Detrina Solomon v. Flipps Media, Inc.

Brooklyn, New York civil rights lawyers represented the Plaintiff on a Video Privacy

Protection Act violation theory.



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In 1987, a newspaper published an article that identified 146 films

that a Supreme Court nominee and his family had rented from a local video

store. Although the rental information disclosed in the article was ʺnot at all

salacious,ʺ1 the invasion of privacy prompted Congress to enact the Video

Privacy Protection Act of 1988, 18 U.S.C. § 2710 (the ʺVPPAʺ), to protect the

privacy of consumers who rented or purchased ʺvideo cassette tapesʺ and

ʺsimilar audio visual materials.ʺ 18 U.S.C. § 2710(a)(4).



In this case, plaintiff‐appellant Detrina Solomon, a subscriber to a

digital video streaming service, contends that her rights under the VPPA were

violated when the service, operated by defendant‐appellee Flipps Media, Inc.,

dba FITE, dba FITE TV (ʺFITEʺ),2 sent certain information to Facebook, Inc.

(ʺFacebookʺ)3 each time she streamed a video. The information consisted of (1) a

sequence of characters, letters, and numbers that, if correctly interpreted, would

identify the title and URL (uniform resource locator, or web address) of the

video, and (2) her ʺFacebook IDʺ (ʺFIDʺ), a unique sequence of numbers linked to

her Facebook profile.



The Defendant filed a motion to dismiss.

Granted.



Affirmed on appeal.