"LinkedIn was not acting "as a virtual filing cabinet," or as an offsite processor of data with respect to the user IDs it created," Koh wrote. The URL addresses of viewed pages were not sent to LinkedIn for storage or processing purposes, she said in dismissing the complaint.
Attorneys for Low could not be reached for comment at deadline.
The SCA is a frequently used statute in privacy lawsuits involving social media companies. Earlier this month, prosecutors used the provisions of the SCA to seek information from Twitter on an Occupy Wall Street protester who was being investigated for disorderly conduct.
In that case, the court ruled that the SCA did apply to Twitter and ordered the social media network to hand over the requested information despite its protests.
Jaikumar Vijayan covers data security and privacy issues, financial services security and e-voting for Computerworld. Follow Jaikumar on Twitter at @jaivijayan or subscribe to Jaikumar's RSS feed. His e-mail address is jvijayan@computerworld.com.
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