M.G. v. Therapymatch, Inc.
3:23-cv-04422
| N.D. Cal. | May 19, 2025Background
- Plaintiff M.G. filed suit against Therapymatch, Inc. (d/b/a Headway), alleging improper disclosure of personal and medical information entered on the defendant’s online platform for connecting with mental health providers.
- The claims center on alleged violations of the California Confidentiality of Medical Information Act (CMIA) and the California Consumer Privacy Act (CCPA) resulting from information being transmitted to and accessed by Google.
- Headway moved to dismiss the third amended complaint (TAC) under Rule 12(b)(6), arguing failure to state a claim.
- The court previously dismissed the CMIA claim due to insufficient allegations regarding "medical information," but allowed other claims to proceed.
- The TAC included new factual allegations detailing the substantive medical and personal information M.G. provided.
- The court reviewed the motion to dismiss and supporting papers, deciding without oral argument.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| CMIA claim – Medical Information | Disclosed substantive medical info and identifiers to Headway. | Info disclosed wasn't "medical information." | Sufficient facts alleged for claim. |
| CMIA claim – Improper Viewing | Google accessed info for its own analytics/ad purposes. | No medical info was transmitted or viewed. | Access by Google plausibly alleged. |
| CCPA claim | Claims under CCPA sufficiently stated in earlier complaints. | CCPA claim should be dismissed anew. | Successive challenge barred; denied. |
| Judicial Notice (re CCPA) | Issue is moot due to denial of dismissal on CCPA grounds. | N/A | Judicial notice request denied as moot |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard of plausibility for Rule 12(b)(6))
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (articulating plausibility standard in complaints)
- Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025 (standard for accepting facts as true on a motion to dismiss)
- Godecke v. Kinetic Concepts, Inc., 937 F.3d 1201 (Rule 12(b)(6) requires plausible facts or a cognizable legal theory)
- Levitt v. Yelp! Inc., 765 F.3d 1123 (complaints must provide fair notice and factual underpinnings to claims)
- Hinds Investments, L.P. v. Angioli, 654 F.3d 846 (identifying grounds for dismissal under Rule 12(b)(6))
- Eisenhower Medical Center v. Superior Court, 226 Cal. App. 4th 430 (defining "medical information" under CMIA)
- Regents of University of California v. Superior Court, 220 Cal. App. 4th 549 (interpreting improper access under CMIA)