Crano v. Sojern, Inc.

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: October 12, 2026

Docket / citation: 3:25-cv-02600-JSC

Summary

Suellen Crano filed a putative class action alleging Sojern collected identifying information and hotel-booking data without her consent through Hilton and Marriott websites. The court dismissed the action with leave to amend because she had not alleged a concrete injury for Article III standing.

Litigation Status

Status, direction, and weight describe how tracked public sources characterize this matter as of our last review — they are informational classifications, not legal assessments.

Procedural Posture

Sojern moved to dismiss the Second Amended Complaint under Rule 12(b)(6). The court raised Article III standing and permitted supplemental briefing following oral argument on April 14, 2026, before dismissing with leave to amend. The excerpt identifies the original filing month as March 2025 but provides no exact filing or decision date.

Reported Holding

The court dismissed the action with leave to amend because Plaintiff failed to allege a concrete injury sufficient for Article III standing.

What the Court Decided

The court found Plaintiff's asserted economic and privacy injuries insufficient to establish Article III standing and dismissed the action with leave to amend.

What the Court Did Not Decide

The bounded excerpt does not establish a merits disposition of the substantive claims.

Significance

Generally viewed as defense-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.

What This Page Does and Does Not Say

This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.

Technologies at Issue

• web tracking
• cookie IDs
• mobile advertising IDs
• IP address
• device type
• email address
• Website tracking technology
• Cookie identifiers
• Mobile advertising identifiers
• TV identifiers
• Email-based identity matching
• IP addresses and browser/device metadata
• Persistent identifiers linking web interactions to user identity

Third parties named or identified in tracked sources: Sojern, Inc..

Statutes Invoked

• Federal Wiretap Act; Electronic Communications Privacy Act (ECPA); California Invasion of Privacy Act (CIPA); California Unfair Competition Law — all-party consent · private right of action
• Electronic Communications Privacy Act, 18 U.S.C. § 2511; California Invasion of Privacy Act, Cal. Pen. Code §§ 631 and 632; California Unfair Competition Law, Bus. & Prof. Code §§ 17200 et seq.

Claims Asserted

Claims identified in tracked public sources; pleadings may include additional or amended claims.

• California Invasion of Privacy Act (CIPA)
• Electronic Communications Privacy Act (ECPA) / Federal Wiretap Act
• California Unfair Competition Law
• Intrusion upon seclusion (common law)
• Unjust enrichment (common law)
• Electronic Communications Privacy Act
• California Invasion of Privacy Act, sections 631 and 632
• Intrusion upon seclusion
• Invasion of privacy under the California Constitution
• Unjust enrichment

What This Matter May Mean for Website Operators

California Invasion of Privacy Act (CIPA) is an all-party consent statute with a private right of action. Consent standard and private enforceability are the structural features that most shape where website tracking claims are filed and how they are valued.

For operators using similar technologies, the recurring factual questions in matters like this one are whether advertising pixels transmit page URLs or hashed form data before a consent choice. Our scanner tests these behaviors empirically.

Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.

Related Intelligence

Sources

• ORDER RE: MOTION TO DISMISS SECOND AMENDED COMPLAINT — Justia · Tier A (Primary authority) · 2026-06-09
• California Court Dismisses Amended Complaint in Hotel Website Wiretapping Suit for Lack of Article III Standing — Inside Class Actions · Tier C (Professional analysis) · 2026-07-07

About This Page

Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.

How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.

Limitations: Counts labeled "Tracked" reflect matters identified in our source set and are not official court statistics. We report what courts decided and did not decide; we do not predict outcomes.

Corrections: If you believe anything on this page is inaccurate, contact us via the contact page and we will review the underlying sources promptly.