CIPA Personal Jurisdiction: Nationwide Call Recording and Analytics Deployment Fails "Express Aiming" Test in Central District of California

A Central District of California ruling determined that uniform nationwide deployment of call recording and analytics technology does not establish personal jurisdiction under the California Invasion of Privacy Act (CIPA) without evidence of state-specific targeting. Applying the Calder effects test, the court held that the defendant’s nationwide implementation strategy, rather than California-directed conduct, failed the express aiming requirement, meaning companies operating through subsidiaries with uniform policies across jurisdictions may avoid CIPA-based claims at jurisdictional thresholds.