Gardner v. Me-TV National Limited Partnership

Federal 7th Circuit Court
Civil Court
Video Privacy Protection Act
Citation
Case Number: 
No. 24-1290
Decision Date: 
March 28, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Reversed and remanded.
Judge: 
EASTERBROOK

In a case involving the Video Privacy Protection Act, the Seventh Circuit considered what it means for a person to be a “subscriber,” a term that is not defined by the Act despite the Act’s prohibition against a video tape service provider releasing information without consumer consent. The term consumer is defined under the Act to include “subscribers.” The Seventh Circuit concluded that any type of purchase or subscription from a video tape service provider satisfies the definition of “consumer,” even if the thing purchased is not a video tape but rather some other item such as an item of clothing or if the subscription is not for a video but for some other item like a newsletter. (JACKSON-AKIWUMI and KOLAR, concurring)