Rodriguez v. Sony Computer Entertainment America, LLC
Opinion
Opinion
Rawlinson, J.
Appellant Daniel Rodriguez (Rodriguez) challenges the district court’s dismissal of his second amended complaint alleging that Appellees Sony' Computer Entertainment America LLC (Sony Computer) and Sony Network Entertainment (Sony Network) International LLC (collectively Sony) violated the Video Privacy Protection Act (the Act) by retaining Rodriguez’s personally identifiable information (personal information) beyond the Act’s statutory limits, and disclosing his personal information between Sony entities. Rodriguez contends that the district court erred in concluding that the Act does not provide a private right of action to enforce its retention requirements. Rodriguez also takes issue with the district court’s conclusion that the intra-corporate disclosures were exempt from the Act’s non-disclosure requirements. We affirm the district court’s rulings.
I. BACKGROUND
A. Statutory Background
The Act was promulgated in 1988 after the Washington City Paper published Judge Robert Bork’s video rental history during his failed Supreme Court confirmation proceedings. See Mollett v. Netflix, Inc., 795 F.3d 1062, 1065-66 (9th Cir.2015).