Ridenti

I. Background

A. The Parties and Facts

Plaintiff Paula Ridenti is a resident of Massachusetts and the parent and legal guardian of two children under the age of 13, R.A. and R.M.A., both of whom have, within the past four years, regularly viewed YouTube videos on channels directed primarily to young children. Defendant Google LLC (“Google”) is a Delaware limited liability company with its principal place of business in Mountain View, California. It is the parent company of defendant YouTube, LLC (“YouTube”), a Delaware limited liability company with its principal place of business in San Bruno, California. YouTube is a popular video-sharing platform operated by

Google which is accessible through web browsers, smart televisions, mobile applications on smartphones and tablets and other methods. Most videos are freely accessible to anyone with internet access, without the need to register, log-in to any account or verify the age of the viewer. Many of those videos are, in fact, catered specifically to children under the age of 13 and expressly labeled as such. Plaintiff contends that the Google Companies track the online activities and viewing history of all YouTube users,…