Sant v. RocketReach LLC

CourtDistrict Court, W.D. Washington
DecidedJuly 9, 2025
Docket2:24-cv-01626
StatusUnknown

This text of Sant v. RocketReach LLC (Sant v. RocketReach LLC) 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
Sant v. RocketReach LLC, (W.D. Wash. 2025).

Opinion

UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7

8 JOSEPH SANT, et al., Case No. C24-1626-RSM

9 Plaintiffs, ORDER DENYING DEFENDANT’S MOTIONS TO DISMISS AND STRIKE 10 v. CLASS ALLEGATIONS

11 ROCKETREACH LLC,

12 Defendants.

14 I. INTRODUCTION This matter comes before the Court on Defendant RocketReach LLC’s Motions to 15 Dismiss and to Strike Class Allegations, Dkts. #18 and #19. Plaintiffs Joseph Sant, Merton Chun, 16 Ronesha Smith, and Heather Nicastro oppose. Dkts. #25 and #27. For the reasons below, the 17 Court DENIES these Motions. 18 19 II. BACKGROUND The Court draws the following facts and allegations from Plaintiffs’ Complaint, Dkt. #1. 20 See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 21 Defendant’s “world’s largest and most accurate database,” www.rocketreach.co, offers a 22 web-based subscription platform for users to access millions of profiles that contain people’s 23 personal and professional information, as well as other business development services. When a 24 1 user navigates the site, they may see free-preview and free-trial “profile” pages, which provide the name, place of work, education history, skills, and other personal information of a specific 2 person. These profile pages include links to obtain further information on the person, which 3 direct users to subscription options for premium features on the platform, such as Autopilot, 4 Intent Data, and RocketReach for Healthcare. Defendant optimizes the free profile pages to rank 5 highly in search engine results through source code, employing specific people to develop these 6 techniques. Defendant tracks the number of times when and from where these free profile pages 7 are viewed by non-subscribers. Plaintiffs allege: 8 Defendant has built and now reaps significant profit from this business by trading 9 off the names, photographs, personas, and identities of millions of Americans to promote its platform, without obtaining their consent or providing them 10 compensation of any kind.

11 Defendant has done this by publishing millions of free-preview and free-trial “profile” pages which use the names, photographs, email addresses, phone 12 numbers, physical address, employers, educational history, and more about individual Americans to advertise subscriptions to its web-based platform. 13

Dkt. #1 at ¶¶ 14 Plaintiffs Joseph Sant (a Washington resident), Merton Chun (a California resident), 15 Ronesha Smith (an Illinois Resident), and Heather Nicastro (an Ohio resident), whose private 16 information appears on Defendant’s free-preview and free-trial profile pages, filed their class 17 action Complaint against Defendant on October 8, 2024. They bring claims under the 18 Washington Personality Rights Act (“WPRA”), RCW 63.60.050, the California Right of 19 Publicity Law (“CRPL”), Cal. Civ. Code § 3344, the Illinois Right of Publicity Act (“IRPA”), 20 765 Ill. Comp. Stat. 1075, and the Ohio Right of Publicity in Individual’s Persona Act 21 (“ORPIPA”), Ohio Rev. Code Ann. § 2741. 22 On December 27, 2024, Defendants filed a Motion to Compel Arbitration and Stay 23 Proceedings, Dkt. #16, and the instant Motions to Dismiss, Dkt. #18, and to Strike Class 24 1 Allegations, Dkt. #19. The Court denied Defendant’s Motion to Compel Arbitration on July 7, 2025. Dkt. #25. 2 III. DISCUSSION 3 A. Motion to Dismiss 4 Defendant requests that the Court dismiss Plaintiff’s claims for lack of standing and 5 failure to state a claim. Dkt. #18. 6 1. Legal Standard 7 a. Standing 8 Pursuant to Article III of the US. Constitution, federal courts have limited jurisdiction to 9 hear only live “cases” and “controversies.” Lujan v. Defenders of Wildlife, 504 U.S. 555, 559 10 (192); U.S. CONST. art III, § 2. Accordingly, “Article III standing is a necessary component of 11 subject matter jurisdiction.” In re Palmdale Hills Prop., LLC, 654 F.3d 868, 873 (9th Cir. 2011). 12 To satisfy the case-or-controversy requirement, “a plaintiff must show (1) it has suffered an 13 ‘injury in fact’ that is (a) concrete and particularized and (b) actual or imminent, not conjectural 14 or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and 15 (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable 16 decision.” Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167, 180-81 17 (2000). When a plaintiff lacks standing, dismissal under Federal Rule of Civil Procedure 12(b)(1) 18 is appropriate. See Maya v. Centex Corp., 658 F.3d 1060, 1067 (9th Cir. 2011); Walsh v. 19 Microsoft Corp., 63 F. Supp. 3d 1312, 1317-18 (W.D. Wash. 2014). 20 A motion to dismiss under Rule 12(b)(1) can attack the factual allegations establishing 21 standing or can attack plaintiff’s standing facially. Leite v. Crane Co., 749 F.3d 1117, 1121 (9th 22 Cir. 2014). “The district court resolves a facial attack as it would a motion to dismiss under 23 12(b)(6): Accepting the plaintiff’s allegations as true and drawing all reasonable inferences in 24 1 the plaintiff’s favor, the court determines whether the allegations are sufficient as a legal matter to invoke the court’s jurisdiction.” Id. at 1121 (citing Pride v. Correa, 719 F.3d 1130, 1133 (9th 2 Cir. 2013)). At the pleading stage, a plaintiff need not satisfy Iqbal/Twombly’s1 plausibility 3 standard but “must ‘clearly . . . allege facts demonstrating’ each element” of standing. Spokeo, 4 Inc. v. Robins, 578 U.S. 330, 338 (2016) (citing Warth v. Seldin, 422 U.S. 490, 518 (1975)). As 5 such, the inquiry does not touch directly on the merits of the plaintiff’s case. See Maya, 658 F.3d 6 at 1068 (contrasting with consideration of a Rule 12(b)(6) motion which “necessarily assesses 7 the merits of the plaintiff’s case”). “In a class action, standing is satisfied if at least one named 8 plaintiff meets the requirements.” Bates v. United Parcel Serv., Inc., 511 F.3d 974, 985 (9th Cir. 9 2007). 10 b. Rule 12(b)(6) 11 In making a 12(b)(6) assessment, the court accepts all facts alleged in the complaint as 12 true and makes all inferences in the light most favorable to the non-moving party. Baker v. 13 Riverside County Office of Educ., 584 F.3d 821, 824 (9th Cir. 2009) (internal citations omitted). 14 However, the court is not required to accept as true a “legal conclusion couched as a factual 15 allegation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 555 16 (2007)).

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Bluebook (online)
Sant v. RocketReach LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sant-v-rocketreach-llc-wawd-2025.