Doe v. CRH Healthcare, LLC et al

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

Docket / citation: 1:25-CV-6353-TWT

Summary

The plaintiff alleged that healthcare website tracking disclosed personal and medical information to Google without authorization. The court granted dismissal with leave to amend; the source does not establish subsequent amendment or final dismissal with prejudice. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/georgia/gandce/1%3A2025cv06353/351542/35/))

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

Rule 12(b)(6) dismissal of the amended complaint, with fourteen days to amend before dismissal becomes with prejudice. ([cases.justia.com](https://cases.justia.com/federal/district-courts/georgia/gandce/1%3A2025cv06353/351542/35/0.pdf?ts=1785437675))

Reported Holding

The court dismissed all claims without prejudice for insufficient damages allegations and application of the ECPA party exception. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/georgia/gandce/1%3A2025cv06353/351542/35/))

What the Court Decided

Counts 1–5 lacked adequately pleaded cognizable loss. The ECPA crime-tort exception required a purpose independent of the interception itself, which was not adequately alleged. ([cases.justia.com](https://cases.justia.com/federal/district-courts/georgia/gandce/1%3A2025cv06353/351542/35/0.pdf?ts=1785437675))

What the Court Did Not Decide

The court did not reach whether the transmitted information constituted ECPA contents; it treated damages as a pleading issue rather than Article III standing. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/georgia/gandce/1%3A2025cv06353/351542/35/))

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

• Google Analytics
• Google DoubleClick
• Tracking pixels
• Cookies
• Form-submission tracking

Third parties named or identified in tracked sources: Google.

Statutes Invoked

• Electronic Communications Privacy Act, 18 U.S.C. §§ 2511, 2520; O.C.G.A. § 51-1-6

Claims Asserted

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

• Negligence and negligence per se
• Breach of fiduciary duty
• Breach of implied contract
• Breach of express contract
• Unjust enrichment
• Electronic Communications Privacy Act

What This Matter May Mean for Website Operators

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; what page URLs and query strings analytics tools share with third parties. Our scanner tests these behaviors empirically.

The reported outcome direction at the pleading 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

• Doe v. CRH Healthcare, LLC et al, 1:2025cv06353 — Document 35 — U.S. District Court for the Northern District of Georgia, via Justia · Tier A (Primary authority) · 2026-07-29

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.