Ryan Emmett v. Delta Air Lines, Inc.

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

Docket / citation: 2:22-1568

Summary

Ryan Emmett brought a lawsuit against Delta Air Lines alleging that session replay software on delta.com recorded his website interactions without prior consent, asserting Pennsylvania Wiretap Act and intrusion-upon-seclusion claims individually and on behalf of a proposed class. The excerpt describes Delta's motion to dismiss as fully briefed and ripe for disposition, but does not provide the court's ruling.

Procedural Posture

Delta moved to dismiss the First Amended Complaint for lack of personal jurisdiction and failure to state a claim, and also argued that federal law barred the claims. The excerpt describes the motion as fully briefed and ripe for disposition but does not include its disposition.

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

• session replay software

Statutes Invoked

• Pennsylvania Wiretap Act, 18 Pa. Cons. Stat. § 5701

Claims Asserted

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

• Pennsylvania Wiretap Act
• Common law invasion of privacy — intrusion upon seclusion

What This Matter May Mean for Website Operators

For operators using similar technologies, the recurring factual questions in matters like this one are when session recording begins relative to consent and whether input masking covers every field. Our scanner tests these behaviors empirically.

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

• Case 2:22-cv-01568-RJC Document 52 Filed 06/03/24 — GovInfo · Tier A (Primary authority) · 2024-06-03

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.