Janelle Cochrane sued People Data Labs Inc. over the alleged disclosure of her cell phone number, claiming the company violated her privacy rights. The case centers on whether unauthorized disclosure of personal phone numbers constitutes sufficient harm to establish standing in federal court.
Judge Lin relied on the Ninth Circuit's decision in Eichenberger v. ESPN Inc., noting that disclosure of private information like cell phone numbers satisfies Article III standing requirements. 'Cochrane has alleged that due to her cell phone number being disclosed, she has suffered a public disclosure of her private information,' Lin wrote. The judge also noted that while the Ninth Circuit's recent Popa v. Microsoft Corp. decision 'expressly declined to overrule the prior decision in Eichenberger,' so the earlier precedent 'still controls.'
The court had previously issued an order to show cause questioning whether Cochrane had established the constitutional requirement of Article III standing to pursue her claims in federal court. Both parties filed responses addressing the standing issue, prompting Judge Lin to discharge the order.
The ruling clears a procedural hurdle as the parties appear to be moving toward settlement, with Judge Lin noting they anticipate filing a motion for preliminary approval of a class settlement. The court also suggested that if parties want to strengthen the complaint with allegations about market value of cell phone numbers, they could do so by stipulation as part of the settlement process.