Retailer's Request For Zip Code Violated Law, But Generated No Harm

A decision in Tyler v. Michaels Stores earlier this month from the United States District Court for the District of Massachusetts, the use of a consumer's Zip Code to find her address and send her mailings was held to be a statutory violation, but did not give rise to a claim for damages.

Melissa Tyler brought suit against Michaels Stores for violation of Massachusetts General Laws, chapter 93, section 105(a) on behalf of herself and a putative class, claiming that Michaels illegally requested customers' ZIP codes when processing their credit card transactions in violation of the section 105(a).  She alleged that the violation of section 105(a) amounted to a per se violation of the Massachusetts Consumer Protection law, chapter 93A, section 9, caused unjust enrichment, and entitled Tyler to declaratory relief pursuant.