Crano v. Sojern, Inc.

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: August 26, 2026

Summary

A California federal judge dismissed the Second Amended Complaint in Crano v. Sojern, Inc. for lack of Article III standing, finding the plaintiff failed to allege a concrete injury. The court rejected theories based on intangible privacy harms from collection of technical identifiers and an unjust-enrichment economic harm theory, relying on Ninth Circuit precedent and distinguishing In re Facebook.

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

Plaintiff filed a Second Amended Complaint after the court previously dismissed the First Amended Complaint. The Second Amended Complaint added allegations about data collection and a new claim for CIPA section 632; the court dismissed the Second Amended Complaint for lack of Article III standing.

Reported Holding

The district court dismissed the plaintiff's Second Amended Complaint for lack of Article III standing, finding the complaint failed to allege a concrete injury. The court rejected theories of intangible privacy injury based on collection of technical identifiers and non-sensitive data and rejected the unjust-enrichment economic-injury theory. The decision relied on Ninth Circuit authority (Popa v. Microsoft) and distinguished In re Facebook.

What the Court Decided

The court held the plaintiff did not allege a concrete Article III injury and therefore dismissed the Second Amended Complaint. It rejected the plaintiff's intangible privacy-injury and tangible economic-injury theories and found the alleged collection of technical identifiers and non-sensitive data insufficient to establish standing.

What the Court Did Not Decide

The court did not reach the merits of the underlying statutory and common-law claims (e.g., merits of alleged CIPA or ECPA violations) because it dismissed the case for lack of Article III standing.

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

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

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)

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.

The reported outcome direction at the standing stage reflects how tracked sources characterize the ruling; such rulings are often narrow, posture-specific, and fact-bound rather than broad statements of law.

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

• 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.