Sealed forensic record · Report #525

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: Texas

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 and the line of authority in *Smith v. LoanMe* (Cal. 2021), *Javier v. Assurance IQ* (9th Cir. 2022), and *In re Meta Pixel Healthcare Litig.*, addressing cookie-consent mechanisms and third-party data transmission on consumer-facing digital properties. Agent captured 50 third-party tracker fires during site inspection. One accessibility violation was documented across the scanned pages. Six screenshots with chain-of-custody seals support the findings. Evidence remains unclassified pending buyer review. Sealed PDF: ~15–25 pages, full photographic chain-of-custody.

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 .