Patel v. Zillow, Inc.

Dist. Ct. did not err in dismissing for failure to state cause of action plaintiffs’ action alleging that defendant’s online estimates of real estate based on application of proprietary algorithm to public data violated Ill. Real Estate Appraiser Licensing Act, since said Act forbids appraisals of real estate without license. Said Act lacks private right of action to enforce appraisal licensing requirement. Also, plaintiffs could not state viable cause of action under Ill. Uniform Deceptive Trade Practices Act, even though plaintiffs asserted that defendant provided appraisals of their property that were unfair and inaccurate, and that defendant wrongfully refused their requests to either change said appraisals or remove their properties from its website. Instant appraisals are matters of opinion, which are outside contours of said Act, which only pertains to misleading statements of fact.