Lane v. Facebook, Inc. class action lawsuit. Based on this act, it is generalized to other forms of rental records such as DVDs, video games, and more. This was the FIRST time VPPA had been used in litigation for such purposes, and would forever change Federal Data Privacy litigation. Malley had previously litigated in the early 2000s using another federal privacy law, the Driver's Privacy Protection Act ("DPPA"), which provided statutory damages for to the unauthorized access of DMV records. This law allowed Malley to successfully file numerous federal class actions against hundreds of companies, but a new theory of liability was needed for added assurance to survive a motion to dismiss. The problem, no case law involving this new-age type of technology. Substantial research was thus required, eventually revealing an "archaic" statute created in 1988: Video Privacy Protection Act ("VPPA"). Arguably unrelated to present technology, VPPA concerned about obtaining information from a physical location and involved VHS and Betamax recordings. As such, lawsuits involving online entities that used audio-video would need to plead comparisons between the "old-new" technologies for advertising. The online advertising industry, in association with analytic companies, had begun using video ads to conduct its ubiquitous tracking, consumer's attention shown to be drawn to such as opposed to written content, In later years, these tracking methods would expand to photos and audio, IE., In 2008, cell phones were re-designed to include a new method of tracking, the use of social apps to collect photos, a process which now permitted a one-step "click" process to uploading a photo as opposed to the previous six steps. This allowed content to be provided for free and which formed the basis for the tracking, IE., Exif data. Such acts were captured when Malley used software applications to log HTTP/HTTPS traffic between a computer's web browser and the Internet, analytic tests using two computers interfaced, producing indisputable evidence of such activities: moreover, detailed reports of any and all parties involved in such nefarious activities, IE., "tracking the trackers". In the continuing research of the Industry's business practices to determine its monetization interests, such revealed the incorporation of complex graphics within online ads, and the exchange of data derived from video ads not confined to an internal network, used via a TCP/IP protocol. This unauthorized activity would become the core allegation. Extensive research and case analysis of Federal and State laws, regulations, and