Schallert v. Palo Alto Networks, Inc.

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

Docket / citation: No. 25STCV17109

Summary

A California Superior Court sustained Palo Alto Networks' demurrer and dismissed a complaint alleging a website SDK was a CIPA trap-and-trace device, holding that CIPA's trap-and-trace provisions are limited to telephone lines. The court dismissed the complaint without leave to amend and did not reach the factual merits about the SDK's operation.

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 complaint alleging Palo Alto Networks deployed an SDK on its website that functioned as a trap-and-trace device in violation of Cal. Penal Code § 638.51; defendant demurred; the court sustained the demurrer without leave to amend and dismissed the action.

Reported Holding

The Los Angeles County Superior Court held that the trap-and-trace provisions of the California Invasion of Privacy Act (CIPA) do not extend to website communications, and sustained Palo Alto Networks' demurrer, dismissing the complaint without leave to amend.

What the Court Decided

The court concluded that CIPA's trap-and-trace definition and related provisions are limited to telephone lines based on the statutory text and legislative history, and therefore the plaintiff's allegation that a website SDK constituted a trap-and-trace device failed to state a cause of action.

What the Court Did Not Decide

The court did not reach the merits of whether the SDK actually captured identifying electronic impulses or other factual allegations beyond whether CIPA's trap-and-trace provisions apply to website communications.

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

• Software Development Kit (SDK)
• website tracking software

Third parties named or identified in tracked sources: Palo Alto Networks, Inc..

Statutes Invoked

• Cal. Penal Code §§ 638.50, 638.51, 638.52

Claims Asserted

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

• Cal. Penal Code § 638.51 (trap and trace)
• Cal. Penal Code § 638.50 (definitions)
• Cal. Penal Code § 638.52 (court order requirements for trap and trace)

What This Matter May Mean for Website Operators

The reported outcome direction at the statutory interpretation 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

• California Superior Court Rules That Website Tracking Software Is Not a “Trap and Trace Device” Under CIPA — Consumer Finance + Privacy Counsel (Womble Bond Dickinson blog) · Tier C (Professional analysis) · March 22, 2026

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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