E.H. et al v. Lifelong Adoptions, Inc.
Summary
The federal district court granted LifeLong’s motion to dismiss in part and denied it in part on July 24, 2026. Several claims were dismissed (some with leave to amend, others without), while multiple privacy-related claims under California common law, the California Constitution, CIPA, and the federal ECPA survived the pleading challenge and will proceed subject to further amendment or litigation.
Litigation Status
Procedural Posture
Plaintiff filed the complaint in April 2025 and amended once as of the briefing on this motion. Defendant filed a renewed Rule 12(b)(6) motion. The court issued an order on July 24, 2026 granting the motion in part and denying it in part and granted leave to amend certain claims; a second amended complaint was ordered due within thirty days.
Reported Holding
The court granted the defendant’s Rule 12(b)(6) motion in part and denied it in part. Claim 1 (intrusion upon seclusion) was dismissed with leave to amend; several other claims (identified in the order as claims 3, 5, 9, 10, and 11) were dismissed without leave to amend. The motion was otherwise denied, allowing remaining claims (including breach of confidence, certain state constitutional and statutory privacy claims, and an ECPA claim) to proceed. The plaintiff was given leave to file a second amended complaint within thirty days of the order.
What the Court Decided
The court ruled on a renewed Rule 12(b)(6) motion: it dismissed some claims (including dismissing Claim 1 with leave to amend and dismissing claims 3, 5, 9, 10, and 11 without leave to amend) and denied dismissal as to several other claims including breach of confidence, the California constitutional privacy claim, the CIPA claim, and the ECPA claim (the motion was otherwise denied).
What the Court Did Not Decide
The court did not resolve the merits of the surviving claims, make factual findings about the accuracy of the allegations, or enter final judgment; those issues remain for later proceedings. The order does not resolve damages or ultimate liability.
Significance
Neutral / mixed significance. 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
- tracking pixels
- cookies
- website analytics
Third parties named or identified in tracked sources: Google (Alphabet, Inc.), Facebook / Meta Platforms, Inc..
Statutes Invoked
Claims Asserted
- intrusion upon seclusion (California common law)
- breach of confidence (California common law)
- negligence (California common law)
- unjust enrichment (equitable)
- Electronic Communications Privacy Act (ECPA) claim
- California constitutional privacy claim (Article I, §1)
- California Invasion of Privacy Act (CIPA)
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; what page URLs and query strings analytics tools share with third parties. Our scanner tests these behaviors empirically.
Because this matter is pending, anything reported here is procedural — allegations and interim rulings, not final determinations.
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
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.
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