L.W.A. v. LinkedIn Corporation

Summary

The United States District Court for the Northern District of California granted LinkedIn Corporation’s motion to compel arbitration in L.W.A.’s action alleging that LinkedIn intercepted private information through an embedded Insight Tag on Noom’s website. The court held that Plaintiff assented to Noom’s online Terms of Use, that her claims fell within the arbitration agreement’s scope, and that LinkedIn could enforce the agreement as a nonsignatory under equitable estoppel. The court stayed the case pending arbitration and terminated LinkedIn’s motion to dismiss as moot.

Holdings

1. Noom's modified sign-in-wrap agreement was enforceable because the sign-up page provided reasonably conspicuous notice of the Terms of Use and Plaintiff unambiguously manifested assent by proceeding to create an account.
2. Plaintiff's claims fell within the scope of the Arbitration Agreement because they arose out of her use of Noom's website and services.
3. LinkedIn could enforce Noom's Arbitration Agreement against Plaintiff under California's doctrine of equitable estoppel because Plaintiff's claims were intimately founded in and intertwined with her agreement with Noom.
4. The action was stayed pending arbitration, and the motion to dismiss was terminated as moot.

Questions Presented

1. Whether Noom's online Terms of Use formed a valid and enforceable arbitration agreement with Plaintiff.
2. Whether Plaintiff's claims against LinkedIn fell within the scope of Noom's arbitration agreement.
3. Whether LinkedIn, as a nonsignatory to the arbitration agreement, could enforce it against Plaintiff under California's doctrine of equitable estoppel.
4. Whether the court should stay the action pending arbitration and terminate LinkedIn's motion to dismiss as moot.

Disposition

other