Golden v. NBCUniversal Media, LLC

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: October 13, 2026

Docket / citation: 25-2226 · Filed: 2026-09-18

Summary

The Second Circuit affirmed dismissal of Sherhonda Golden’s lawsuit against NBCUniversal Media concerning alleged disclosure of her Today.com video-viewing activity to Facebook through the Facebook Pixel. The nonprecedential summary order stated that Solomon compelled dismissal of her VPPA claim based on substantially similar allegations; Golden did not challenge dismissal of her unjust enrichment claim on appeal.

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

Appeal from the Southern District of New York’s judgment dismissing Golden’s Fourth Amended Complaint.

Reported Holding

The Second Circuit affirmed dismissal of Golden’s Fourth Amended Complaint, finding that Solomon compelled dismissal of her VPPA claim based on substantially similar Facebook Pixel allegations. Solomon applies an ordinary-person test to whether disclosed information identifies a consumer’s video-watching habits.

What the Court Decided

The court affirmed the September 3, 2025 district court judgment and stated that Solomon compelled dismissal of Golden’s claims.

What the Court Did Not Decide

Golden did not challenge the dismissal of her state-law unjust enrichment claim on appeal. The bounded excerpt does not contain the court’s full analysis of her argument concerning intervening Supreme Court decisions.

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

• Facebook Pixel
• Facebook identifiers
• Video URLs

Third parties named or identified in tracked sources: Facebook.

Statutes Invoked

• Video Privacy Protection Act, 18 U.S.C. § 2710

Claims Asserted

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

• VPPA disclosure claim
• New York unjust enrichment
• Video Privacy Protection Act (VPPA)
• State-law unjust enrichment

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. Our scanner tests these behaviors empirically.

The reported outcome direction at the appeal 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

• Golden v. NBCUniversal Media, LLC — Petition for a Writ of Certiorari — Supreme Court of the United States (petition filed by counsel for Sherhonda Golden) · Tier A (Primary authority) · 2026-09-18
• Golden v. NBCUniversal Media — Summary Order — U.S. Court of Appeals for the Second Circuit · Tier A (Primary authority) · 2026-04-23

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.

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