T.S. v. Body Contour Centers LLC
2:24-cv-01944
W.D. Wash.Jul 7, 2025Background
- Plaintiff filed a putative class action on behalf of California residents alleging violations of privacy and medical confidentiality due to the defendant’s use of website tracking technologies.
- Plaintiff seeks to proceed under the pseudonym "T.S." to protect her privacy regarding sensitive medical information related to weight loss surgery inquiries.
- Defendant, Body Contour Centers, LLC (d/b/a Sono Bello), does not oppose plaintiff's request for pseudonymity at this stage.
- Plaintiff’s motion argues that public disclosure of her identity would cause the precise injury (loss of medical privacy and potential embarrassment) the litigation seeks to address.
- The case is in early litigation, with motions to dismiss and for discovery stay recently addressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether T.S. can proceed pseudonymously | Disclosure would expose highly sensitive medical info, cause embarrassment, and defeat the purpose of the lawsuit | Does not oppose at this stage | Motion granted: Plaintiff may proceed under pseudonym 'T.S.' |
| Public interest in open courts versus privacy | Her identity is irrelevant to core issues; identity not central in class actions | No argument (non-opposition) | Court finds privacy outweighs public interest in this context |
| Prejudice to defendant | No prejudice since defendant does not oppose and plaintiff’s identity is not crucial | No argument (non-opposition) | Non-opposition supports no unfairness to defendant |
| Legal standard for anonymous litigation | Meets threshold where disclosure causes the very injury at issue and involves sensitive health/privacy rights | N/A | Court applies standard favorably for pseudonymity |
Key Cases Cited
- Doe v. Kamehameha Schools/Bernice Pauahi Bishop Estate, 596 F.3d 1036 (9th Cir. 2010) (general rule that parties identify themselves unless special circumstances warrant anonymity)
- Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058 (9th Cir. 2000) (outlines when pseudonymity is appropriate in federal litigation)
- Doe v. Rostker, 89 F.R.D. 158 (N.D. Cal. 1981) (most compelling cases for anonymity involve highly sensitive matters)