Did your lawsuit and arbitration demand look something like this for a Meta-Pixel Violation?

Governing Law
Under the California Invasion of Privacy Act (“CIPA”), Cal. Penal Code § 630 et seq (“CIPA”), a person whose communications are illegally tapped, read, or contents are learned is entitled to the following damages:

• $5,000 per violation, pursuant to Cal. Pen. Code § 637.2.

Courts have ruled that Cal. Penal Code § 631(a) of CIPA is not limited to phone lines, but also applies to “new technologies” such as computers, the internet, and email. See Matera v. Google, Inc., 2016 WL 8200619 at *21 (N.D. Cal. 2016) (CIPA applies to “new technologies” and must be construed broadly to effectuate its remedial purpose of protecting privacy); Bradley v. Google, Inc. 2006 WL 3798134 at *5-6 (N.D. Cal. 2006) (CIPA governs “electronic communications”).

Under California common law, claims for intrusion upon seclusion and invasion of privacy involve a similar test, so courts consider the claims together and ask whether: (1) there exists a reasonable expectation of privacy, and (2) the intrusion was highly offensive. In re Facebook, Inc. Internet Tracking Litigation, 956 F.3d 589 (2020).

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