In re Meta Pixel Healthcare Litigation

Summary

The United States District Court for the Northern District of California resolves a discovery dispute concerning Meta’s advertising revenue allegedly attributable to health information collected through Meta Pixel and related business tools. The court orders Meta to provide a further answer to Interrogatory No. 18 and produce documents responsive to RFPs 283 and 287, subject to reasonable accessibility, while requiring further party conferral regarding RFPs 284–286. The order addresses the relevance and proportionality of discovery to plaintiffs’ unjust-enrichment theory.

Holdings

1. Discovery concerning advertising revenue and profits associated with the alleged use of putative class members' health information was relevant to plaintiffs' unjust-enrichment theory because it could assist in reasonably approximating profits causally connected to the alleged interceptions.
2. Meta must provide a further answer to Interrogatory No. 18 concerning profits from revenue received from non-Healthcare Providers for advertising in which data obtained from putative class members through the Meta Pixel was used during the relevant class period, based on reasonably accessible information.
3. Meta must produce reasonably accessible documents sufficient to show revenue from advertisements within the agreed definition covered by RFP 283 and documents permitting apportionment of that revenue or accounting for costs and other reductions under RFP 287.
4. The court would not order production responsive to RFPs 284 through 286 at that time because it could not determine from the discovery-dispute record what documents plaintiffs sought or how those documents were likely to yield relevant information.

Questions Presented

1. Whether Meta should be required to provide a further answer to Interrogatory No. 18 concerning profits from advertising revenue allegedly attributable to data obtained through the Meta Pixel.
2. Whether Meta should be required to produce documents responsive to RFPs 283 and 287 concerning advertising revenue, profits, apportionment, costs, and reductions.
3. Whether the court should order production responsive to RFPs 284 through 286 where the requests relied on unclear definitions or materials not in the record.

Disposition

other