Bride v. Snap Inc.

Background

The Estate of Carson Bride, Kristin Bride, and the Tyler Clementi Foundation brought this consumer class action against Snap, Inc., YOLO Technologies, Inc., and LightSpace, Inc. Snap owns Snapchat; YOLO owns an in-app Snapchat extension; and LightSpace owns another Snapchat extension. The plaintiffs assert claims under Oregon, New York, and California law arising from alleged harassment and cyberbullying of Carson Bride and Tyler Clementi. They contend that the companies failed to carry out promised anti-bullying and harassment policies and failed to safeguard teenagers.

The defendants moved under 28 U.S.C. § 1404(a) to transfer the case from the Northern District of California to the Central District of California. That statute allows a federal court to transfer a civil case to another district where it could originally have been filed when convenience and the interests of justice favor the transfer. The motion was decided without oral argument.

Court’s analysis

The court first determined that the case could have been brought in the Central District. The plaintiffs did not dispute that point. The court explained that Snap and YOLO were headquartered in Santa Monica and Los Angeles, respectively, and therefore resided in the Central District for venue purposes. LightSpace was incorporated in the Cayman Islands. The court said it did not need to resolve whether LightSpace maintained an office in Palo Alto or in China because venue was proper in the Central District either way.

The court then applied the factors used to decide whether transfer would be more convenient and would promote justice. The plaintiffs lived in Oregon and New York and sought certification of a nationwide class, along with Oregon and New York subclasses. Because this was a class action and the plaintiffs did not live in the Northern District, the court gave their choice of forum less weight. The court also noted that none of the alleged events occurred in the Northern District and that the plaintiffs said they filed there because the defendants generally did business there.

The court found that the Central District would be more convenient for the parties and witnesses. Snap and YOLO were headquartered there, and declarations showed that most employees with relevant knowledge who might testify were located there. The plaintiffs did not identify nonparty witnesses whose convenience favored the Northern District. The court also found no other sufficient reason not to transfer the case.

Disposition

The court granted the transfer to the Central District of California. Judge James Donato entered the order on August 9, 2021.