PACIFIC TRIAL ATTORNEYS

A NATIONAL LITIGATION FIRM

01/10/ 2025

VIA FEDERAL EXPRESS

To: XXXXX

Address: XXXXX

City: XXXXX State: XX

Zip Code: XXXXX

Attn: Legal Department

Re:      Lawsuit-Invasion of Privacy

Ladies and Gentlemen:

This law firm intends to bring suit against you for secretly deploying tracking software at www.XXXXX in violation of the California Invasion of Privacy Act.

Our client recently visited your website. Our expert has since preserved evidence confirming that your website secretly deploys a persistent "tracking script" to monitor visitors over multiple browsing sessions. We believe this constitutes installation of "pen register" and/or "trap and trace" software in violation of Section 638.51 of the California Invasion of Privacy Act. See Greenlry v. Kochava, Inc., 2023 WL 4833466, at *15-*16 (S.D. Cal. July 27, 2023).

This letter is written as a courtesy to advise you that we intend to file suit very soon; no further notice will be provided. If you believe we are mistaken or if you would like additional information, your counsel should immediately contact me.

Sincerely,

Scott Ferrell

Scott J. Ferrell