Judge: Cherol J. Nellon, Case: 24STCV21735, Date: 2025-02-18 Tentative Ruling

Case Number: 24STCV21735    Hearing Date: February 18, 2025    Dept: 14

Case Background

This is an action for violation of the California Invasion of Privacy Act (CIPA).

On August 26, 2024, Plaintiff Dana Hughes filed her Complaint against Defendant, Newegg, Inc.

On January 17, 2025, Defendant filed a motion to strike.

On February 3, 2025, Plaintiff filed an opposition.

On February 7, 2025, Defendant filed a reply.

Instant Pleading

Defendant moves to strike the demands for punitive damages and attorney’s fees from the Complaint.

Decision

Defendant’s motion to strike is GRANTED with leave to amend. Plaintiff must file a First Amended Complaint by March 20, 2025.

Legal Standard

In order to state a prima facie claim for punitive damages, a complaint must set forth the elements as stated in the general punitive damage statute, Civil Code section 3294. (College Hospital, Inc. v. Superior Court (1994) 8 Cal.4th 704, 721.) These statutory elements include allegations that the defendant has been guilty of oppression, fraud or malice. (Civ. Code, § 3294, subd. (a).) 

“Malice is defined in the statute as conduct intended by the defendant to cause injury to the plaintiff or despicable conduct which is carried on by the defendant with a willful and conscious disregard of the rights or safety of others.” (College Hospital, Inc., supra, 8 Cal.4th at p. 725 [examining Civ. Code, section 3294, subd. (c)(1)].) “A conscious disregard of the safety of others may constitute malice within the meaning of section 3294 of the Civil Code. In order to justify an award of punitive damages on this basis, the plaintiff must establish that the defendant was aware of the probable dangerous consequences of his conduct, and that he willfully and deliberately failed to avoid those consequences.” (Taylor v. Superior Court (1979) 24 Cal.3d 890, 895-896.) 

“As amended to include [despicable], the statute plainly indicates that absent an intent to injure the plaintiff, ‘malice’ requires more than a ‘willful and conscious’ disregard of the plaintiffs’ interests. The additional component of ‘despicable conduct’ must be found.” (College Hospital, Inc., supra, 8 Cal.4th at p. 725.) The statute’s reference to despicable conduct represents a “new substantive limitation on punitive damage awards.” (Ibid.) Despicable conduct is “conduct which is so vile, base, contemptible, miserable, wretched or loathsome that it would be looked down upon and despised by ordinary decent people. Such conduct has been described as ‘having the character of outrage frequently associated with crime.’” (Tomaselli v. Transamerica Ins. Co. (1994) 25 Cal.App.4th 1269, 1287.) 

“[T]he imposition of punitive damages upon a corporation is based upon its own fault. It is not imposed vicariously by virtue of the fault of others.” (City Products Corp. v. Globe Indemnity Co. (1979) 88 Cal.App.3d 31, 36.) “Corporations are legal entities which do not have minds capable of recklessness, wickedness, or intent to injure or deceive. An award of punitive damages against a corporation therefore must rest on the malice of the corporation’s employees. But the law does not impute every employee’s malice to the corporation. Instead, the punitive damages statute requires proof of malice among corporate leaders: the ‘officer[s], director[s], or managing agent[s].’” (Cruz v. Home Base (2000) 83 Cal.App.4th 160, 167 [citation omitted].) As to ratification, “[a] corporation cannot confirm and accept that which it does not actually know about.’” (Ibid. [citing College Hospital, Inc., supra, 8 Cal.4th at p. 726 [for ratification sufficient to justify punitive damages against corporation, there must be proof that officers, directors, or managing agents had actual knowledge of the malicious conduct and its outrageous character]].) 

Discussion

Defendant moves to strike the demands for punitive damages and attorneys’ fees from the prayer for relief in Plaintiff’s Complaint.

The Complaint alleges that Defendant installed a program on its website (the TikTok Software) which collects data from visitors, matches it with existing data, transmits users’ identifying information, and transmits the data to TikTok. (Compl., ¶¶12-17.) Defendant did not obtain Plaintiff’s consent before using the TikTok Software to collect her data. (Id., ¶23.)

Punitive Damages

The allegations in the Complaint do not state that Defendant engaged in despicable behavior. Although the allegations that Defendant took Plaintiff’s data without her consent demonstrate that Defendant acted with a conscious disregard for Plaintiff’s rights, the facts do not show that this conduct amounted to despicable conduct sufficient to support a demand for punitive damages.

Additionally, the Complaint does not state that Defendant’s alleged malicious conduct was committed or ratified by an officer, director, or managing agent. Thus, the Complaint fails to meet the pleading standard to demand punitive damages from a corporate entity.

The Court declines to reach Defendant’s remaining arguments.

Attorney Fees

Plaintiff argues in opposition to this motion that attorney fees are permitted under Code of Civil Procedure Section 1021.5, which states in pertinent part, “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement, or of enforcement by one public entity against another public entity, are such as to make the award appropriate, and (c) such fees should not in the interest of justice be paid out of the recovery, if any.” (Code Civ. Proc., section 1021.5.) 

Here, there are no facts in the Complaint alleging this lawsuit concerns an important right affecting the public interest. Although the Complaint states the TikTok Software would collect data from visitors to Defendant’s website, there are no allegations that the software affected anyone other than Plaintiff. Additionally, the facts merely state that Defendant has been taking and transmitting visitor data through the TikTok Software. There are no facts alleging that Plaintiff prevailing in this action and stopping Defendant’s use of the TikTok Software would confer a significant public benefit. Thus, the Complaint fails to plead a basis for the recovery of attorney fees.

The motion to strike is GRANTED.

Plaintiff requests leave to amend. Although Plaintiff fails to explain how the Complaint may be amended to cure the defects described above, as the law requires that leave to amend be granted liberally, the Court will grant leave to amend.

Conclusion

Defendant’s motion to strike is GRANTED with leave to amend. Plaintiff must file a First Amended Complaint by March 20, 2025.