Sealed forensic record · Report #526

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

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** CIPA § 631 violation theory under *Smith v. LoanMe* (Cal. 2021), *Javier v. Assurance IQ* (9th Cir. 2022), and *In re Meta Pixel Healthcare Litig.* framework. Consumer-facing platform failed to implement functional consent mechanism before third-party data transmission. Run captured 37 third-party tracker fires without corresponding user opt-in. One accessibility violation identified across scanned pages. No verbatim consumer-facing representations were obtained; findings remain unclassified pending further review. 10 screenshots with chain-of-custody seals. Sealed PDF: ~15–25 pages.

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 .