[HN Gopher] Ninth Circuit Takes a Wrecking Ball to Internet Pers...
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       Ninth Circuit Takes a Wrecking Ball to Internet Personal
       Jurisdiction Law
        
       Author : hn_acker
       Score  : 43 points
       Date   : 2025-04-23 19:09 UTC (3 hours ago)
        
 (HTM) web link (blog.ericgoldman.org)
 (TXT) w3m dump (blog.ericgoldman.org)
        
       | hn_acker wrote:
       | The full title is:
       | 
       | > Ninth Circuit Takes a Wrecking Ball to Internet Personal
       | Jurisdiction Law-Briskin v. Shopify
        
         | topspin wrote:
         | What law was wrecked? The outcome appears to be the upholding
         | of a CA law.
        
           | Aloisius wrote:
           | Case law on internet-specific personal jurisdiction made by
           | the district court, presumably.
        
       | Alupis wrote:
       | I suspect this has something to do with "Shop Pay", Shopify's own
       | payment system used on most (all?) Shopify stores. It enables you
       | to have saved payment information for any Shopify store you come
       | across, facilitating one-click checkout even if you have never
       | shopped on that particular brand/website before. Webshop
       | operators love it because it is very good at fraud detection (due
       | to the pooled data on the backend), and removes barriers at
       | checkout (needing your wallet, fill out an address form, etc). As
       | far as I'm aware, it's optional on the Shopify platform. Using
       | Shop Pay for payment is optional on the consumer level.
       | 
       | I suspect Shopify's terms inform their customers (webshop
       | operators) that they are responsible for disclosure, etc and
       | being compliant with state privacy laws - however since majority
       | of web shops are exempt (due to small size, revenue, etc), these
       | shops did not (knowingly or otherwise) publish these terms.
       | That's just speculation on my part...
       | 
       | If this is true, I find this case troubling and weak, and hope it
       | is overturned. It is squarely on the shop operator to be
       | compliant - Shopify is just a platform vendor and shoppers are
       | not Shopify customers; rather, they are customers of the shop.
       | This seems to be akin to suing Google because a website uses
       | Google Analytics but didn't disclose it in their privacy
       | statement - silly...
       | 
       | This particular case gives me ADA and Prop65 vibes... lots of
       | bottom-feeding lawyers using serial plaintiffs to extort
       | businesses out of money. At least in this case they're going
       | after someone with deep pockets and not just small businesses...
        
         | chocolatkey wrote:
         | Stripe also has a version of this called "Link", which uses SMS
         | authentication. Based on Stripe data on multiple platforms I
         | have access to, quite a high percentage of people use it,
         | probably due to how hard it's pushed by the UI when adding a
         | payment method
        
         | ndriscoll wrote:
         | I'm not familiar enough with California's law to know whether
         | companies like Shopify/Google are meant to be liable (in the
         | sense that the law says so), but certainly it would be a great
         | thing if the companies actually performing the mass
         | surveillance (Google, Shopify) _were_ liable even if the
         | payload deliverer is small. Absolutely what is needed is law
         | saying that Google can be sued (or better, held criminally
         | liable for harassment /stalking) for spying on people through
         | its Google Analytics program, among others.
         | 
         | Relentlessly stalking millions of people makes it millions of
         | times worse than stalking one person, not somehow okay.
        
           | rkagerer wrote:
           | Or hold enough of those small actors to account that nobody
           | wants to do business with Google Analytics in its current
           | form.
           | 
           | It disgusts me that companies who want to transact with me
           | don't vet their partners better. Off-Meta is another one
           | that's despicable. Companies like my bank or their partners
           | have NO business uploading lists of their users to third
           | parties like that (even if it was induced by use of their
           | analytics SDK's).
        
         | pessimizer wrote:
         | > It is squarely on the shop operator to be compliant - Shopify
         | is just a platform vendor and shoppers are not Shopify
         | customers; rather, they are customers of the shop.
         | 
         | I disagree energetically. If Shopify wants to run a service
         | identifying people between every site that it serves as a
         | backend to, it should ask those people if they want to be
         | included in that. The only alternative to stop the illegal
         | activity otherwise is to print a list of Shopify's customers,
         | and visit (and sue) them one by one in California. Shopify is
         | running the service, and the shop owner probably doesn't even
         | know how it works.
         | 
         | I'd even think that a shop owner sued over this should in turn
         | be able to sue Shopify. If Shopify knows that something it does
         | is not legal in California, it should tell its clients who may
         | do business in California.
        
           | Alupis wrote:
           | You opt-into using Shop Pay, as a consumer. By default you
           | are in "guest" mode.
           | 
           | > If Shopify knows that something it does is not legal in
           | California
           | 
           | This is what is being debated. This ruling is mostly expected
           | out of the 9th... we'll see what happens when a real court
           | hears this case.
        
             | Aloisius wrote:
             | What are the odds the Supreme Court hears this?
        
               | Alupis wrote:
               | Your guess is as good as mine. I doubt Shopify will let
               | this rest, since the consequences are fairly huge.
        
         | nozzlegear wrote:
         | > If this is true, I find this case troubling and weak, and
         | hope it is overturned. It is squarely on the shop operator to
         | be compliant - Shopify is just a platform vendor and shoppers
         | are not Shopify customers; rather, they are customers of the
         | shop. This seems to be akin to suing Google because a website
         | uses Google Analytics but didn't disclose it in their privacy
         | statement - silly...
         | 
         | Most of my work is in the Shopify app dev ecosystem, and while
         | I haven't been following this case very closely, I do think
         | it's ironic how Shopify is behaving here given the privacy
         | standards they enforce on their app developers.
         | 
         | Some context: all Shopify app developers are required to follow
         | the EU's GDPR rules for customer data, full stop. Your app
         | _must_ implement Shopify 's mandatory GDPR webhooks. You _must_
         | delete customer data when a shop 's customer is deleted; you
         | must produce all data you store on a shop's customer within 7
         | days upon receipt of a certain GDPR webhook; and you must
         | delete all the data you store on the shop itself after the shop
         | uninstalls your app.
         | 
         | Additionally, if your app requires access to any customer data
         | (whether its via the Customer API, or via other APIs e.g. to
         | get the name of a customer who placed an order), you need to
         | apply for access to that data on an app-by-app basis - replete
         | with an explanation for why your app needs the data. Shopify's
         | app store staff has to manually review and approve that data
         | access application before you can publish your app on their app
         | store.
         | 
         | To be clear, I think these restrictions are a good thing+, as
         | apps used to have access to a veritable firehose of private
         | customer data. But it's ironic to see Shopify enforce such
         | standards on their app developers, while at the same time
         | arguing that they should be able to track their own potential
         | customers anywhere and everywhere across the internet
         | regardless of privacy laws.
         | 
         | + Though I think it's a little odd that a Canadian company is
         | making me, an American app developer, think about/adhere to the
         | EU's GDPR rules. Not to mention other privacy laws like the one
         | in California. Why not just call it "Shopify's Privacy
         | Standards?"
        
       | getcrunk wrote:
       | Backstory from eff:
       | 
       | https://www.eff.org/deeplinks/2024/07/courts-should-have-jur...
        
       | nickff wrote:
       | This seems like a very strange reading of "express aiming";
       | instead of those words meaning that a person has done something
       | to 'target', it means that the person did not 'expressly avoid'?
       | I am not sure that "expressly aim" has much meaning at all in
       | this reading.
       | 
       | I don't have any horse in this race, though I know the EFF is
       | very popular on HN, and that many people here are also against
       | data collection.
        
         | 3np wrote:
         | I guess it's just a coincidence that the California Shopify
         | meetup groups are abandoned without notice?
        
       | 3np wrote:
       | > What Could Shopify Have Done Differently?
       | 
       | For completion I think "cease to insecurely extract, aggregate
       | and abuse all that user data" should also be mentioned as an
       | alternative to the different ways they could skirt regulation.
        
         | johnea wrote:
         | I was going to quote, and respond in almost the exact same way.
         | 
         | The only change I would make to your suggestion would be to
         | remove the word "insecurely".
         | 
         | They shouldn't extract or aggregate user data in any fashion
         | whatsoever.
        
         | clucas wrote:
         | You're misunderstanding the question - he's asking how Shopify
         | could avoid _jurisdiction_ , not avoid this suit. Jurisdiction
         | is a threshold question before you get to the merits... maybe
         | Shopify did the bad thing, maybe they didn't, but before we
         | decide that, we need to determine if California law even
         | applies to Shopify.
         | 
         | The author seems to think that there should be some way for
         | Shopify to avoid jurisdiction while still offering services in
         | California, but I don't really understand why he thinks so.
        
           | otterley wrote:
           | As a former student of the author, I don't think he's saying
           | they _should_ be able to avoid jurisdiction. I think he was
           | musing on whether it would even be possible under this new
           | Ninth Circuit framework /test. He concludes it's unlikely,
           | and hence for Shopify (or any other company putting cookies
           | in browsers) to have any chance of avoiding it, they're going
           | to have to appeal to SCOTUS.
        
       | dpifke wrote:
       | The "online retailer" (IABMFG) in this case is based in
       | California.
       | 
       | A company in California, selling to a customer in California,
       | shouldn't be able to say "California law doesn't apply because my
       | payment processor is Canadian." And if Shopify wants to take a
       | cut of every sale from retailers based in California, they should
       | be willing to comply with California law as well, at least
       | insofar as it applies to the services provided via those
       | California-based retailers' web sites.
       | 
       | (The actual opinion is linked at the bottom of the submission; I
       | humbly suggest folks commenting here should read it first:
       | https://cdn.ca9.uscourts.gov/datastore/opinions/2025/04/21/2...)
        
         | otterley wrote:
         | To be clear, this isn't a choice-of-law case. It's not about
         | whether California law applies. It's about whether a court in
         | California has jurisdiction; that is, whether it can hear the
         | case _at all._
        
           | dpifke wrote:
           | Could a tort claim under California state law be heard in any
           | other court (assuming no accompanying Federal claims)?
        
             | otterley wrote:
             | Yes. Choice-of-law terms are frequently found in contracts.
             | When interpreting the law, the court with jurisdiction will
             | do its best to refer to and interpret existing law of the
             | state in question to the case.
        
       | healsdata wrote:
       | > then more privacy-protective option are not feasibly available
       | to Shopify
       | 
       | I haven't laughed that hard in awhile. Poor Shopify, they
       | couldn't possibly protect the privacy and data of their
       | customers.
        
       | djoldman wrote:
       | The part where many may object:
       | 
       | > First, the majority might say that Shopify should not engage in
       | privacy-invasive activities. I didn't invest the energy to figure
       | out the irreducible privacy elements of the plaintiffs' claims,
       | but if using cookies to track users is an essential part of the
       | claim, then more privacy-protective option are not feasibly
       | available to Shopify.
        
       | Glyptodon wrote:
       | Maybe the line of reasoning offered and argued against is
       | dubious. But IMO there are literally dozens of other arguments
       | that will come to the same conclusion if you want to avoid hand
       | waving about the particular bits the author raises.
       | 
       | By and large states having different laws is a pain, but arguing
       | that you can do business in every state while only following the
       | laws of one state is a very messy rejection of state's rights,
       | and leads to using the commerce clause to basically negate most
       | state level regulations and jurisdiction.
        
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