Court Denies Class Certification In Internet Tracking Case Over Individualized Statute Of Limitations Issues

A recent decision from the Northern District of California reminds corporate defendants in Internet tracking cases that strategies to defeat class certification based on individualized issues can be just as critical as merit-based defenses.

In In re Meta Pixel Tax Filing Cases, No. 22-cv-07557-PCP (N.D. Cal. Mar. 30, 2026), a group of plaintiffs sought to certify classes of individuals who visited tax-preparation websites where the Meta Pixel was deployed, alleging that user data—including URLs, browsing behavior, and potentially sensitive financial information—was transmitted to Meta in violation of the California Invasion of Privacy Act (CIPA), among other statutes. Plaintiffs’ original complaint defined the class to include individuals whose “tax filing information” was collected. But in their certification motion, plaintiffs sought to define the class as anyone whose data from visiting the websites appeared in Meta’s internal data tables—a significantly broader group.