Appeals Court Upholds ESPN Win in Video Privacy Suit
Plaintiff Chad Eichenberger claimed ESPN violated the Video Privacy Protection Act by handing over his Roku device serial number and the identity of the videos he watched to Adobe Analytics.
November 29, 2017 at 04:59 PM
6 minute read
SAN FRANCISCO — A federal appeals court has upheld a win for ESPN Inc. in a lawsuit that accused the company of sharing the personal identities of customers who used the sports network's Roku streaming application with data analytics companies.
Plaintiff Chad Eichenberger, who was represented by lawyers at Edelson PC, claimed ESPN violated the Video Privacy Protection Act, or VPPA, by handing over his Roku device serial number and the identity of the videos he watched to Adobe Analytics, which used the information in combination with other data to build consumer marketing profiles. The federal privacy statute, passed in 1988 in the wake of a newspaper printing U.S. Supreme Court nominee Robert Bork's video rental history, bars “video tape service providers” from knowingly handing over “personally identifiable information” and carries stiff statutory penalties.
But in a 15-page opinion issued Wednesday by the U.S. Court of Appeals for the Ninth Circuit, the court found the data handed over by ESPN didn't qualify as “personally identifiable information” because, on its own, it wouldn't make it apparent to an “ordinary person” who watched what videos.
“As plaintiff concedes, that information cannot identify an individual unless it is combined with other data in Adobe's possession—data that ESPN never disclosed and apparently never even possessed,“ wrote Ninth Circuit Judge Susan Graber. “It is true that today's technology may allow Adobe to identify an individual from the large pool by using other information—as plaintiff alleges. But the advent of the internet did not change the disclosing-party focus of the statute.”
Graber's opinion adopted the “ordinary person” standard previously outlined by the Third Circuit in In re Nickelodeon and upheld a prior ruling by U.S. District Senior Judge Thomas Zilly of the Western District of Washington to dismiss the case.
Her ruling, however, did side with the plaintiff on one important point, finding he had standing to sue under the VPPA. ESPN's lawyers at Munger, Tolles & Olson argued the plaintiff hadn't established “concrete harm” as required to show standing under the Supreme Court decision in Spokeo v Robins. Graber wrote that the VPPA codified “a context-specific extension of the substantive right to privacy.”
“Accordingly, every disclosure of an individual's 'personally identifiable information' and video-viewing history offends the interests that the statute protects,” Graber continued.
Munger's Daniel Collins, who argued the case for ESPN, was out of his office and didn't immediately respond to a voicemail message Wednesday. ESPN representatives didn't immediately respond to a request for comment.
Edelson's J. Aaron Lawson and Roger Perlstadt, likewise, didn't immediately respond to messages.
SAN FRANCISCO — A federal appeals court has upheld a win for
Plaintiff Chad Eichenberger, who was represented by lawyers at Edelson PC, claimed ESPN violated the Video Privacy Protection Act, or VPPA, by handing over his Roku device serial number and the identity of the videos he watched to Adobe Analytics, which used the information in combination with other data to build consumer marketing profiles. The federal privacy statute, passed in 1988 in the wake of a newspaper printing U.S. Supreme Court nominee Robert Bork's video rental history, bars “video tape service providers” from knowingly handing over “personally identifiable information” and carries stiff statutory penalties.
But in a 15-page opinion issued Wednesday by the U.S. Court of Appeals for the Ninth Circuit, the court found the data handed over by ESPN didn't qualify as “personally identifiable information” because, on its own, it wouldn't make it apparent to an “ordinary person” who watched what videos.
“As plaintiff concedes, that information cannot identify an individual unless it is combined with other data in Adobe's possession—data that ESPN never disclosed and apparently never even possessed,“ wrote Ninth Circuit Judge
Graber's opinion adopted the “ordinary person” standard previously outlined by the Third Circuit in In re Nickelodeon and upheld a prior ruling by U.S. District Senior Judge Thomas Zilly of the Western District of Washington to dismiss the case.
Her ruling, however, did side with the plaintiff on one important point, finding he had standing to sue under the VPPA. ESPN's lawyers at
“Accordingly, every disclosure of an individual's 'personally identifiable information' and video-viewing history offends the interests that the statute protects,” Graber continued.
Munger's Daniel Collins, who argued the case for ESPN, was out of his office and didn't immediately respond to a voicemail message Wednesday. ESPN representatives didn't immediately respond to a request for comment.
Edelson's J. Aaron Lawson and Roger Perlstadt, likewise, didn't immediately respond to messages.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllApple Disputes 'Efforts to Manufacture' Imaging Sensor Claims Against iPhone 15 Technology
'Another Broken Promise': California Tribes Sue Casinos for Allegedly Illegal Profit From Card Games
After Solving Problems for Presidents, Ron Klain Now Applying Legal Prowess to Helping Airbnb Overturn NYC Ban
7 minute readHusch Blackwell Hires Former Adobe Counsel to Oversee AI Advisory Offering
3 minute readTrending Stories
- 1Supreme Court Takes Up the Corporate Transparency Act: Recent Litigation and Potential Next Steps
- 2Brogdon: The Final Nail in Corbin’s Coffin in Premises Cases
- 3What to Know About the New 'Overlapping Directorship' Antitrust Development
- 4'Quiet, Appropriate End:' NY Court of Appeals Formally Removes Erin Gall From Bench
- 5Just One Cookie? Justices to Decide Liability for Half-Truths
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250