In a swift rebuke to a burgeoning wave of web privacy class actions, U.S. District Judge David O. Carter dismissed Travis Rounds v. Development Dimensions International, Inc. without leave to amend, ruling that common website analytics tools do not violate California’s anti-wiretapping law. Travis Rounds v. Development Dimensions Int’l, Inc., 2026 WL 746291 (C.D. Cal. Mar. 11, 2026).
The Allegations
Plaintiff Travis Rounds accused DDI, a Delaware-based leadership consulting firm, of illegally “deanonymizing” website visitors using 6Sense’s data-broker software. Rounds claimed the tool captured his geolocation, device info, and browser cookies to build secret profiles—amounting to an unauthorized “trap-and-trace” device under Penal Code § 638.51, a statute targeting phone surveillance.
Court’s Decisive Blow
DDI countered that it didn’t target California and that cookies aren’t trap-and-trace tech, which legally records only call-originating signals like phone numbers—not web data. Judge Carter had previously dismissed Plaintiff’s lawsuit after finding that the court lacked personal jurisdiction over the Delaware corporation and had granted Plaintiff leave to amend the Complaint. Subsequently, in its order dismissing the Amended Complaint, Judge Carter again agreed with Defendant’s arguments, finding the claims implausibly stretched a telecom law to modern websites. Without a valid violation, California lacked personal jurisdiction over out-of-state DDI, ending the case cold.
Implications
Judge Carter’s dismissal without leave to amend is the latest in a growing trend of courts refusing to stretch CIPA’s “trap-and-trace” provisions—originally for phone surveillance—to include standard web trackers like cookies or SDKs from providers such as 6Sense. Defense counsel can now also cite this precedent to argue that capturing geolocation, device info, or browser data doesn’t qualify, enabling early motions to dismiss on the merits. In addition, the court emphasized that a California court can only hear cases against out-of-state defendants if they have sufficient “minimum contacts” with the forum and the claims plausibly arise from those contacts. Judge Carter held that because cookie-based tracking does not violate CIPA’s trap-and-trace law, no claims arise from the defendant’s contacts with the state and therefore dismissal followed automatically.
