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'Grab-Bag Complaint'

Meta Sets Aug. 16 Date for Motion to Dismiss Healthcare Litigation

Meta will move for an order to dismiss Meta Pixel Healthcare Litigation on Aug. 16 before U.S. District Judge William Orrick for Northern California in San Francisco, said a Monday notice of motion (docket 3:22-cv-03580) and motion to dismiss the class action. The case involves healthcare providers’ use of the Meta Pixel tracking tool on their websites for targeted advertising.

At issue, Meta said, is the allegation that healthcare providers “decided to use a commonplace internet analytics tool to send sensitive health-related information to Meta that Meta never intended, and did not want, to receive,” said its memorandum of points and authorities. The court, in denying plaintiffs’ motion for a preliminary injunction, referenced a “potentially serious problem,” and “Meta does not disagree,” it said. That’s why Meta “has built, and is constantly working to improve, the filtration systems that are designed to screen out potentially sensitive data when it is sent by web developers in violation of Meta’s policies.”

There's nothing “inherently unlawful or harmful” about pixel-based analytics technology, which helps web developers “measure certain actions users take on their websites,” such as the pages they view and products they purchase to help grow their businesses, Meta said. The company makes the “generic bit of code publicly available, and third-party web developers can freely customize and install it to help them improve the online services they offer.”

Web developers, “not Meta,” choose where and how they use the pixel, and they must agree to Meta’s business tools terms before integrating the code on their websites, it said. The terms tell developers not to send any health or other sensitive information and to confirm they have the proper permissions and legal rights to share data, said the memorandum. Meta’s filtering mechanism screens out potentially sensitive health data it detects and alerts the developer so it can check the Pixel configuration and fix issues, it said.

Plaintiffs “attempt to distract” the court from such points by noting ways in which Meta allegedly encourages healthcare companies to use its tools, but the allegations “miss the point," said the memorandum. "Companies can use Meta’s Pixel without sending health information to Meta, and are expected to use the Pixel in compliance with Meta’s terms.”

Plaintiffs filed a “grab-bag complaint” asserting 13 causes of action, including wiretap violations, larceny and trespass, said the memorandum. None of the causes of action fits plaintiffs’ theory that Meta should be held liable for healthcare providers’ “alleged misuse of a publicly available tool that Meta did not implement or configure on the providers’ websites,” it said.

Federal and state wiretapping claims fail because plaintiffs don’t allege the requisite intent by Meta to receive sensitive health information, said the memorandum; other claims fail because they're based on California laws that don’t apply elsewhere, and plaintiffs aren’t California residents. Larceny and trespass “cannot be stretched to encompass the technology at issue and the facts alleged in this case,” it said.

Meanwhile, Meta requested a ruling Friday (docket (3:23-cv-00059) on its pending motion to sever claims in an unrelated Pixel case, following co-defendant Hey Favor’s April 18 bankruptcy filing and an automatic stay of proceedings in the same court. Plaintiff “Jane Doe” alleges Hey Favor incorporated pixels on social media platforms, sending her personally identifiable health information to FullStory, Meta, TikTok and ByteDance without her consent. Meta filed a motion to sever the claims against it in the action; the next day it filed a conditional motion to relate the action with Meta Pixel Healthcare Litigation.