Sealed forensic record · Report #522

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.

**Broken Cookie Banner – Consumer Platform** This matter implicates CIPA § 631, *Smith v. LoanMe* (Cal. 2021), *Javier v. Assurance IQ* (9th Cir. 2022), and *In re Meta Pixel Healthcare Litig.* — addressing consent and tracking disclosures on consumer-facing digital properties. A mid-market consumer platform fired 105 third-party trackers during a 12-turn agent run. Two accessibility violations were documented across the scanned pages. The sealed PDF chain includes 23 screenshots with forensic seals, spanning approximately 15–25 pages. No verbatim representations were captured; findings remain unclassified pending expert review.

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 .