Lawsuits are rapidly multiplying against website operators over how user information is collected and shared. Plaintiffs are increasingly creative in asserting that website tracking tools, especially those tied to search bars, violate wiretap and related electronic communications laws. One emerging legal theory invokes “trap and trace” provisions, meant for surveillance devices, to challenge the capture

Beware of demand letters from plaintiffs’ attorneys for allegations of illegal use of pen registers, trap and trace pixels, and search bar pixels—why? This “trap and trace” litigation is a growing trend for plaintiffs’ attorneys because they can leverage existing wiretap laws (particularly in California under the California Invasion of Privacy Act (CIPA)) to argue