UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 10 GABRIELA HERNANDEZ, Case No. 23-cv-00971-BAS-DEB
Plaintiff,
ORDER GRANTING DEFENDANT’S
v. MOTION TO DISMISS WITH
LEAVE TO AMEND
PURE HEALTH RESEARCH LLC,
Defendant. (ECF No. 10)
I. Synopsis Plaintiff Gabriela Hernandez files this First Amended Complaint against Defendant Pure Health Research LLC alleging various claims, including violations of the California Invasion of Privacy Act and the California Unauthorized Access to Computer Data Act. (First Am. Comp. (“FAC”) ¶¶ 46, 61, ECF No 9.) Plaintiff claims Defendant secretly installed surveillance tools on its website to record visitors’ chat conversations and used the content of these conversations to target visitors with marketing information. (FAC 1:2– 6.) Plaintiff alleges Defendant has violated numerous laws by collecting Plaintiff’s data without her informed consent. (FAC 1:7–8.) Defendant moves to dismiss, claiming: …