a continuing effort to limit consumer's privacy violations, Malley filed a class action involving Hulu in 2012. A San Francisco federal trial court found the VPPA's subscriber protections apply to users with Hulu accounts. In 2015, the United States Court of Appeals for the Eleventh Circuit found that those protections do not reach the users of a free Android app, even when the app assigns each user a unique identification number and shares user behavior with a third-party data analytics company. References : Wrongful disclosure of video tape rental or sale records. 1988 in law United States federal privacy legislation Computer law