Brown

I. BACKGROUND

1 To access a website on the internet, an individual must use “web-browsing software” (a 2 “browser”). See SAC ¶¶ 2, 63. Specifically, the user must type the website’s Uniform Resource 3 Locator (“URL”) into the browser’s address bar. Id. ¶ 63. Entering a URL causes the browser to 4 send a “GET request” to the website’s server. Id. A GET request tells the server “what 5 information is being requested” and instructs the server “to send the information back.” Id. The 6 browser then displays the requested information for the user. Id. 7 Google provides services and products both to website publishers and to internet users. 8 Google provides advertising and data analytics services to website publishers. See id. ¶¶ 8, 67–83. 9 More than 70% of website publishers in the United States use at least one of these services. Id. 10 ¶ 8. Google provides internet users with a browser called “Google Chrome” (“Chrome”). See id. 11 ¶ 51. Chrome, like other popular browsers, offers a “private browsing mode.” Id. ¶ 52. Chrome’s 12 “private browsing mode” is called “Incognito Mode.” Id. 13 The instant case arises from Google’s practice of using its advertising and…