Court Rules California Privacy Laws Have Geographic Limits
Geography places boundaries on California's privacy statutes, though courts and lawmakers could feel pressure to clarify these limits or even expand them, said Robinson+Cole lawyer Kathryn Rattigan in a blog post Thursday.
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Steve Dellasala, et al., v. Samba TV was dismissed by the U.S. District Court for Northern California on Oct. 30, which ruled that out-of-state plaintiffs weren't protected under California privacy laws, particularly when the activity charged in the complaint occurred outside the state.
In case 3:25-cv-03470, Dellasala said that California-based Samba TV -- which had its technology installed on some Sony televisions -- intercepted his and other class-action members' “private video-viewing data in real time and without consent,” the blog said. Dellasala and other class members were watching their TVs in North Carolina and Oklahoma, well beyond California's borders, when the data was collected. However, they said Samba TV's actions were in violation of the California Invasion of Privacy Act (CIPA) and the Comprehensive Computer Data Access and Fraud Act (CCDAFA), among other statutes.
Judge Jacqueline Scott Corley “found that both the CCDAFA and CIPA specifically indicate the California legislature’s intent for the statutes not to apply extraterritorially,” the blog said.
However, Rattigan wrote, "As data privacy concerns continue to grow, both legislatures and courts will likely face ongoing pressure to clarify and expand the reach of these protections."
Additionally, the judge ruled that Samba TV didn't count as a “video tape service provider,” dismissing the Video Privacy Protection Act claim (see 2507310070 and 2503270053), nor was “the invasion of privacy" "sufficiently ‘highly offensive’ to sustain a claim for intrusion upon seclusion,” as only IP addresses were collected.
The ruling followed other recent court decisions narrowing the scope of privacy litigation (see 2511050057).