Sealed forensic record · Report #512

What's for sale here is a dated, hashed snapshot of a defendant's live tracking behavior, marketing representations, and consent UX, sealed under FRE 901 chain of custody on the day we captured it. Defendants rewrite their policies and pull their pixels the moment a complaint lands — this record is the only proof of what the site was doing before.

Case at a glance

LocationHQ: California

Nat'l classCalif. statewide — CIPA is state law

ArbitrationArb risk — mass-arbitration target

ClaimsCIPA § 631 / Smith v. LoanMe (Cal. 2021) / Javier v. Assurance IQ (9th Cir. 2022) / In re Meta Pixel Healthcare Litig.

**Broken Cookie Banner – Consumer Platform** This matter implicates CIPA § 631, *Smith v. LoanMe* (Cal. 2021), *Javier v. Assurance IQ* (9th Cir. 2022), and *In re Meta Pixel Healthcare Litig.* regarding cookie consent and third-party data transmission. A consumer-facing platform fired 30 third-party trackers during initial page load. Three accessibility violations were documented across the scanned pages. The run encountered an embedded CAPTCHA barrier that prevented deeper scope penetration. No verbatim representations of cookie-consent language were captured before scope blockage. Sealed PDF: ~15–25 pages, 3 screenshots with chain-of-custody seals.

Case theory: CIPA § 631 — consent-defect

What you receive

Sealed PDF report (typical 15–28 pp) with full chain of custody — SHA-256 + RFC 3161 timestamps on every artifact
Verbatim binding representations with Wayback-anchored class-period bounds
Full network capture: every tracker fire, sensitive transmission, identity-sync event
Wrap classification: BROWSEWRAP / CLICKWRAP / SIGN-IN-WRAP verdict + Specht-line alignment
Per-circuit case-law alignment (LIKELY_UNENFORCEABLE / LIKELY_ENFORCEABLE / JURISDICTIONALLY_DEPENDENT)
Defendant name + domain — revealed at purchase

✓ Prior-litigation check: clear. No prior plaintiff-class filing found against this defendant on this theory (CourtListener federal + web search of state courts, checked 2026-08-05).
No same-kind case against this defendant (federal RECAP + web, <3yr).