Schallert v. Laird Superfood, Inc.

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: September 26, 2026

Docket / citation: No. 2:25-CV-12407-SPG-PVC

Summary

A federal district court in the Central District of California dismissed a CIPA-based pixel class action for lack of Article III standing because the plaintiff did not allege a concrete privacy injury or identify specific website interactions or data transmitted. The court found boilerplate allegations about tracking pixels insufficient and granted leave to amend.

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 alleging that embedded third-party trackers (from Meta, Google, TikTok) intercepted web interactions on defendant's website and asserted CIPA, the California Comprehensive Computer Data Access and Fraud Act, and intrusion upon seclusion; the district court dismissed for lack of subject-matter jurisdiction (Article III standing) and gave leave to amend.

Reported Holding

The district court dismissed the CIPA class action for lack of Article III standing because the plaintiff failed to allege a concrete, particularized injury showing that the information allegedly intercepted was highly offensive, embarrassing, or otherwise deeply private; the plaintiff also failed to specify what website interactions or specific personal information were transmitted. The plaintiff was granted leave to amend.

What the Court Decided

That boilerplate allegations about the general capabilities of tracking pixels and verbatim statutory language were insufficient to establish Article III standing; merely visiting a publicly available website selling wellness products, without allegations about specific clicks or transmitted sensitive data, did not plausibly plead a concrete privacy injury.

What the Court Did Not Decide

The court did not resolve the merits of the CIPA or other substantive claims, nor did it make a factual finding about whether tracking pixels can capture particular types of private data in other circumstances.

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

• tracking pixels
• third-party web trackers

Third parties named or identified in tracked sources: Meta, Google, TikTok.

Statutes Invoked

• California Invasion of Privacy Act (CIPA); California Comprehensive Computer Data Access and Fraud Act; common law intrusion upon seclusion — all-party consent · private right of action

Claims Asserted

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

• California Invasion of Privacy Act (CIPA)
• California Comprehensive Computer Data Access and Fraud Act
• intrusion upon seclusion (common law)

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. Our scanner tests these behaviors empirically.

The reported outcome direction at the standing 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

• PIXEL PURGE- Judge Dismisses CIPA Pixel Class Action Because The Plaintiff Failed to Show The Tracking Captured Anything “Embarrassing, Invasive, or Otherwise Private” — The National Law Review · Tier C (Professional analysis) · 2026-06-15

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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