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

A nationwide call recording and analytics service, uniformly deployed nationwide, that merely operates in California is not sufficient, standing alone, to establish specific personal jurisdiction under the California Invasion of Privacy Act (CIPA), according to a recent decision from the Central District of California. At issue was a wiretapping allegation arising out of call tracking and analytics technology used across a car dealership network. The plaintiff alleged that the deployment of call recording and analytics constituted unlawful interception of communications.