T.S. v. Body Contour Centers LLC

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

Docket / citation: 2:24-cv-01944-LK

Summary

T.S. alleges Sono Bello transmitted consultation information to Meta through the Facebook Tracking Pixel without consent. The court allowed ECPA to proceed while dismissing CIPA and the withdrawn CMIA claim. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/washington/wawdce/2%3A2024cv01944/341964/47/))

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

Rule 12(b)(6) motion in a putative class action, granted in part and denied in part. ([cases.justia.com](https://cases.justia.com/federal/district-courts/washington/wawdce/2%3A2024cv01944/341964/47/0.pdf?ts=1790815521))

Reported Holding

The ECPA claim survived; CIPA was dismissed for insufficient predicate allegations, and CMIA was dismissed following withdrawal. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/washington/wawdce/2%3A2024cv01944/341964/47/))

What the Court Decided

Consultation requests plausibly constituted contents; alleged HIPAA-related disclosure supported the crime-tort exception. ECPA permits civil procurement liability. CIPA Clause One excludes internet communications, and Clause Two required allegations of real-time review absent here. ([cases.justia.com](https://cases.justia.com/federal/district-courts/washington/wawdce/2%3A2024cv01944/341964/47/0.pdf?ts=1790815521))

What the Court Did Not Decide

The court did not determine ultimate liability, damages, or class certification; CMIA dismissal followed withdrawal rather than substantive adjudication. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/washington/wawdce/2%3A2024cv01944/341964/47/))

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

• Facebook Tracking Pixel
• Facebook Business Tools

Third parties named or identified in tracked sources: Facebook / Meta, Meta/Facebook.

Statutes Invoked

• ECPA, 18 U.S.C. §§ 2511, 2520; CIPA, Cal. Penal Code § 631(a); CMIA, Cal. Civ. Code § 56.10 — all-party consent · private right of action
• ECPA, 18 U.S.C. §§ 2511 and 2520; CIPA, Cal. Penal Code § 631(a); CMIA, Cal. Civ. Code § 56.10; HIPAA, 42 U.S.C. § 1320d-6(a)(3) — all-party consent · private right of action

Claims Asserted

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

• ECPA interception, disclosure, and intentional use
• CIPA aiding or conspiring under section 631(a)
• CMIA disclosure
• CIPA § 631(a) aiding or conspiracy
• CMIA disclosure of medical information

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.

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

• T.S. v. Body Contour Centers LLC — Order Granting in Part and Denying in Part Motion to Dismiss — Justia — U.S. District Court, Western District of Washington · Tier A (Primary authority) · 2026-09-29
• T.S. v. Body Contour Centers LLC — Order Granting in Part and Denying in Part Motion to Dismiss — U.S. District Court for the Western District of Washington, via Justia · Tier A (Primary authority) · 2026-09-29

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.

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