Judge Michelle Williams Court, of the Central District of California, granted a motion to dismiss privacy violations asserted against a Rhode Island-based corporation. Plaintiff failed to establish that the company purposefully directed its activities at California. The dismissal was without prejudice.
Plaintiff alleged that the defendant’s website embedded software enabling third-party data and marketing companies to intercept and collect users’ search queries, along with identifying information such as user IDs, location data, cookies, and device details. The plaintiff, a California resident, claimed that his search for employee benefits information was transmitted to third parties without his knowledge or consent, in violation of the California Invasion of Privacy Act (CIPA).
To establish jurisdiction over an out of state defendant, a plaintiff must show that the defendant purposefully directed activities at the forum state, that the claim arises out of those activities, and that exercising jurisdiction would be reasonable.
The court found that while the defendant intentionally embedded software to transmit user data, the plaintiff’s complaint did not sufficiently allege that these actions were expressly aimed at California or that the defendant knew harm would be suffered there. The court emphasized that merely suffering injury in California or transmitting data to third-party companies based in California was not enough to establish jurisdiction. The court also noted that the website’s data collection process did not provide the defendant with knowledge of the user’s location prior to data transmission.
Though the FAC alleges that Defendant “has purposely directed its activities to the Central District of California by regularly engaging with individuals in California through its website” and its “illegal conduct is directed at and harms California residents,” FAC ¶ 2, the Court cannot rely on such barebones allegations. Mavrix Photo, 647. F.3d at 1223; Conohan v. Gen Digital Inc, No. 2:24-CV-06894-MCS-PVC, 2025 WL 864655, at *2 (C.D. Cal. Feb. 19, 2025). The allegation that the data can “be used to market and advertise directly to Plaintiff in California” also falls short of establishing Defendant’s knowledge of Plaintiff’s location, let alone purposeful direction. FAC ¶ 28. Moreover, “[t]he fact the plaintiff suffers an injury in the forum state alone is insufficient to demonstrate purposeful direction.” Saloff v. Giampapa, No. CV 15–02715 BRO (FFMx), 2015 WL 13273305, at *7 (C.D. Cal. July 22, 2015) (citing Picot, 780 F.3d at 1214).
Dino Moody v. Textron Inc. et al. Additional Party Names: Rhode Island corporation, No. 2:25-CV-01032-MWC (EX), 2025 WL 2025597 (C.D. Cal. July 2, 2025).
