White v. PayPal Holdings Inc
- Pits
- 5:25-cv-04884
- U.S. District Court · Northern District of California
- 5
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
In White v. PayPal, Judge Pits granted Honey defendants’ motion to dismiss because four plaintiffs did not show personal injury, allowing amendment.
The ruling directly affected the claims of Antonio Minichiello, Annabelle Regan, Caleb Brackney, and Abigail Roskind. Their claims were dismissed under Rule 12(b)(1), but they were allowed to amend within 35 days; without an amended complaint, their claims would be dismissed without further leave to amend.
What happened
Leah White and other plaintiffs sued PayPal Holdings Inc. and Honey, alleging Honey promoted the best coupons but sometimes favored partner merchants’ coupons instead. They brought claims for a nationwide group of Honey users and eleven state or District of Columbia groups.
The defendants asked the court to dismiss four plaintiffs’ claims—Antonio Minichiello, Annabelle Regan, Caleb Brackney, and Abigail Roskind—because they had not shown that they personally suffered an injury. The court said the complaint’s example showed only that a better coupon might have been available, not that these plaintiffs personally paid more than they otherwise would have.
Judge Pits granted the defendants’ motion to dismiss under the federal rule governing subject-matter jurisdiction. The dismissal was with leave to amend, and an amended complaint had to be filed within 35 days; otherwise, the four plaintiffs’ claims would be dismissed without further leave to amend.
The detailed version
- White v. PayPal Holdings Inc · No. 5:25-cv-04884
- Pits
- Aug. 31, 2026
Background
Honey is a browser extension owned by PayPal that searches for and applies coupon or discount codes during online purchases. Plaintiffs alleged that Honey did not always apply the best available coupons and instead prioritized coupons from Honey’s partner merchants, sometimes excluding coupons from non-partners.
The plaintiffs brought the case for people in the United States who used Honey during an online purchase, along with eleven subclasses covering users in specified states and the District of Columbia. The defendants moved under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when the court lacks subject-matter jurisdiction, and Rule 12(b)(6), which addresses legally insufficient claims. The motion targeted the claims of Antonio Minichiello, Annabelle Regan, Caleb Brackney, and Abigail Roskind.
Standing Analysis
The court focused on Article III standing, which requires a plaintiff to show a concrete and personal injury, a connection between that injury and the defendant’s conduct, and a likelihood that a court ruling would remedy the injury.
The complaint relied on a test search at Princess Polly. Honey applied code HONEY66151, which gave a $10 discount on a $100 purchase. A Google search then revealed code JULIA20, which gave a $20 discount on the same purchase. The court held that this example did not show that any of the four named plaintiffs personally bought a product at a higher price than they would have paid using the best available code at the time of their own purchases.
Because Honey is free, the court said the plaintiffs needed to allege that defendants’ alleged misrepresentations caused them to pay more for products than they otherwise would have paid. Their allegations showed only that they might have been harmed, which was not enough to establish a concrete injury or standing.
Disposition
The court granted the defendants’ motion to dismiss under Rule 12(b)(1). The dismissal was with leave to amend. Any amended complaint had to be filed within 35 days of the order. If no amended complaint was filed, the claims of Minichiello, Regan, Brackney, and Roskind against the defendants would be dismissed without further leave to amend.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.