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hiQ Labs, Inc. v. LinkedIn Corp.

Citation: 273 F. Supp. 3d 1099Docket: Case No. 17-cv-03301-EMC

Court: District Court, N.D. California; August 14, 2017; Federal District Court

Narrative Opinion Summary

This case involves a dispute between a data analytics company, hiQ, and LinkedIn, a major social networking platform. The conflict arose when LinkedIn sent a cease and desist letter to hiQ, threatening legal action under the Computer Fraud and Abuse Act (CFAA) for hiQ's automated data scraping activities. hiQ sought a preliminary injunction, claiming LinkedIn's actions violated California's Unfair Competition Law (UCL) and free speech rights under the California Constitution. The court granted the injunction, emphasizing that hiQ demonstrated serious questions regarding the CFAA's applicability to its access of publicly available data and that the balance of hardships favored hiQ. The court was skeptical about LinkedIn's broad interpretation of the CFAA, which could jeopardize open internet access. Additionally, the court recognized serious questions about LinkedIn's conduct potentially constituting anticompetitive practices under the UCL. The injunction prevents LinkedIn from blocking hiQ's access to public profiles, highlighting potential conflicts between privacy claims and competitive practices. This case underscores significant legal considerations regarding digital access rights and competitive behavior in the context of publicly accessible online data.

Legal Issues Addressed

California Constitutional Free Speech

Application: hiQ argued that LinkedIn's actions infringed upon California's constitutional free speech protections, but the court found insufficient demonstration of a violation of constitutional rights.

Reasoning: The court finds that hiQ has not sufficiently demonstrated that LinkedIn’s actions violate its constitutional rights.

Computer Fraud and Abuse Act (CFAA) Interpretation

Application: The court is skeptical that accessing publicly available data on a website constitutes 'access without authorization' under the CFAA, especially if permission was revoked without adequate legal basis.

Reasoning: The Court is skeptical that LinkedIn's revocation of access to publicly available data amounts to 'without authorization' under the CFAA.

Preliminary Injunction Standards

Application: hiQ successfully obtained a preliminary injunction by demonstrating serious questions regarding the merits of its claims and that the balance of hardships favored its position.

Reasoning: The Court granted hiQ’s motion for a preliminary injunction, finding that the balance of hardships favors hiQ and that there are substantial questions regarding the merits of the case.

Tortious Interference with Contract

Application: hiQ's claim of tortious interference with contract depends on whether LinkedIn's actions were based on anticompetitive motives rather than legitimate business reasons.

Reasoning: If LinkedIn's actions were driven by improper anticompetitive motives, the tortious interference claim could succeed.

Unfair Competition Law (UCL)

Application: hiQ raised serious questions about LinkedIn's conduct being anti-competitive under the UCL, suggesting that LinkedIn's actions may violate antitrust principles.

Reasoning: The court acknowledges that hiQ has raised serious questions regarding its claim that LinkedIn is exploiting its market power for anticompetitive purposes.