Ninth Circuit Applies a Narrow Reading of What Constitutes PII Under the VPPA in ESPN Case

By Gretchen A. Ramos, of Squire Patton Boggs   In Eichenberger-v.-ESPN., Case No. 15-35499 (Nov. 29, 2017), the United States Court of Appeals for the Ninth Circuit affirmed the district court judgment holding that the serial numbers on a consumer’s video streaming device and the titles of the videos an individual watches do not constitute personally identifiable information (PII) under the Video Privacy Protection Act of 1988 (VPPA)—even if a third party has additional information that