In 1988, Michigan enacted the Personal Privacy Protection Act (PPPA) to “preserve personal privacy with respect to the purchase, rental, or borrowing” of written materials, sound recordings, and video recordings. Enacted with the video rental industry in mind, the PPPA prohibits sellers of media from disclosing sale or rental “information . . . that indicates the identity of the customer.”
Gary Lin, a paid subscriber of a Crain magazine and a Virginia resident, filed a proposed class action against Crain Communications Inc. alleging that Crain sold “highly detailed customer lists” including sensitive information about its subscribers to data aggregators in violation of the PPPA. Crain moved to dismiss the complaint on the basis that the PPPA protects only Michigan residents and, therefore, Lin, as a Virginia resident, cannot seek relief under the PPPA.
The U.S. District Court for the Eastern District of Michigan denied Crain’s motion, holding that the PPPS does not impose a residency requirement for customers to have protections under the act.
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