Farrell v. LinkedIn Corporation
- Vince Chhabria
- 3:26-cv-02953
- U.S. District Court · Northern District of California
- 3
Counsel of record per CourtListener. Firm names are approximate.
In Farrell and Ganan v. LinkedIn, Judge Chhabria granted LinkedIn’s dismissal motions for lack of standing, allowed amendment, and denied consolidation as moot.
Nicholas Farrell and Jeff Ganan may amend their complaints within 14 days; otherwise, the court stated that dismissal will be with prejudice. LinkedIn’s dismissal motions were granted, and Farrell’s motion to consolidate was denied as moot.
What happened
In Nicholas Farrell v. LinkedIn Corporation and Jeff Ganan v. LinkedIn Corporation, the plaintiffs alleged that LinkedIn obtained private information through browser extensions. Ganan did not allege that he had any browser extensions installed. Farrell alleged that he had several extensions but did not allege that any of his extensions revealed private information.
The court ruled that these allegations did not show a concrete, personal injury required to bring the claims in federal court. It also rejected Ganan’s argument that the unauthorized examination itself was enough, explaining that a plaintiff must identify private information that the defendant actually collected. The court did not decide whether LinkedIn ultimately violated the law.
Judge Vince Chhabria granted LinkedIn’s motions to dismiss, giving both plaintiffs 14 days to amend. If neither files an amended complaint by then, the dismissal will be with prejudice. The court denied Farrell’s motion to consolidate as moot, while stating that successful amended claims could lead to consolidation later.
The detailed version
- Farrell v. LinkedIn Corporation · No. 3:26-cv-02953
- Vince Chhabria
- Sept. 8, 2026
Background
Nicholas Farrell and Jeff Ganan brought separate cases against LinkedIn Corporation involving browser extensions and private information. The opinion does not identify the specific statutory claims in the complaints. Farrell alleged that he had long used several browser extensions and that browser extensions can reveal sensitive private information generally. He did not allege that one of his own extensions revealed such information. Ganan did not allege that he had any browser extensions installed.
Farrell also moved to consolidate the two cases. LinkedIn moved to dismiss both complaints for lack of standing, meaning the plaintiffs had not adequately alleged the personal injury required to sue in federal court.
Court’s Analysis
The court held that neither plaintiff adequately alleged an injury in fact. The court explained that a plaintiff must allege a concrete and particularized harm connected to the defendant’s conduct. General descriptions of the kinds of private information that browser-extension surveillance might reveal were insufficient. The complaints did not plausibly connect that potential harm to information actually revealed or collected from either plaintiff.
The court also rejected Ganan’s argument that the injury was the unauthorized examination itself, rather than the information obtained from it. Relying on Ninth Circuit authority, the court stated that both the nature of the collection and the sensitivity of the information collected matter in an internet-privacy case. A plaintiff must identify embarrassing, invasive, or otherwise private information that the defendant collected.
The court noted LinkedIn’s additional argument that users voluntarily download browser extensions that intentionally expose data to websites. The court stated that it seemed unlikely the plaintiffs would ultimately be able to allege a privacy violation or prevail, but it did not decide those issues because the immediate ruling concerned standing.
Disposition
The court granted LinkedIn’s motion to dismiss in the Farrell case and its motion to dismiss in the Ganan case. The dismissals were entered with leave to amend, and any amended complaint had to be filed within 14 days of the order. The court stated that if no amended complaint was filed by that deadline, dismissal would be with prejudice.
The court denied Farrell’s motion to consolidate as moot. It further stated that if both plaintiffs amended their complaints and both successfully stated a claim, the cases would be consolidated, Farrell would be the lead plaintiff, and Farrell’s counsel would serve as interim class counsel.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.