’ legislation were changed to include web analytics, such legislation could apply 14 to the technology we use and potentially restrict our ability to conduct our business.’” (Id. 15 ¶ 22.) “Page 1 of its 2017 Form 10-K states in relevant part, ‘[a]ccording to our internal 16 measures, during 2017, we monitored an average of 2.6 billion visitor sessions per month 17 across our customers’ websites. LivePerson combines this session data with conversational 18 transcripts and other historical, behavioral, and operational information to develop insights 19 into consumer intent and each step of the customer journey, which leads to optimized 20 campaign outcomes for sales and service transactions.’” (Id. ¶ 23.) 21 “The homepage of LivePerson’s website markets LivePerson’s services by stating: 22 ‘[a]nalyze omnichannel conversation data to uncover the wants and needs of your 23 customers. Identify top customer intents and uncover opportunities to continuously 24 improve the customer journey.’ The homepage of LivePerson’s website contains a 25 hyperlink named ‘Learn more about Conversational Intelligence,’ which takes the user to 26 a landing page addressing LivePerson’s ‘Conversational Intelligence’ suite of software.” 27 (Id.

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Rodriguez v. Ford Motor Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-v-ford-motor-company-casd-2024.