Juhyun So v. Hyatt Hotels Corporation

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: August 23, 2026

Docket / citation: 1:2025cv10483

Summary

A May 5, 2026 district-court memorandum opinion in the N.D. Ill. granted Hyatt's motion to dismiss a Wiretap Act-based putative class action alleging that Hyatt enabled Adobe and Meta to collect data from hyatt.com. The court found the complaint showed Hyatt consented to the tracking and that the crime/tort exception was not plausibly alleged under the contractually chosen Illinois law, so the complaint was dismissed with leave to seek amendment.

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 putative class action (originally in Central District of California alleging CIPA claims), the case was transferred to the Northern District of Illinois, plaintiff filed a second amended complaint alleging violations of the Federal Wiretap Act (18 U.S.C. § 2511) based on third-party tracking on hyatt.com, defendant Hyatt moved to dismiss under Rule 12(b)(6), and the court granted the motion but gave plaintiff leave to seek to amend by May 26, 2026.

Reported Holding

The court granted Hyatt's Rule 12(b)(6) motion to dismiss the plaintiff's second amended complaint alleging violations of the Federal Wiretap Act because the complaint itself showed Hyatt consented to the third-party tracking at issue, and the plaintiff failed to plausibly allege the Wiretap Act's crime/tort exception applied (the choice-of-law clause made Illinois law the governing state law and the complaint did not allege a violation of Illinois law). The court also held that consent defeats the private cause of action based on a procurement theory under the circumstances alleged.

What the Court Decided

The court decided that (1) Hyatt's consent defense is clear on the face of the complaint and therefore dismissal under Rule 12(b)(6) was appropriate; (2) the Wiretap Act's crime/tort exception must be evaluated under the body of state law that would apply under choice-of-law principles, and the parties' contractual choice-of-law (Illinois) governed; (3) plaintiff did not plausibly allege a predicate tort under Illinois law (and thus did not plausibly plead the crime/tort exception), and (4) a procurement theory cannot sustain a private cause of action where the underlying interception is not unlawful due to consent.

What the Court Did Not Decide

The court did not definitively resolve whether the California guest-record statute (Cal. Civ. Code § 53.5) would prohibit the alleged disclosures if California law governed; it did not decide the motion to strike class allegations; and it did not finally adjudicate any amendment the plaintiff might file (plaintiff was given leave to move to amend).

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

• website third-party tracking
• cookies
• Meta advanced matching/form field scanning
• Adobe tracking

Third parties named or identified in tracked sources: Adobe Inc., Meta Platforms, Inc..

Statutes Invoked

• 18 U.S.C. § 2511; 18 U.S.C. § 2520; (discusses Cal. Civ. Code § 53.5)

Claims Asserted

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

• Federal Wiretap Act (18 U.S.C. § 2511) - interception/procurement/disclosure/use
• Private civil cause of action (18 U.S.C. § 2520)
• California guest-record statute (Cal. Civ. Code § 53.5) discussed as predicate tort claim

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 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

• Juhyun So v. Hyatt Hotels Corporation — CaseMine · Tier A (Primary authority) · 2026-05-05

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.