Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 1 of 11
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`In The United States District Court
`For The Western District Of Washington
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`Darlin Gray, individually and on behalf of
`all others similarly situated,
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`Plaintiff,
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`v.
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`Twitter, Inc.,
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`Defendant.
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`No. 2:20-cv-1389
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`Class Action Complaint
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`Jury Demand
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`Plaintiff, individually and on behalf of all others similarly situated, alleges the following
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`based upon personal knowledge as to Plaintiff and Plaintiff’s own acts, and upon information and
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`belief as to all other allegations, based on investigation of counsel. This investigation included, inter
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`alia, a review of public statements and disclosure materials prepared by Defendant; review of
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`Federal Trade Commission filings; FOIA requests to FTC; media reports; interviews; social
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`media; and other information concerning Defendant. The investigation of the facts pertaining to
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`this case is continuing. Plaintiff believes that substantial evidentiary support will exist for the
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`allegations set forth herein after a reasonable opportunity for discovery.
`I. Introduction
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`1.
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`Privacy is a 21st century civil rights issue that affects everyone who interacts on
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`digital platforms.
`2.
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`Behemoth providers of ubiquitous digital platforms make promises of privacy when
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`they solicit users. Too often, those promises are not kept.
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`Class Action Complaint and Jury Demand - 1
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 2 of 11
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`3.
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`Many powerful actors who violate individuals’ civil rights, including privacy rights,
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`thereafter contest whether any damages resulted from their wrongful conduct.
`4.
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`Those powerful companies disregard their promises to users about privacy because
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`of strong financial incentives. Using and trading in private user data can be extraordinarily lucrative
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`for those companies which do so.
`5.
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`Yet those same companies routinely contend that, despite the degree to which they
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`profit from refusing to honor the privacy choices exercised by users, there is no comparable,
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`measurable financial harm to those whose rights they violate.
`6.
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`Privacy violators also often contend that the harm to an individual is de minimus,
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`thereby making it prohibitively expensive for an individual to protect her privacy rights.
`7.
`8.
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`As with other civil rights violations, legislation has begun to address this issue.
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`As with other civil rights violations, legislatures have established statutory
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`violations, and set a specific amount of statutory damages, together with an award of attorneys’
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`fees and the costs of suit.
`9.
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`Washington state has done exactly this, in order to ensure judicial recourse to
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`protect the civil right in privacy of users’ phone numbers and other records against improper
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`procurement and use.
`10.
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`This suit seeks statutory damages together with attorneys’ fees, other costs of
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`litigation, and prejudgment interest, resulting from the acts of Defendant Twitter, Inc.
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`(“Twitter”) which engaged in the unauthorized procurement of telephone records of Plaintiff and
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`the Class in violation of RCW 9.26A.140.
`11.
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`Plaintiff is entitled to bring this private action to enforce RCW 9.26A.140 by virtue
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`of that statute and by virtue of RCW 9A.82.010 and 9A.82.100.
`II. Jurisdiction And Venue
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`12.
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`This Court has subject matter jurisdiction over the claims pursuant to 28 U.S.C.
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`§ 1332(d)(2) because the amount in controversy exceeds $5,000,000 exclusive of interest and costs
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`Class Action Complaint and Jury Demand - 2
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 3 of 11
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`and all members of the putative class of plaintiffs are citizens of a State different from Defendant
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`Twitter, Inc. (“Twitter”).
`13.
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`This Court has personal jurisdiction over Twitter because it has purposefully
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`directed its activities at this State and this judicial district, including by opening and maintaining
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`and office and employees in this State and judicial district.
`14.
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`Twitter has also consummated a transaction with at least one resident of the State
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`and judicial district, including Plaintiff.
`15.
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`This Court has personal jurisdiction over Twitter because it has performed acts by
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`which it purposefully avails itself of the privilege of conducting activities in this State and judicial
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`district, thereby invoking the benefits and protections of the laws of this State.
`16.
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`This Court has personal jurisdiction over Twitter because the claim arises out of or
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`relates to Twitter’s forum-related activities.
`17.
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`This Court has personal jurisdiction over Twitter because the exercise of
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`jurisdiction over Twitter as to the allegations of this Complaint comport with fair play and
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`substantial justice.
`18.
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`Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) and (3) because a
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`substantial part of the events or omissions giving rise to the claim occurred in this State and judicial
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`district and because Twitter is subject to personal jurisdiction in this State and judicial district.
`III. Parties
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`19.
`20.
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`Plaintiff Darlin Gray (“Gray”) is a Twitter user with the username @darlingray.
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`Plaintiff Gray is now, and at all times relevant to this Complaint has been, a
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`Washington resident.
`21.
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`Twitter is a Delaware Corporation with a principal place of business in San
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`Francisco, California.
`22.
`23.
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`Twitter is a for-profit company.
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`Twitter acts at all times for financial gain.
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`Class Action Complaint and Jury Demand - 3
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`A.
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 4 of 11
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`IV. Facts
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`Twitter Is A Telecommunications Company.
`24. Under Washington
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`law, “‘[t]elecommunications’
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`is the transmission of
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`information by wire, radio, optical cable, electromagnetic, or other similar means. As used in this
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`definition, ‘information’ means knowledge or intelligence represented by any form of writing,
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`signs, signals, pictures, sounds, or any other symbols.” RCW 80.04.010(27); see also RCW
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`9.26A.100 (“‘Telecommunications” shall have the same meaning as that contained in RCW
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`80.04.010 and includes telecommunications service that originates, terminates, or both originates
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`and terminates in this state”).
`25.
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` Under Washington law, “‘[t]elecommunications company’ includes every
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`corporation, company, association, joint stock association, partnership and person, their lessees,
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`trustees or receivers appointed by any court whatsoever, and every city or town owning, operating
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`or managing any facilities used to provide telecommunications for hire, sale, or resale to the general
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`public within this state.” RCW 80.04.010(28); see also (“‘Telecommunications company’ shall
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`have the same meaning as that contained in RCW 80.04.010”).
`26.
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`Twitter transmits knowledge or intelligence represented by any form of writing,
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`signs, signals, pictures, sounds, or any other symbols by wire, radio, optical cable, electromagnetic,
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`or other similar means.
`27.
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`Twitter provide telecommunications for hire, sale, or resale to the general public
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`within this state, at least by virtue of its provision, for money, of advertising to Twitter users.1
`28.
`29.
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`Twitter provides telecommunications service that either originates, or terminates,
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`Twitter is a telecommunications company.
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`or both originates and terminates in the state of Washington.
`30.
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`Telephone numbers are “telephone records” as defined in RCW 9.26A.140,
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`inasmuch as they comprise “information retained by a telecommunications company that relates
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`1 See https://business.twitter.com/en/help/ads-policies/campaign-
`considerations/about-eligibility-for-twitter-ads.html (last accessed September 20, 2020).
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`Class Action Complaint and Jury Demand - 4
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`No. 2:20-cv-1389
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Ard Law Group PLLC
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 5 of 11
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`to the telephone number dialed by the customer or the incoming number or call directed to a
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`customer, or other data related to such calls typically contained on a customer telephone bill such
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`as the time the call started and ended, the duration of the call, the time of day the call was made,
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`and any charges applied.” RCW 9.26A.140.
`31.
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`Telephone numbers are telephone records which pertain to the person whose
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`telephone number it is.
`32.
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`Each telephone number is a telephone record which pertains to at least the user
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`associated with that telephone number.
`33.
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`A telephone record may pertain to a person other than the person who pays for the
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`telephone service associated with that number.
`34.
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`For example, in so-called “friends and family” type plans, one person might be
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`contractually responsible for paying the invoicing for multiple telephone numbers, where all but
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`one of the telephone numbers pertains to other persons.
`35.
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`In that type of arrangement, a telephone number constitutes a record that pertains
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`to a user who is not the financially responsible subscriber.
`B.
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`Twitter’s Unlawful Procurement Of Telephone Records.
`36.
`37.
`38.
`39.
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`Twitter procured a telephone record which pertains to Gray.
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`Specifically, Twitter procured Gray’s telephone number from Gray.
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`Twitter did so with fraudulent, deceptive, or false means.
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`Those means included assurances to Gray that Gray could designate the uses to
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`which the telephone number was put, thereby maintaining control over the use of the telephone
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`number by Twitter, through functions made available on Twitter’s user-facing systems.
`40.
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`In making these representations, Twitter falsely assured Gray that it would honor
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`the privacy choices exercised by her, a user.
`41.
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`Gray provided her telephone number, a telephone record which pertains to her, to
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`Twitter.
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`Class Action Complaint and Jury Demand - 5
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 6 of 11
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`42.
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`She did so in reliance on Twitter’s fraudulent, deceptive, or false means, namely,
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`assurances that she could designate the uses to which the telephone number was put and thereby
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`maintain control over the use of the telephone number by Twitter, through functions made
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`available on Twitter’s user-facing systems.
`43.
`44.
`45.
`46.
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`Twitter procured telephone records which pertain to other Washington persons.
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`Specifically, Twitter procured telephone numbers from other Washington persons.
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`Twitter did so with fraudulent, deceptive, or false means.
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`Those means included assurances to other Washington persons that they could
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`designate the uses to which the telephone number was put, thereby maintaining control over the
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`use of the telephone number by Twitter, through functions made available on Twitter’s user-facing
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`systems.
`47.
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`In making these representations, Twitter falsely assured Washington users that it
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`would honor the privacy choices exercised by users.
`48. Other Washington persons provided telephone numbers, telephone records which
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`pertains to each of them, to Twitter.
`49.
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`They did so in reliance on Twitter’s fraudulent, deceptive, or false means, namely,
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`assurances that each person could designate the uses to which the telephone number was put and
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`thereby maintain control over the use of the telephone number by Twitter, through functions made
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`available on Twitter’s user-facing systems.
`50.
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`Twitter did not honor the privacy choices exercised by Gray or other Washington
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`51.
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`Twitter provided to Gray and each Washington user various screens purportedly
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`for account management that purported to give Gray and other Washington users the ability to
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`control the use to which Twitter put phone numbers it had procured.
`52. Unbeknownst to Gray or any Washington user, Twitter did not honor the privacy
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`choices exercised by users, as evidenced to Twitter through the account settings selections made
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`on those screens.
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`Class Action Complaint and Jury Demand - 6
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 7 of 11
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`53. No user knew or could have known of Twitter’s fraudulent, deceptive, and false
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`representations regarding its false assurances that it honored the privacy choices exercised by users
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`prior to October 8, 2019.
`54.
`55.
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`Twitter concealed its wrongdoing until October 8, 2019.
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`On October 8, 2019 Twitter publicly acknowledged that “when [users] provided an
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`email address or phone number for safety or security purposes (for example, two-factor
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`authentication) this data may have inadvertently been used for advertising purposes, specifically
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`in our Tailored Audiences and Partner Audiences advertising system.”2
`56. Whatever Twitter means by “inadvertent,” it used fraudulent, deceptive, or false
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`means to obtain the telephone record of Gray.
`57. Whatever Twitter means by “inadvertent,” it used fraudulent, deceptive, or false
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`means to obtain the telephone records of other Washington users.
`58.
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`Twitter used fraudulent, deceptive, or false means to obtain telephone records,
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`namely telephone numbers, from Gray and countless other Washington users.
`59.
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`Those means included promising users that Twitter would honor the privacy
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`choices exercised by users regarding the use of telephone numbers through user-facing Twitter
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`systems.
`60. However, despite its false promises, Twitter did not create, implement, or execute
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`systems that honored users’ designations as to use of those numbers.
`61.
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`In doing so, Twitter’s fraudulent, deceptive, or false means in obtaining the
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`telephone numbers increased its revenue, by increasing the amount advertisers paid it for ads.
`62.
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`Twitter committed its acts of fraudulent, deceptive, or false means of obtaining
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`telephone records for financial gain.
`63.
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`A reasonable opportunity for discovery will also reveal whether Twitter disclosed
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`telephone numbers to advertisers, despite its recent assurances to the contrary.
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` See https://help.twitter.com/en/information-and-ads#10-08-2019
`September 20, 2020).
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`Class Action Complaint and Jury Demand - 7
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`(last
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`accessed
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`Ard Law Group PLLC
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`No. 2:20-cv-1389
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 8 of 11
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`64.
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`If so, it also “[i]ntentionally [sold] the telephone record of any resident of this state
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`without the authorization of the customer to whom the record pertains.” RCW 9A.26.140.
`65.
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`If so, it committed that act of sale for financial gain.
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`C.
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`Civil Remedy.
`66. Due to the foregoing conduct, Twitter is “subject to legal action for injunctive relief
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`and either actual damages, including mental pain and suffering, or liquidated damages of five
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`thousand dollars per violation, whichever is greater.” RCW 9A.26.140.
`67.
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`Each telephone number Twitter obtained from a Washington person constitutes a
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`separate violation of RCW 9A.261.40, subject to $5,000 liquidated damages.
`68.
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` Each separate occasion on which Twitter disclosed the telephone number of a
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`Washington person to advertisers, thereby increasing the fees paid by those advertisers, constitutes
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`a separate violation subject to $5,000 liquidated damages.
`69.
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`Gray has sustained injury to her person, business, or property by Twitter’s acts that
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`are part of a pattern of acts included in RCW 9A.82.010(4)(nn).
`70.
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`Gray may therefore file an action for the recovery of damages and the costs of the
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`suit, including reasonable investigative and attorney’s fees.
`V. Class Allegations
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`71.
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`Gray brings this action as a class action pursuant to Rules 23(a) and 23(b)(2) and or
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`(b)(3) of the Federal Rules of Civil Procedure on behalf of the following Class of persons:
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`All Washington persons who provided a telephone number to Twitter prior to October 8, 2019.
`72.
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`Excluded from the Class is any person, firm, trust, corporation, or other entity
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`related to or affiliated with Defendant.
`73.
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`Gray reserves the right to amend the Class definition if further investigation and/or
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`discovery indicate that the Class definition should be narrowed, expanded, or otherwise modified.
`74. Upon information and belief, numerous Washington persons provided telephone
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`numbers to Twitter.
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`Class Action Complaint and Jury Demand - 8
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`

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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 9 of 11
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`75.
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`Upon information and belief, the number of individuals and entities who comprise
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`the Class are so numerous that joinder of all such persons is impracticable and the disposition of
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`their claims in a class action, rather than in individual actions, will benefit both the parties and the
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`courts.
`76. Upon information and belief, class members may be identified from records
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`maintained by Defendants, and may be notified of the pendency of this action by mail or electronic
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`mail using the form of notice similar to that customarily used in class actions, including by using
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`Twitter’s telecommunications service.
`77.
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`Gray’s claims are typical of the claims of the other members of the Class. All
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`members of the Class have been and/or continue to be similarly affected by Defendant’s wrongful
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`conduct as complained of herein. Gray is unaware of any interests that conflict with or are
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`antagonistic to the interests of the Class.
`78.
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`Gray will fairly and adequately protect the Class members’ interests and has
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`retained counsel competent and experienced in class actions and complex litigation. Gray and
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`Gray’s counsel will adequately and vigorously litigate this class action, and Gray is aware of her
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`duties and responsibilities to the Class.
`79.
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`Defendant has acted with respect to the Class in a manner generally applicable to
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`each Class member. Common questions of law and fact exist as to all Class members and
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`predominate over any questions affecting individual Class members. The questions of law and fact
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`common to the Class include, inter alia:
`a. Whether Defendant obtained telephone records which pertain to residents of
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`this state through fraudulent, deceptive, or false means;
`b. Whether Defendant intentionally sold the telephone records of residents of this
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`state; and
`c. The remedies available to Gray and the Class.
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`80.
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`A class action is superior to all other available methods for the fair and efficient
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`adjudication of this controversy since joinder of all Class members is impracticable. Furthermore,
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`Class Action Complaint and Jury Demand - 9
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 10 of 11
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`as the injury and/or damages suffered by individual Class members may be relatively small, the
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`expense and burden of individual litigation makes it impossible as a practical matter for Class
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`members to individually redress the wrongs done to them. There will be no difficulty in managing
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`this action as a class action.
`81.
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`Defendant has acted on grounds generally applicable to the entire Class with
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`respect to the matters complained of herein, thereby making appropriate the relief sought herein
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`with respect to the Class as a whole.
`VI. Cause Of Action
`82. Gray hereby incorporates by reference the allegations contained in the preceding
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`paragraphs of this Complaint.
`83.
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`This sole Count is brought pursuant to RCW 9.26A.140 and RCW 9A.82.100, on
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`behalf of the Class, against Defendant.
`84. Defendant obtained telephone records of residents of this state through fraudulent,
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`deceptive, or false means and/ or intentionally sold the telephone records of residents of this state
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`without the authorization of the customer to whom the record pertains.
`85.
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`Pursuant to RCW 9.26A.140, Gray and each member of the Class is entitled to
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`$5,000 in liquidated damages for each such violation.
`VII. Prayer For Relief
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`WHEREFORE, Gray and the Class pray for relief and judgment as follows:
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`A.
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`Declaring that this action is properly maintainable as a class action under Civil Rule
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`23, and certifying Gray as the Class representative and Gray’s counsel as Counsel for the Class;
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`B.
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`Declaring that Defendant engaged in the unauthorized procurement and sale of
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`telephone records under RCW 9.26A.140;
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`C.
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`Awarding Gray and the members of the Class the remedy of statutory damages of
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`$5,000 for each violation, together with pre- and post-judgment interest;
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`D.
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`Awarding costs of investigation and litigation, including expert witness costs, and
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`reasonable attorneys’ fees, against Defendant;
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`Class Action Complaint and Jury Demand - 10
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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`

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`Case 2:20-cv-01389 Document 1 Filed 09/21/20 Page 11 of 11
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`E.
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`F.
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`Enjoining Defendant from further violations of RCW 9.26A.140; and
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`Such other and further relief as this Court may deem just and proper.
`VIII. Jury Demand
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`Gray and the Class hereby demand a trial by jury.
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`///
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`///
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`///
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`September 21, 2020.
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`Ard Law Group pllc
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`By:_____________________
`Joel B. Ard, WSBA # 40104
`Ard Law Group pllc
`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
`Attorneys For Plaintiff And The
`Putative Class
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`Class Action Complaint and Jury Demand - 11
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`No. 2:20-cv-1389
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`Ard Law Group PLLC
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`P.O. Box 11633
`Bainbridge Island, WA 98110
`Phone: (206) 701-9243
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