3rd Circuit Remands Popa v. Harriet Carter Wiretap Case to PA State Court

Published
Score
8

Why it matters

The U.S. Court of Appeals for the Third Circuit has ruled that a plaintiff lacks federal standing to pursue wiretapping claims based solely on website tracking. In Popa v. Harriet Carter Gifts, Inc., the court found that Andreea Popa alleged no concrete injury from session-replay and web-tracking software beyond routine browsing activity—mouse movements and clicks. The court vacated the district court's summary judgment for defendants and remanded the case to Pennsylvania state court, where the Pennsylvania Wiretapping and Electronic Surveillance Control Act (WESCA) claims can proceed without federal standing requirements. Harriet Carter Gifts and its unnamed marketing-services provider had deployed the tracking tools at issue.

The decision extends the Third Circuit's 2025 Cook v. GameStop precedent, which established that ordinary website interactions do not constitute concrete harm for Article III standing absent capture of sensitive data. The district court had previously granted summary judgment to defendants on federal grounds. On remand, the state court will now review whether the tracking software "intercepts" communications under Pennsylvania law—a question governed by state, not federal, standing doctrine. This follows a 2022 Third Circuit ruling in an earlier phase of Popa that narrowed WESCA's direct-party exception, which had sparked dozens of session-replay lawsuits against website vendors across Pennsylvania.

Attorneys defending web analytics companies in the Third Circuit—Pennsylvania, New Jersey, Delaware, and the Virgin Islands—should note that federal jurisdiction now turns on alleging tangible harm such as captured personal data, not statutory violations alone. The ruling refocuses litigation strategy on state-court forums and raises the stakes for disclosure practices and user consent mechanisms. WESCA violations carry statutory damages of up to $1,000 per violation over a two-year period, creating significant class-action exposure for companies that fail to adequately disclose tracking practices or obtain proper consent.

mail

Get notified about new Privacy developments

Primary sources. No fluff. Straight to your inbox.

See more entries tagged Privacy.

Also on LawSnap