Isiah Sheppard v. Fantasia Trading LLC
5:23-cv-02407
| C.D. Cal. | Feb 18, 2025Background
- Plaintiffs, Illinois-based delivery drivers, filed a class action against Fantasia Trading LLC (a California distributor) and Anker Innovations Limited (a Chinese manufacturer), alleging violations of Illinois’s Biometric Information Privacy Act (BIPA), specifically Sections 15(a) and 15(b).
- Plaintiffs alleged Defendants’ eufy security cameras used AI to capture and process scans of their faces/hands during deliveries, collecting and storing biometric data (facial geometry).
- Plaintiffs claimed some data was uploaded to cloud servers despite marketing that all footage was stored locally.
- The claims progressed through multiple amended complaints; after previous dismissals the court warned that further failure to state a claim would lead to dismissal without leave to amend.
- Anker moved to dismiss for insufficient service, lack of personal jurisdiction, and failure on the merits; Fantasia moved to dismiss on the merits (arguing no active collection or possession of biometric identifiers).
- The court ultimately granted both motions to dismiss—Anker for lack of personal jurisdiction in California, and Fantasia for failure to allege it actively collected, captured, or possessed biometric identifiers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Anker served properly under Rule 4 and CA law? | Service on Fantasia (subsidiary/distributor) sufficed as service | No proper service; Fantasia not a “general manager” for service | Anker was properly served under CA law via service on Fantasia |
| Does CA have personal jurisdiction over Anker? | Anker purposefully availed by using CA ports for distribution | No specific jurisdiction; injuries occurred in IL, contacts with CA are attenuated | No specific jurisdiction—insufficient nexus; claims dismissed as to Anker |
| Did Fantasia collect/capture/possess biometric identifiers under BIPA? | eufy system uploads data to cloud, Fantasia is involved | Fantasia did not take active steps to collect or possess biometric data | Plaintiffs failed to allege Fantasia actively collected/possessed biometric identifiers |
| Are the stored images/“thumbnails” biometric identifiers under BIPA? | Cloud-stored thumbnails were biometric identifiers | Thumbnails not sufficiently tied to biometric ID; BIPA excludes photos | Thumbnails not biometric identifiers; plaintiffs failed to allege biometric scans |
Key Cases Cited
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (articulates the minimum contacts standard for personal jurisdiction)
- Ford Motor Co. v. Montana Eighth Judicial Dist. Court, 592 U.S. 351 (2021) (clarifies "arise out of" and "relate to" standard for specific jurisdiction)
- Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (1987) (weighs factors of convenience, state interest, and fairness in personal jurisdiction questions)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability and limits on personal jurisdiction for product sellers)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (further explaining plausibility standard in complaints)
- Helictopteros Nacionales de Colombia S.A. v. Hall, 466 U.S. 408 (1984) (general vs. specific jurisdiction)