Case 5:20-cv-08204-SVK Document 1 Filed 11/20/20 Page 1 of 12
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`Rafey Balabanian (SBN 315962)
`rbalabanian@edelson.com
`Todd Logan (SBN 305912)
`tlogan@edelson.com
`Brandt Silver-Korn (SBN 323530)
`bsilvercorn@edelson.com
`EDELSON PC
`123 Townsend Street, Suite 100
`San Francisco, California 94107
`Tel: 415.212.9300
`Fax: 415.373.9435
`
`Antonio M. Romanucci (pro hac vice pending)
`aromanucci@rblaw.net
`Bryce T. Hensley (pro hac vice pending)
`bhensley@rblaw.net
`David A. Neiman (pro hac vice pending)
`dneiman@rblaw.net
`ROMANUCCI & BLANDIN, LLC
`321 North Clark Street, Suite 900
`Chicago, Illinois 60654
`Tel: 312.458.1000
`Fax: 312.458.1004
`
`Counsel for Plaintiffs and the Putative Class
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`Case No.
`
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`CLASS ACTION COMPLAINT FOR:
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`(1) Violation of Cal. Bus. & Bus. Prof.
`Code § 17200, et seq.
`(2) Fraud
`(3) Accounting
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`Defendant.
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`DEMAND FOR JURY TRIAL
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`CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
`Plaintiffs Drew Krisco (“Krisco”) and Livly, Inc. (“Livly”) bring this Class Action
`Complaint and Demand for Jury Trial against Defendant LinkedIn Corporation (“LinkedIn”) to seek
`compensation for Defendant overcharging advertisers and misrepresenting the reliability of the data
`produced by its advertising platform. Plaintiffs allege as follows upon personal knowledge as to
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`CLASS ACTION COMPLAINT
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`v.
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`Plaintiffs,
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`DREW KRISCO, an individual, and LIVLY,
`INC., a Delaware corporation, individually and
`on behalf of all others similarly situated,
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`LINKEDIN CORPORATION, a Delaware
`corporation,
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`Case 5:20-cv-08204-SVK Document 1 Filed 11/20/20 Page 2 of 12
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`themselves and their own acts and experiences, and, as to all other matters, upon information and
`belief.
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`NATURE OF THE ACTION
`1.
`On November 12, 2020, Defendant LinkedIn stated on its own blog that “[i]n
`August, our engineering team discovered and then subsequently fixed two measurement issues in
`our ads products that may have overreported some Sponsored Content campaign metrics for
`impression and video views.” Defendant revealed that these “issues” impacted hundreds of
`thousands of LinkedIn advertisers, undetected, over the span of at least two years.
`2.
`Specifically, advertisers were overcharged and overpaid for advertisements on
`LinkedIn’s platform, all while relying on LinkedIn’s assurances that their advertising metrics were
`accurate and reliable.
`3.
`While LinkedIn has tried to downplay the impact of this failure to monitor and
`control its own advertising platform, the total extent of the damage to their customers is not yet
`known. Nor is there conclusive proof that these problems have been fully rectified and that other
`unknown “measurement issues” may not lurk in its vast system.
`4.
`Above and beyond simply overpaying for mismeasured ads, Plaintiffs and members
`of the Class paid for an unknown number of ineffective ads, losing out on the opportunity to serve
`effective ads that would have fulfilled the purposes of the advertisements. Had Plaintiffs and
`members of the Class known of the lack of reliability in choosing to place ads with LinkedIn, they
`would have taken their ad dollars to other competitive platforms.
`5.
`Plaintiffs therefore bring this Complaint to seek compensation for the amount they
`were overcharged, as well as seek an accounting of their ad accounts, along with those of the Class,
`to ensure that the payments they have made are consistent with the services they received.
`PARTIES
`6.
`Plaintiff Drew Krisco is a natural person and resident of the State of Illinois. Mr.
`Krisco is a current customer of Defendant LinkedIn.
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`CLASS ACTION COMPLAINT
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`Case 5:20-cv-08204-SVK Document 1 Filed 11/20/20 Page 3 of 12
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`7.
`Plaintiff Livly, Inc. is a corporation incorporated under the laws of the State of
`Delaware, with its principial place of business located at 1325 West Randolph Avenue, Chicago,
`Illinois 60607. Livly is a current customer of Defendant LinkedIn.
`8.
`Defendant LinkedIn Corporation is a corporation incorporated under the laws of the
`State of Delaware, with its principial place of business located at 1000 West Maude Avenue,
`Sunnyvale, California 94085.
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`JURISDICTION AND VENUE
`9.
`This Court has subject matter jurisdiction over Plaintiffs’ claims under 28 U.S.C. §
`1332(d)(2) because, as to all proposed Class members, (a) at least one member of the Class, which
`consists of at least 100 members, is a citizen of a different state than Defendant, (b) the amount in
`controversy exceeds $5,000,000, exclusive of interest and costs, and (c) none of the exceptions
`under that subsection apply to this action.
`10.
`This Court has personal jurisdiction over Defendant because it transacts business in
`this State, and because the tortious conduct alleged in this Complaint occurred in, was directed to,
`and/or emanated from this State.
`11.
`Venue is proper in this District under 28 U.S.C. § 1391 because Defendant conducts
`business transactions in this District, and because the wrongful conduct giving rise to this case
`occurred in, was directed to, and/or emanated from this District.
`FACTUAL BACKGROUND
`12.
`LinkedIn is a global professional networking site, offering numerous professional
`services for job seekers, professionals, recruiters, and employers. With LinkedIn, users create an in-
`depth professional profile, and user information is standardized by education, profile headlines,
`profile experience and a customer’s prior experience. LinkedIn has branded itself as “the place to
`find and be found.”
`13. With this enormous draw to facilitate networking, LinkedIn has over 706 million
`total users, with more than 260 million monthly active users. As such, this creates a robust and
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`CLASS ACTION COMPLAINT
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`active audience for an untold number of advertisers to buy a wide range of advertisements, a core
`aspect of LinkedIn’s business model.
`14.
`Not unlike with Facebook or Google, advertisers pay extortionary amounts to reach
`target audiences and rely on platforms like LinkedIn to be honest brokers in how they track,
`monitor, and charge for those ads. While advertisers have certain tools available to them to track
`their own ads, certain information can only be known and conveyed by LinkedIn itself, leaving
`advertisers in a vulnerable position to act in blind reliance on LinkedIn’s own metrics and reporting.
`15.
`In November of 2020, LinkedIn revealed that it had taken advantage of that
`vulnerability through its own failures to properly design and audit its advertising system.
`16.
`In its own words, “In August, our engineering team discovered and then
`subsequently fixed two measurement issues in our ads products that may have overreported some
`Sponsored Content campaign metrics for impression and video views. Together these issues
`potentially impacted more than 418,000 customers over a two plus year period.”1
`17.
`Additional reporting on this issue revealed:
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`With video ads, LinkedIn discovered that some organic videos and video ads would
`play while they were off-screen on Apple Inc.’s iOS devices.
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`If a LinkedIn user scrolled past a video ad while the video was buffering, for
`example, the ad would autoplay even when out of view, but still be tracked and
`logged as a video view or completion.
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`That may have resulted in overstated measures including video views and view-
`through rates, as well as overcharging advertisers paying by the view, according to a
`LinkedIn spokesman.
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`The company also said it may have been overreporting impressions on sponsored-
`content campaigns in the LinkedIn feed—for example, in cases when users would
`rotate their phones or quickly move to other parts of the app, the spokesman said.2
`
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`We discovered two measurement issues. Here’s how we’re making it right., LinkedIn,
`1
`https://business.linkedin.com/marketing-solutions/blog/linkedin-news/2020/how-we-re-working-to-
`improve.
`2
`LinkedIn Finds Measurement Errors That Inflated Video and Ad Metrics, THE WALL STREET
`JOURNAL, https://www.wsj.com/articles/linkedin-finds-measurement-errors-that-inflated-video-and-
`ad-metrics-11605228577.
`CLASS ACTION COMPLAINT
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`18. What’s worse, based on publicly available information, LinkedIn allegedly
`discovered this issue in August 2020, but waited at least two months to fix it and provide any kind
`of notice to its customers.
`19.
`During this time, millions of advertisers bought untold amounts of advertising on the
`LinkedIn platform, with absolutely no notice of ongoing or previous failures to properly track and
`monitor advertising performance.
`20.
`Of course, this same issue had been ongoing for two years without notice or
`explanation, impacting billions of ad dollars spent with Defendant LinkedIn.
`PLAINTIFF KRISCO’S EXPERIENCE
`21.
`Plaintiff Krisco is in the real estate business.
`22.
`Starting in 2020, Plaintiff Krisco purchased advertisements on the LinkedIn platform
`to promote job opportunities.
`23.
`Krisco became aware of the mismeasurement issues in November 2020. Without
`detailed information from LinkedIn, Krisco is unaware of the details of what ads were impacted,
`when any issues occurred, or the full nature of the damage he suffered.
`PLAINTIFF LIVLY’S EXPERIENCE
`24.
`Plaintiff Livly is a software and mobile app developer that provides products for the
`property management industry.
`25.
`Starting in 2020, Livly purchased advertisements on the LinkedIn platform to build
`brand awareness and drive potential customers to its website.
`26.
`Livly became aware of the mismeasurement issues in November 2020. Without
`detailed information from LinkedIn, Livly is unaware of the details of what ads were impacted,
`when any issues occurred, or the full nature of the damage it suffered.
`CLASS ALLEGATIONS
`Class Definition: Plaintiffs bring this action pursuant to Federal Rule of Civil
`27.
`Procedure 23 on behalf of himself and the Class defined as follows:
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`CLASS ACTION COMPLAINT
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`Case 5:20-cv-08204-SVK Document 1 Filed 11/20/20 Page 6 of 12
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`All persons or entities who, during the relevant statute of limitations
`period, paid to place advertisements with Defendant LinkedIn.
`Excluded from the Class are: (1) any Judge or Magistrate presiding over this action and
`members of their families; (2) Defendant, Defendant’s subsidiaries, parents, successors,
`predecessors, and any entity in which Defendant or its parents have a controlling interest and its
`current or former employees, officers and directors; (3) persons who properly execute and file a
`timely request for exclusion from the Class; (4) persons whose claims in this matter have been
`finally adjudicated on the merits or otherwise released; (5) Plaintiffs’ counsel and Defendant’s
`counsel; and (6) the legal representatives, successors, and assigns of any such excluded persons.
`Numerosity: The exact number of members of the Class is unknown and not
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`available to Plaintiffs at this time, but it is clear that individual joinder is impracticable. On
`information and belief, Defendant has refused to reimburse thousands of agents like and including
`Plaintiffs.
`Commonality and Predominance: There are many questions of law and fact
`29.
`common to the claims of Plaintiffs and the Class, and those questions predominate over any
`questions that may affect individual members of the Class. Common questions for the Class
`include, but are not necessarily limited to, the following:
`a. Whether LinkedIn’s actions were likely to deceive members of the public and
`those constituted a fraudulent business practice under California’s Unfair
`Competition Law (UCL), Cal. Bus. & Prof. Code § 17200;
`b. Whether LinkedIn made material misrepresentations about its advertising
`services;
`c. Whether LinkedIn’s failure to properly audit and verify its advertising metrics
`was unfair, deceptive, untrue and misleading, and constitutes an unfair and
`fraudulent business practice under the UCL;
`d. Whether LinkedIn breached its contract with Plaintiffs and the Class by reporting
`inaccurate advertising metrics.
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`CLASS ACTION COMPLAINT
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`Typicality: Plaintiffs’ claims are typical of the claims of other members of the Class,
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`in that Plaintiffs and members of the Class sustained damages arising out of Defendant’s uniform
`wrongful conduct.
`Adequate Representation: Plaintiffs will fairly and adequately represent and
`31.
`protect the interests of the Class, and have retained counsel competent and experienced in complex
`litigation and class actions. Plaintiffs’ claims are representative of the claims of the other members
`of the Class. That is, Plaintiffs and members of the Class sustained damages as a result of
`Defendant’s uniform conduct. Plaintiffs also have no interests antagonistic to those of the Class, and
`Defendant have no defenses unique to Plaintiffs. Plaintiffs and their counsel are committed to
`vigorously prosecuting this action on behalf of the members of the Class, and have the financial
`resources to do so. Neither Plaintiffs nor their counsel have any interest adverse to the Class.
`Policies Generally Applicable to the Class: This class action is appropriate for
`32.
`certification because Defendant have acted or refused to act on grounds generally applicable to the
`Class as a whole, thereby requiring the Court’s imposition of uniform relief to ensure compatible
`standards of conduct toward members of the Class, and making final injunctive relief appropriate
`with respect to the Class as a whole. Defendant’s practices challenged herein apply to and affect
`members of the Class uniformly, and Plaintiffs’ challenge of those practices hinges on Defendant’s
`conduct with respect to the Class as a whole, not on facts or law applicable only to Plaintiffs.
`Superiority: This case is also appropriate for class certification because class
`33.
`proceedings are superior to all other available methods for the fair and efficient adjudication of this
`controversy given that joinder of all parties is impracticable. The damages suffered by the
`individual members of the Class will likely be relatively small, especially given the burden and
`expense of individual prosecution of the complex litigation necessitated by Defendant’s actions.
`Thus, it would be virtually impossible for the individual members of the Class to obtain effective
`relief from Defendant’s misconduct. Even if members of the Class could sustain such individual
`litigation, it would still not be preferable to a class action, because individual litigation would
`increase the delay and expense to all parties due to the complex legal and factual controversies
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`CLASS ACTION COMPLAINT
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`presented in this Complaint. By contrast, a class action presents far fewer management difficulties
`and provides the benefits of single adjudication, economy of scale, and comprehensive supervision
`by a single court. Economies of time, effort, and expense will be fostered, and uniformity of
`decisions ensured.
`34.
`Plaintiffs reserve the right to revise the foregoing “Class Allegations” and “Class
`Definition” based on facts learned through additional investigation and discovery.
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`FIRST CAUSE OF ACTION
`CALIFORNIA UNFAIR COMPETITION LAW,
`CAL. BUS. & PROF. CODE § 17200, et seq.
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`
`35.
`Plaintiffs incorporate the foregoing allegations as if fully set forth herein.
`36.
`LinkedIn violated California’s Unfair Competition Law, Cal. Bus. & Prof. Code
`§ 17200 et seq., by engaging in the fraudulent and unfair business acts and practices alleged, as
`further specified below.
`37.
`LinkedIn’s dissemination of inaccurate and inflated advertising metrics constitutes a
`fraudulent practice under the UCL, as it is likely to deceive Class members into believing that their
`paid advertisements generated a highly inflated number of impressions.
`38.
`LinkedIn’s failure to properly audit and verify the accuracy of its advertising metrics
`before disseminating them to Class members is unfair, deceptive, untrue and misleading, and
`constitutes an unfair and fraudulent business practice under the UCL. LinkedIn’s practice was also
`contrary to legislatively declared and public policies that seek to protect consumers from misleading
`statements. See, e.g., Federal Trade Commission Act (15 U.S.C. § 45); Consumers Legal Remedies
`Act (Cal. Civ. Code § 1750 et seq.); and California False Advertising Law (Cal Bus. & Prof. Code §
`17500). The harm these practices caused to Plaintiffs and the Class members outweigh their utility,
`if any.
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`39.
`Prior to November 2020, LinkedIn knew or through reasonable investigation should
`have known that its advertising metrics were inaccurate and inflated, and had LinkedIn properly
`audited and verified its advertising metrics it would have known that those metrics were inaccurate
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`CLASS ACTION COMPLAINT
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`and inflated. The calculation errors that LinkedIn allowed to persist for over two years were obvious
`errors that would have been discovered by a reasonable auditing and verification process.
`40.
`LinkedIn’s failure to employ reasonable auditing and verification procedures gave it
`an unfair competitive advantage, as it allowed LinkedIn to provide video-advertising services at a
`lower cost and made those advertising services appear to be more effective than they were.
`41.
`Plaintiffs have standing to bring these claims under the UCL because they were
`injured and lost money or property, including, but not limited to money paid for LinkedIn
`advertisements, as a result of LinkedIn’s fraudulent and unfair business practices. Among other
`things, Plaintiffs would not have bought as much advertising services if LinkedIn had not
`disseminated inflated metrics and would have paid a lower price for the advertising services they
`did purchase.
`42.
`Pursuant to Cal. Bus. & Prof. Code § 17203, Plaintiffs seek equitable relief to
`prevent the continued use of LinkedIn’s unfair and fraudulent practices and to restore to the Class
`all money LinkedIn may have acquired by means of its fraudulent and unfair business practices.
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`SECOND CAUSE OF ACTION
`FRAUD
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`43.
`Plaintiffs incorporate the foregoing allegations as if fully set forth herein.
`44.
`LinkedIn falsely represented the number of impressions generated by Plaintiffs’ and
`Class members’ advertisements.
`45.
`LinkedIn either (i) knew that the metrics it was reporting to Plaintiffs and Class
`members was false; or (ii) reported those metrics recklessly and without regard for their truth.
`46.
`And even if LinkedIn’s statement is true—and it failed to discover the issue until
`August 2020—it still knowingly disseminated false metrics for several additional months. The
`persistence of LinkedIn’s false metrics was possible only because LinkedIn did not take verification
`of its metrics seriously, severely understaffed the engineering team in charge of fixing errors, did
`not fully investigate or correct errors that were reported to it, and refused to allow third-party
`verification of its metrics.
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`CLASS ACTION COMPLAINT
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`47.
`LinkedIn intended that Plaintiffs and Class members rely on its metrics. LinkedIn
`promoted the metrics to users to demonstrate the supposed effectiveness of paid advertisements on
`its platform, knew that its metrics were relevant and material to advertisers, and concealed the fact
`that its recklessness had caused the metrics to be inflated because it knew that would hurt user trust
`and result in advertisers purchasing fewer ads.
`48.
`Plaintiffs and Class members did rely on LinkedIn’s inflated impressions metrics
`when deciding whether and how to purchase video advertising from LinkedIn. As a result of the
`inflated metrics, Plaintiffs and Class members purchased more advertising from LinkedIn than they
`otherwise would have and paid a higher price than they otherwise would have.
`49.
`Plaintiffs seek an award of compensatory and punitive damages. LinkedIn’s conduct
`as previously described constitutes oppression, fraud, or malice.
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`THIRD CAUSE OF ACTION
`ACCOUNTING
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`50.
`Plaintiffs incorporate the foregoing allegations as if fully set forth herein.
`51.
`Plaintiffs and the Class conferred a monetary benefit on Defendant in the form of
`monies paid for advertising.
`52.
`Defendant appreciated or had knowledge of the benefits conferred upon it by
`Plaintiffs and the Class.
`53.
`In November 2020, Defendant announced that it had not accurately captured or
`reported advertising metrics, or accurately charged for advertising, during at least a two-year period.
`While it made this announcement, it did not provide any detail to advertisers of the nature of the
`issue, what ads were impacted, or any other specifics of the harm.
`54.
`Because all advertising records, data, and other metrics, of Plaintiffs and the Class’s
`paid advertisements are exclusively within the control of Defendant, Plaintiffs and the Class have an
`inadequate legal remedy in that they cannot determine the precise amount of damage that they have
`suffered as a result of Defendant’s conduct.
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`CLASS ACTION COMPLAINT
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`55.
`As a result, Plaintiffs and the Class seek an order requiring Defendant to provide a
`full and complete accounting of all transactions or records relating to Plaintiffs’ and the Class’s
`advertising on the LinkedIn platform.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiffs Drew Krisco and Livly, Inc., individually and on behalf of the
`Class, prays for the following relief:
`(a)
`An order certifying the Class as defined above, appointing Plaintiffs as the
`representatives of the Class, and appointing their counsel as Class Counsel;
`(b)
`Awarding injunctive and other equitable relief as is necessary to protect the interests
`of the Class, including an order: (i) prohibiting LinkedIn from engaging in the wrongful acts
`described herein; (ii) requiring LinkedIn to engage third-party auditors to conduct audits and
`evaluations of LinkedIn’s advertising metrics on a periodic basis and ordering them to promptly
`correct any problems or issues detected by these auditors; and (iii) requiring LinkedIn to disclose
`any further inaccurate advertising metrics in a timely and accurate manner.
`(c)
`An award of all economic, monetary, actual, consequential, compensatory, and
`punitive damages available at law and caused by LinkedIn’s conduct;
`(d)
`An award of reasonable litigation expenses and attorneys’ fees;
`(e)
`An award of pre- and post-judgment interest, to the extent allowable;
`(f)
`Such other and further relief that the Court deems reasonable and just.
`JURY DEMAND
`Plaintiffs Drew Krisco and Livly, Inc. request a trial by jury of all claims that can be so
`
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`tried.
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`Date: November 20, 2020
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`CLASS ACTION COMPLAINT
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`Respectfully submitted,
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`DREW KRISCO and LIVLY, INC.,
`individually and on behalf of all other similarly
`situated individuals.
`
`By: /s/ Rafey S. Balabanian
` One of Plaintiffs’ Attorneys
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`Rafey Balabanian (SBN 315962)
`rbalabanian@edelson.com
`Todd Logan (SBN 305912)
`tlogan@edelson.com
`Brandt Silver-Korn (SBN 323530)
`bsilvercorn@edelson.com
`EDELSON PC
`123 Townsend Street, Suite 100
`San Francisco, California 94107
`Tel: 415.212.9300
`Fax: 415.373.9435
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`Antonio M. Romanucci (pro hac vice pending)
`aromanucci@rblaw.net
`Bryce T. Hensley (pro hac vice pending)
`bhensley@rblaw.net
`David A. Neiman (pro hac vice pending)
`dneiman@rblaw.net
`ROMANUCCI & BLANDIN, LLC
`321 North Clark Street, Suite 900
`Chicago, Illinois 60654
`Tel: 312.458.1000
`Fax: 312.458.1004
`
`Counsel for Plaintiffs and the Putative Class
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`CLASS ACTION COMPLAINT
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