Sealed forensic record · Report #520

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

LocationU.S. · operates nationally

Nat'l classCalif. statewide — CIPA is state law

ArbitrationClass-viable — browsewrap, likely unenforceable

ClaimsCIPA § 631 / Smith v. LoanMe (Cal. 2021) / Javier v. Assurance IQ (9th Cir. 2022) / In re Meta Pixel Healthcare Litig.

**Case Theory** CIPA § 631 cookie-consent violation. Applicable precedent: *Smith v. LoanMe* (Cal. 2021), *Javier v. Assurance IQ* (9th Cir. 2022), *In re Meta Pixel Healthcare Litig.* **Tease** Large consumer-facing platform. Agent captured 207 third-party tracker fires during site traversal. Three accessibility violations documented across scanned pages. Seven screenshots with sealed chain-of-custody documentation. No verbatim user-facing representations obtained; findings remain unclassified pending further review. Evidence suggests cookie-banner mechanics may permit tracker deployment prior to affirmative consent. 15–25 pages, sealed PDF with forensic chain-of-custody seals.

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 .