Sealed forensic record · Report #514

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: Tennessee

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 – AI Services Platform** This matter involves alleged violations of California's consumer privacy statute (CIPA § 631) and related precedent governing cookie consent mechanisms, tracking disclosures, and biometric/health data flows under *Smith v. LoanMe*, *Javier v. Assurance IQ*, and *In re Meta Pixel Healthcare Litig.* An AI services platform's website fired 423 third-party trackers during the audit run. Seven accessibility violations were documented across the scanned pages. No affirmative cookie-banner representations were captured in verbatim form. Fifteen screenshots with chain-of-custody seals support the findings. The sealed PDF contains approximately 15–25 pages of technical evidence, including tracker-fire logs and accessibility audit results.

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 .