Narrative Opinion Summary
The case involves a putative class action filed by the Plaintiffs against Redbox, alleging unlawful disclosure of personal information during video rentals, thus violating Michigan's Video Rental Privacy Act (VRPA), and claiming breach of contract and unjust enrichment under state law. Redbox, a video rental company, allegedly shared customer information with third-party vendors without proper consent, contrary to its Terms of Use and Privacy Policy. Both parties moved for summary judgment. The court examined whether customers consented to data sharing through the Terms of Use, which incorporated an Illinois choice of law clause, thereby excluding the Michigan Uniform Electronic Transactions Act (UETA) from applicability. The court upheld the Terms of Use as binding, determining that Plaintiffs consented to the disclosures as outlined in Redbox's Privacy Policy. Given the lack of evidence for unauthorized disclosures, the court granted summary judgment for Redbox, dismissing Plaintiffs' claims with prejudice. The court also noted the inapplicability of Michigan law due to the agreed Illinois choice of law, barring Plaintiffs from fully recovering under the VRPA, breach of contract, and unjust enrichment claims.
Legal Issues Addressed
Application of Illinois Law over Michigan UETAsubscribe to see similar legal issues
Application: The Terms of Use included an Illinois choice of law clause, precluding the application of the Michigan UETA to the contract's enforceability.
Reasoning: Notably, they agreed to an Illinois choice of law clause, which governs the Terms and is significant because Illinois has not adopted the UETA.
Breach of Contract and Unjust Enrichmentsubscribe to see similar legal issues
Application: Plaintiffs claim breach of contract and unjust enrichment under state law, which are contingent upon the alleged violations of the VRPA.
Reasoning: They also claim breach of contract and unjust enrichment under state law.
Consent through Terms of Usesubscribe to see similar legal issues
Application: The court found that by accepting the Terms of Use, Plaintiffs granted permission for Redbox to disclose information as described in the Privacy Policy.
Reasoning: By accepting the Terms of Use, Plaintiffs granted permission for Defendant to disclose information as described in the Privacy Policy.
Summary Judgment Standard under Rule 56subscribe to see similar legal issues
Application: The Court granted summary judgment in favor of Redbox, finding no genuine dispute of material fact that would preclude judgment as a matter of law.
Reasoning: The Court granted Defendant’s Motion for Summary Judgment, denied Plaintiffs’ Motion for Partial Summary Judgment, and dismissed Plaintiffs’ Complaint with prejudice.
Violation of Michigan's Video Rental Privacy Act (VRPA)subscribe to see similar legal issues
Application: The Plaintiffs allege that Redbox disclosed Personal Viewing Information to third parties without consent, violating the VRPA.
Reasoning: Plaintiffs, both Michigan residents, have used Redbox services extensively and filed a complaint on November 11, 2012, under the Class Action Fairness Act alleging that Redbox disclosed Personal Viewing Information to third parties without consent, violating Michigan’s Video Rental Privacy Act (VRPA).