Nelson v. Reddit, Inc.
Summary
The Southern District of California denied Reddit’s motion to dismiss a CIPA-based class action alleging that embedding a LiveRamp tracker which collected IP addresses and cookies qualified as a pen register. The court found the complaint plausibly alleged direct use/installation of a device or process that recorded addressing information and rejected several legal defenses raised by Reddit, allowing the claim to proceed past the pleading stage.
Litigation Status
Procedural Posture
Defendant filed a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) (motion filed July 14, 2025, per the opinion); after briefing and supplemental authority, the Court issued an order on February 17, 2026 denying the motion to dismiss and denying as moot Defendant’s request for judicial notice.
Reported Holding
The court denied Defendant Reddit, Inc.’s Rule 12(b)(6) motion to dismiss the class action complaint alleging that Reddit’s embedding of a LiveRamp third‑party tracker that collected IP addresses and cookies constituted a pen register/trap-and-trace device under CIPA (Cal. Penal Code § 638.50(b)) and thus violated § 638.51(a). The court found the complaint pleaded a plausible claim, rejected Reddit’s arguments that the technology cannot qualify as a pen register, that Reddit is exempt as a party to the communication, that CIPA applies only to person‑to‑person communications, and that the rule of lenity required dismissal.
What the Court Decided
The court denied Reddit’s motion to dismiss, concluding the Complaint plausibly alleges that Reddit installed/used a device or process (the LiveRamp tracker) that records addressing information (IP addresses/cookies) and that CIPA can plausibly apply to those facts; the court therefore allowed the CIPA claim to proceed past the pleading stage.
What the Court Did Not Decide
The court did not decide the merits of liability or damages on the CIPA claim, did not enter final judgment, and did not resolve any factual disputes; the court also did not grant or rely on Defendant’s request for judicial notice (denied as moot).
Significance
Generally viewed as plaintiff-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
- LiveRamp third-party tracker
- HTTP requests / IP address collection
- browser cookies / cookie-based tracking
- third-party advertising identity graph
- LiveRamp tracker
- browser cookies
- IP address collection via HTTP requests
- cookies
- IP address collection
- web tracking / online advertising tracking
- third‑party tracking tool (LiveRamp tracker)
- advertising identity/graphing for personalized ads
Third parties named or identified in tracked sources: LiveRamp, Reddit, Inc..
Statutes Invoked
- Cal. Penal Code §§ 638.50(b), 638.51(a); Cal. Penal Code § 637.2 (damages provision)
- Cal. Penal Code §§ 638.50(b), 638.51(a); Cal. Penal Code § 637.2
- Cal. Penal Code §§ 638.50(b), 638.51(a), 637.2
Claims Asserted
- California Invasion of Privacy Act (CIPA) — Cal. Penal Code §§ 638.50(b), 638.51(a)
- Statutory damages provision — Cal. Penal Code § 637.2
- California Invasion of Privacy Act — Pen Register Act (Cal. Penal Code §§ 638.50(b), 638.51(a))
- Statutory damages claim under Cal. Penal Code § 637.2
- California Invasion of Privacy Act (Pen Register Act) § 638.51(a) (as defined by § 638.50(b))
- Statutory damages provision under Cal. Penal Code § 637.2 (pled in complaint)
- Cal. Penal Code § 638.50(b) (pen register definition)
- Cal. Penal Code § 638.51(a) (prohibition on pen registers without order/consent)
- Cal. Penal Code § 637.2 (civil remedies/damages)
What This Matter May Mean for Website Operators
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
- Nelson v. Reddit, Inc. — ORDER Denying Defendant Reddit, Inc.'s Motion to Dismiss Class Action Complaint (Document 26)
- ORDER Denying Defendant Reddit, Inc.'s Motion to Dismiss Class Action Complaint (Signed Feb 17, 2026)
- ORDER Denying Defendant Reddit, Inc.'s Motion to Dismiss Class Action Complaint
- Nelson v. Reddit, Inc., Doc. 26 (S.D. Cal. Order denying motion to dismiss)
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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