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Low v. LinkedIn Corporation

900 F. Supp. 2d 1010 (2012)

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Low v. LinkedIn Corporation

United States District Court for the Northern District of California
900 F. Supp. 2d 1010 (2012)

  • Written by Sharon Feldman, JD

Facts

LinkedIn was a social-networking website for professionals. LinkedIn assigned to each registered user a unique identification number (ID). Kevin Low and Alan Masand (plaintiffs) brought a putative class action against LinkedIn Corporation (defendant) on behalf of all persons in the United States who registered for LinkedIn services after a certain date. Low and Masand alleged that LinkedIn, acting as a remote computing service (RCS), allowed users’ browsing history and LinkedIn IDs to be transmitted to third parties, including advertisers, marketing companies, data brokers, and web-tracking companies, through the use of cookies—website data stored on a user’s computer and resent to the website’s server each time the user accesses it—in violation of the Stored Communications Act (SCA). LinkedIn moved to dismiss the SCA claim on the grounds that LinkedIn was not acting as an RCS when it disclosed LinkedIn IDs and URLs of viewed pages to third parties.

Rule of Law

Issue

Holding and Reasoning (Koh, J.)

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