Silver v. Stripe, Inc.

CourtDistrict Court, N.D. California
DecidedJuly 28, 2021
Docket4:20-cv-08196
StatusUnknown

This text of Silver v. Stripe, Inc. (Silver v. Stripe, 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
Silver v. Stripe, Inc., (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JASEN SILVER ET AL., Case No. 4:20-cv-08196-YGR

8 Plaintiffs, ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION TO 9 v. DISMISS PLAINTIFFS’ AMENDED COMPLAINT 10 STRIPE INC.,

Defendant. 11 Re: Dkt. No. 48

12 Plaintiffs Jasen Silver, Jill Lienhard, Patricia Tysinger, Victoria Waters, and Alaina Jones 13 bring this amended class action complaint against defendant Stripe Inc. (“Stripe”) alleging 14 violations of various privacy laws. (Dkt. No. 47.) (“First Amended Complaint” or “FAC.”) 15 Plaintiffs assert nine causes of action: (1) violation of the California Invasion of Privacy Act 16 (“CIPA”) under California Penal Code § 631; (2) violation of CIPA under California Penal Code § 17 635; (3) violation of the Florida Security of Communications Act (“FSCA”), Florida Statutes § 18 934; (4) violation of Washington’s Wiretap Act, Revised Code of Washington § 9.73.030; (5) 19 violation of the Utah Notice of Intent to Sell Nonpublic Personal Information Act, Utah Code 20 Ann. § 13-37-201; (6) invasion of privacy under California’s constitution; (7) intrusion upon 21 seclusion (California); (8) violation of the California Unfair Competition Law, Cal. Bus. & Prof. 22 Code § 17200, et seq.; and (9) unjust enrichment. 23 Having once considered a motion to dismiss, now before the Court is Stripe’s motion to 24 dismiss all causes of action of the revised First Amended Complaint. (Dkt. Nos. 47 and 48.) The 25 matter was fully briefed by the parties. (See also Dkt. Nos. 51 and 53.) 26 The Court has carefully considered the papers submitted, the pleadings in this action, oral 27 argument, and for the reasons set forth below, it GRANTS IN PART AND DENIES IN PART the 1 motion to dismiss plaintiffs’ first amended complaint.1 2 I. BACKGROUND 3 The First Amended Complaint alleges as follows: 4 Stripe violated various privacy laws by secretly tracking, collecting, and storing the 5 personal data and web activity of visitors to merchants’ website. (FAC ¶¶ 1, 206.) It then created 6 Stripe Elements, a software code that allows merchants to integrate Stripe’s payment platform into 7 their applications. (Id. ¶ 3.) Merchants that use Stripe Elements, in this case Instacart, as a 8 payment platform do not usually contain any identifying information or identification to alert 9 consumers that their transactions are being processed by Stripe. (Id. ¶ 4.) Specifically, there is no 10 branding on the payment screens indicating that Stripe is involved, and other than by looking into 11 the detailed coding of the website and the platform, consumers cannot tell that Stripe is obtaining 12 or storing sensitive information, including financial information. (Id. ¶¶ 4-6.) 13 Consequently, most users think that they are communicating directly with the merchant, 14 when they are in fact communicating directly with Stripe. (Id.) In addition to sensitive financial 15 information, Stripe collects, stores, and uses the following information: 16 • the consumer’s mouse movements and clicks; 17 • the consumer’s keystrokes; 18 • the consumer’s IP address and internet service provider; 19 • the geolocation of the consumer and his or her device; 20 • the consumer’s device brand and model, browser, and operating system; 21 • the number of cards that have been used at the consumer’s IP address; 22 • the number of declined cards the consumer had used with Stripe; 23 • a record of when the consumer’s attempted purchases were declined; 24 • the name of the consumer’s bank or card issuer; 25 • whether or not the consumer had sufficient funds for the transaction; 26

27 1 The parties do not dispute the legal standard for a motion to dismiss under Federal Rule 1 • the time of day the consumer makes the purchase; 2 • other processing codes returned by the consumer’s bank, such as “do not honor” 3 codes or those relating to stolen cards; and 4 • whether the consumer later disputes the charge. 5 (“at-issue data”) (Id. ¶¶ 7, 36.) 6 Stripe takes all the collected information, correlates all payments the consumer made 7 across its entire platform, and then—without informing the consumer—provides much of it to its 8 other merchants. (Id. ¶ 9.) 9 Next, Stripe installs cookies on consumers’ computers and mobile devices, “so that Stripe 10 can track their purchasing behavior across its vast merchant network.” (Id. ¶ 8.) For example, 11 merchants are able to view a consumer’s history of transactions processed by Stripe. (Id.) Using 12 this history, Stripe makes what is known as a “Risk Insights,” which assigns a risk score to each 13 consumer’s transactions based on numerous factors. (Id. ¶ 10.) At no time does Stripe inform 14 consumers who use Stripe Elements that any of the alleged conduct is taking place. (Id. ¶ 12.) 15 A. Content of the Privacy Policy 16 Relevant here, the privacy policy contains three provisions. First it states that Instacart 17 may share “information about you and your order with the other parties who help enable the 18 service” and that “[t]his includes . . . the payment processing partner(s) that we use to validate 19 and charge your credit card. . . .” No one disputes that Stripe is a payment processing partner. 20 (Dkt. No. 22) (Declaration of Jonathan H. Blavin (“Blavin Decl.”), Ex. C at 3-4, § IV (emphases 21 supplied.)) Second, it states that Instacart may “disclose the following categories of personal 22 information to third parties for our commercial purposes: identifiers, demographic information, 23 commercial information, relevant order information, internet activity, geolocation data, sensory 24 information, and inferences.” (Id. at 5, § VIII (emphasis supplied); id. at 1-3, § II; 3-4, § IV.) 25 Third, the privacy policy expressly provides: 26 We, our partners, our advertisers, and third-party advertising 27 networks use various technologies to collect information, including Our partners, advertisers, and third-party advertising networks may 1 use these technologies to collect information about your online 2 activity over time and across different websites or online services. 3 (Blavin Decl., Ex. C at 2, § II (emphases supplied.)) 4 II. ANALYSIS 5 A. Consideration of Consent is Appropriate 6 Consideration of consent is appropriate on a motion to dismiss where lack of consent is an 7 element of the claim. E.g. Garcia v. Enter Holdings, Inc., 78 F. Supp. 3d 1125, 1136 (N.D. Cal. 8 2015) (“[d]efendants may properly challenge [p]laintiffs’s allegations regarding lack of consent 9 through the instant motion to dismiss); Javier v. Assurance IQ, LLC, No. 4:20-CV-02860-JSW, 10 2021 WL 940319, at *2 (N.D. Cal. Mar. 9, 2021) (explaining that “consent generally defeats 11 privacy claims” and granting motion to dismiss); Smith v. Facebook, Inc., 745 F.App’x, 8, 9 (9th 12 Cir. 2018) (affirming motion to dismiss based on consent). 13 Plaintiffs’ first four causes of action depend on consent. With respect to plaintiffs’ first 14 and second causes of action, Cal. Penal Code Section 631(a) prohibits wiretapping “without the 15 consent of all parties to the communication,” and Cal. Penal Code. Section 635 also depends on 16 consent. Opperman v. Path, Inc., 205 F. Supp. 3d 1064, 1072 (N.D. Cal. 2016) (user consent is a 17 defense under CIPA); see also Cramer v. Consol. Freightways, Inc., 209 F.3d 1122, 1130, n.9 (9th 18 Cir. 2000) (amended on other grounds 255 F.3d 683 (9th Cir. 2001)) (explaining that a claim 19 under Cal. Penal Code “Section 635 requires proof that the plaintiff was “injured’ by the 20 eavesdropping equipment, which in turn also depends on consent”). Similarly, plaintiffs’ third 21 and fourth causes of action under the FSCA and Washington’s Wiretap Act both require lack of 22 consent. See Fla. Stat. Ann.

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Silver v. Stripe, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/silver-v-stripe-inc-cand-2021.