Beagle v. Amazon.com Inc, 2:24-cv-00316

Plaintiffs (Meredith Beagle, Jordan Guerrero, Sofauna Johnson) sued Amazon Services and Amazon.com, Inc. for allegedly disclosing personally identifiable information (PII) from Amazon Prime Video usage to Amazon's parent and affiliates without consent.
The case was filed as a putative class action, raising claims under the federal Video Privacy Protection Act (VPPA), California Civil Code § 1799.3, and originally the Washington Consumer Protection Act (CPA), though CPA claims were later dismissed.
The case underwent several amendments; Plaintiffs' prior complaints were dismissed due to failure to plausibly allege that Amazon affirmatively disclosed PII to affiliates or third parties, rather than merely provided access.
Plaintiffs' latest (third amended) complaint abandoned claims regarding disclosure to non-Amazon third parties, focusing solely on alleged disclosures to Amazon.com, Inc. and unnamed affiliates.
Plaintiffs pointed to privacy policies, data request replies, and FTC reports as circumstantial evidence, but provided no direct facts showing affirmative disclosure by Amazon Services of video PII to Amazon affiliates.
Amazon moved to dismiss under Rule 12(b)(6), arguing that mere access is insufficient to establish a VPPA or § 1799.3 violation; the court granted the motion, dismissing the action with prejudice and no leave to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Amazon affirmatively disclose Plaintiffs' PII?	Amazon gave affiliates access; privacy statements suggest sharing.	Allegations show mere access possibility, not actual affirmative disclosure.	No plausible allegation of affirmative disclosure.
Does providing access to PII equal disclosure?	Access is equivalent to disclosure under applicable law and caselaw.	Only affirmative acts—not mere access—constitute disclosure under the statutes.	Access alone is insufficient to show unlawful disclosure.
Can circumstantial evidence collectively infer disclosure?	New allegations and circumstantial evidence together suggest disclosure.	Evidence is speculative, not specific to any actual PII disclosure by Amazon.	Allegations remain speculative; inference not warranted.
Should leave to amend be granted again?	Plaintiffs sought leave to file a fourth amended complaint.	Defendants argued further amendment would be futile; deficiencies persist.	Denied; three prior amendments failed to cure deficiencies.

Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard under Rule 12(b)(6))
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (requiring factual allegations to cross from possibility to plausibility)
Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025 (court must construe pleadings in light most favorable to non-movant)
Sprewell v. Golden State Warriors, 266 F.3d 979 (court not required to accept conclusory allegations)
Allen v. City of Beverly Hills, 911 F.2d 367 (standards for granting leave to amend)