Sealed forensic record · Report #511

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: New York

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 — CIPA § 631 / Smith v. LoanMe / Javier v. Assurance IQ / In re Meta Pixel Healthcare** Consumer-facing platform defendant fired 22 third-party trackers across crawled pages without documented user consent mechanism. No verbatim cookie-banner representations were captured during the run; however, tracker-fire evidence was sealed and chain-of-custody documented across 4 screenshots. Agent completed 5 turns without scope obstruction. Sealed PDF: ~15–25 pages, chain-of-custody verified.

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: caution. No lane query terms defined for broken_cookie_banner; editor must review manually.
Full match list included in the sealed PDF appendix; buyer should review before filing. Checked .