Doe v. YouTube, Inc.

Background

Jane Doe filed a proposed class action against YouTube LLC, incorrectly named in the lawsuit as YouTube Inc. YouTube moved to dismiss the complaint.

Claims and Analysis

The court stated that Doe did not oppose dismissal of her strict-liability claim.

For the negligence claims, the court found that Doe had not sufficiently explained what role, if any, her employer Collabera had in her work compared with YouTube. Without more allegations, the court could not determine whether the negligence claims were plausibly stated.

For the unfair-competition claims under California’s Unfair Competition Law, the court found that Doe had not alleged the relevant conduct in California needed to justify applying that law to conduct occurring outside California. The court also stated that, as a former content moderator, Doe lacked standing to seek an injunction requiring YouTube to implement safety guidelines. In addition, the court found that she had not sufficiently alleged that legal remedies, such as damages, were inadequate or incomplete.

Ruling

Judge Yvonne Gonzalez Rogers granted the motion to dismiss with leave to amend. The complaint was dismissed with leave to amend, and Doe was ordered to file an amended complaint no later than 30 days after the order. YouTube was required to respond 21 days after the amended complaint was filed. If YouTube filed another motion to dismiss, it could not raise new issues that could have been raised in the original motion. The order terminated Docket Number 16.