Berman Tabacco is counsel for plaintiffs in this consumer class action against defendants Ladder Financial, Inc. and FullStory, Inc. As alleged in the complaint, Ladder offers consumers online quotes for insurance policies by filling out a form in which the consumers must enter private information about themselves, and FullStory is a marketing software-as-a-service company that sold to Ladder the software platform which records consumers’ keystrokes and other actions on Ladder’s website in realtime. Specifically, the complaint alleges that Ladder embedded FullStory’s JavaScript in the source code on Ladder’s website which allowed both companies to surreptitiously observe and record visitors’ keystrokes, mouse clicks, and other electronic communications, including their entry of their private Personally Identifiable Information (“PII”) and Protected Health Information (“PHI”). PII and PHI included such information as name, zip code, gender, age, height, weight, information regarding medical conditions, prescribed medications, use of tobacco products, marijuana or illegal drugs, criminal record history and current blood pressure and cholesterol levels. Plaintiffs bring this action on behalf of themselves and a class of all Californians whose electronic communications were intercepted by Defendants through Ladder’s use of FullStory’s software on its website.
