Judge Michael W. Fitzgerald, in the Central District of California, granted defendant’s motion to dismiss. The case involved allegations that a website operator installed the Meta Pixel—a tool provided by Meta (formerly Facebook)—on its site, which allegedly intercepted and disclosed users’ personally identifiable information (PII) and viewing history without their consent. The plaintiff brought a class action under the California Invasion of Privacy Act (CIPA), claiming that the website aided and abetted Meta’s unlawful eavesdropping.
Is Meta Pixel a Third-Party Eavesdropper?
The central question was whether the Meta Pixel acts as an independent third-party eavesdropper, or merely as a tool for the website operator. Under CIPA section 631(a), liability can attach if a third party intercepts communications for its own purposes, but not if the technology simply stores or relays information for the website’s benefit.
The court reviewed the complaint’s allegations and found them insufficient. While the plaintiff asserted that Meta received user data via the Pixel, there were no specific factual allegations that Meta used, or was capable of using, the data for its own business purposes (such as advertising analytics or targeting by other advertisers). Instead, the complaint suggested that the Pixel’s primary function was to help the website operator target its own users with advertisements.
Court’s Reasoning and Ruling
The court distinguished between tools that merely facilitate a website’s operations (not third-party eavesdroppers) and independent entities that use intercepted data for their own gain (potential eavesdroppers under CIPA). Because the complaint did not allege facts showing Meta’s independent use or capability to use the data, the court concluded that the plaintiff failed to state a plausible claim.
As a result, the court granted the website operator’s motion to dismiss. However, the dismissal was “with leave to amend,” meaning the plaintiff may file an amended complaint with more detailed allegations regarding Meta’s capabilities and use of the data.
Mike Goldstein v. Rumble Inc., No. CV 25-06304-MWF (SKX), 2025 WL 3691987 (C.D. Cal. Nov. 6, 2025).
