{"page":"/blog/pixel-problem-healthcare-marketing","modified":"2026-10-18","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Date","Actor","Target","What was alleged","Amount or outcome","Source"],"rows":[["16 Jun 2022","The Markup (investigation)","33 of top 100 hospitals; 7 portals","Meta Pixel sending appointment, condition and portal data","Triggered the litigation wave","The Markup, 16 Jun 2022"],["1 Dec 2022","HHS OCR","Covered entities and business associates","Bulletin: tracking tech on authenticated and many unauthenticated pages discloses PHI","Guidance; revised 18 Mar 2024","Shook Hardy & Bacon, 22 Mar 2024"],["1 Feb 2023","FTC","GoodRx","Health data to Facebook, Google, Criteo, Branch, Twilio for ads; first HBNR action","$1.5M civil penalty; ad-sharing ban","FTC, 1 Feb 2023"],["2 Mar 2023","FTC","BetterHelp","Emails, questionnaire answers, IPs to Facebook, Snapchat, Criteo, Pinterest","$7.8M consumer refunds; ad-sharing ban","FTC, 2 Mar 2023"],["17 May 2023","FTC with CT, DC, OR","Easy Healthcare (Premom)","Fertility data to AppsFlyer and Google SDKs","$100,000 to FTC plus $100,000 to three states","FTC, 17 May 2023"],["27 Dec 2023","New York AG","NewYork-Presbyterian Hospital","Tools from Meta, Google, Microsoft, TikTok, The Trade Desk, X, iHeartMedia on doctor-search and booking pages (June 2016 to June 2022)","$300,000; delete data; third-party deletion","NY AG, 27 Dec 2023"],["11 Apr 2024","FTC","Monument (alcohol treatment)","Data on up to 84,000 users to ad platforms, 2020 to 2022","$2.5M penalty, suspended for inability to pay","Choate, 16 Apr 2024"],["12 Apr 2024","FTC","Cerebral (telehealth)","Data on more than 3 million people to ad platforms, Oct 2019 to Mar 2023","More than $7M; further $8M suspended","Choate, 16 Apr 2024"],["20 Jun 2024","N.D. Tex. (AHA v. Becerra)","HHS","IP address plus unauthenticated page is not PHI","Bulletin vacated in part; appeal dropped 29 Aug 2024","AHA, 20 Jun 2024; The Record, 30 Aug 2024"],["10 Jul 2024","E.D. Wis. (class action)","Advocate Aurora Health","Pixels on website and portal to Meta and Google; 2.5M people","$12.225M, final approval","Robinson+Cole, 25 Jul 2024"],["29 Jul 2024","FTC (rule)","Non-HIPAA health apps and services","HBNR amendments: unauthorised disclosure is a breach; 60-day FTC notice for 500+ people","Rule effective","MoFo, 14 May 2024"],["14 Jan 2025","FTC","Gravy Analytics/Venntel; Mobilewalla","Sale of sensitive location data incl. medical facilities","Orders finalized; sale bans; sensitive-location programs","Hunton, 4 Feb 2025"],["10 Feb 2025","W.D. Wash. (class action)","Amazon (ads SDK)","First MHMDA case; location and biometric data via SDK","Pending","Paul Hastings, Feb 2025"],["1 Jul 2025","California AG","Healthline Media","Article titles revealing a diagnosis shared with third parties; opt-out failures","$1.55M; ban on sharing such titles","California AG"],["10 Jul 2025","Marin County Superior Court (class action)","MarinHealth Medical Center","Meta Pixel","$3M","HIPAA Journal, 10 Jul 2025"],["22 Sep 2025","S.D. Tex. (Sweat v. Houston Methodist)","Houston Methodist Hospital","Meta Pixel; Wiretap Act crime-tort exception","Summary judgment for the hospital: no purpose to violate HIPAA","Opinion, 22 Sep 2025"],["Dec 2025 (secondary)","Class action","Kaiser Permanente","Tracking technologies","$46M base, preliminary approval","Curve Compliance, reviewed 25 Aug 2026"],["17 Dec 2025 (secondary)","Class action","Inova Health Care Services","Pixels on public-facing sites","$3,147,390, preliminary approval","Curve Compliance, reviewed 25 Aug 2026"],["Early 2026 (secondary)","Class action","Sutter Health","Google Analytics, Meta Pixel, other tools","$21.5M","Curve Compliance, reviewed 25 Aug 2026"],["11 May 2026","D. Minn. (class action)","Allina Health System","Pixel tracking; class 16 Sep 2018 to 11 May 2026","$12.5M; final hearing 24 Sep 2026","Top Class Actions, 2026"],["22 May 2026","N.C. court (class action)","Atrium Health","Pixels incl. portal; Meta","$1.8M, preliminary approval; final hearing 30 Sep 2026","ClassAction.org, 2 Jul 2026"],["29 Jul 2026","FTC, Utah DCP, Los Angeles County (for California)","Hims & Hers Health","Pixels, Conversions API, customer-list uploads to Meta, Snap and others; \"private\" marketing claims; ROSCA","Complaint, N.D. Cal.; $60M accrual as of 30 Jun 2026; follow-on Doe class action","Hims & Hers 10-Q, Q2 2026; Healthcare Dive, 30 Jul 2026"],["Aug 2026","Pa. Court of Common Pleas (class action)","Penn Medicine","Meta Pixel, Google Analytics","$9.5M, preliminary approval; final hearing 12 Nov 2026","HIPAA Journal, 7 Aug 2026"],["Aug 2026","State courts (class actions)","Concord Hospital; Emanate Health; Mount Sinai Medical Center of Florida; Bayhealth","Website tracking tools (Google, Geonetric named at Concord)","$800,000; $777,000; $220,000; $25 per claimant plus monitoring","HIPAA Journal, 7 Aug 2026"],["Sep 2026","Broward County, Fla. (class action)","CVS Health and Criteo","Tools on CVS site and app sending data to Criteo, Adobe, Medallia, Quantum Metric","$18.5M (CVS) plus $2M (Criteo); final hearing 1 Dec 2026","HIPAA Journal, 24 Sep 2026"],["Sep 2026","Sacramento County (class action)","American Well (LiveHealth Online)","Pixels on appointment booking, Oct 2024 to Aug 2025; Wiretap, CIPA, CMIA","$2,037,751; final hearing 15 Jan 2027","HIPAA Journal, 24 Sep 2026"],["2026","N.D. Ga. (class action)","Wellstar Health System","Pixels on website and portal to Meta and Google; class Feb 2020 to Jul 2026","$4.25M; final hearing 1 Dec 2026","Top Class Actions, 2026"],["2026","N.C. (class action)","Cone Health","Pixel tracking","$1.76M; objection deadline 5 Oct 2026","Top Class Actions, 2026"],["Pending","N.D. Cal. (In re Meta Pixel Healthcare Litigation, No. 3:22-cv-03580-WHO)","Meta Platforms","Receipt of patient data via the Pixel from hospital sites","Class certification hearing reset to 22 Apr 2026; docket entry 1420 filed 12 Oct 2026; no ruling found","CAND case page; CourtListener docket"]],"sourceUrls":[["https://themarkup.org/pixel-hunt/2022/06/16/facebook-is-receiving-sensitive-medical-information-from-hospital-websites"],["https://www.shb.com/intelligence/client-alerts/pds/march-2024-revised-ocr-bulletin-saikali"],["https://www.ftc.gov/news-events/news/press-releases/2023/02/ftc-enforcement-action-bar-goodrx-sharing-consumers-sensitive-health-info-advertising"],["https://www.ftc.gov/news-events/news/press-releases/2023/03/ftc-ban-betterhelp-revealing-consumers-data-including-sensitive-mental-health-information-facebook"],["https://www.ftc.gov/news-events/news/press-releases/2023/05/ovulation-tracking-app-premom-will-be-barred-sharing-health-data-advertising-under-proposed-ftc"],["https://ag.ny.gov/press-release/2023/attorney-general-james-secures-300000-newyork-presbyterian-hospital-failing"],["https://www.choate.com/insights/ftc-seeks-significant-penalties-from-two-health-companies-alleging-misuse-of-consumer-personal-information/"],["https://www.choate.com/insights/ftc-seeks-significant-penalties-from-two-health-companies-alleging-misuse-of-consumer-personal-information/"],["https://www.aha.org/news/news/2024-06-20-judge-rules-favor-aha-vacating-hhs-online-tracking-bulletin-unlawful-and-beyond-agency-authority","https://therecord.media/hhs-drops-appeal-web-tracking-hospitals"],["https://www.dataprivacyandsecurityinsider.com/2024/07/advocate-aurora-health-12-2m-pixel-litigation-settlement-approved-by-court/"],["https://www.mofo.com/resources/insights/240514-ftc-issues-final-rule-to-expand"],["https://www.hunton.com/privacy-and-information-security-law/ftc-finalizes-orders-against-data-brokers-over-sensitive-location-data"],["https://paulhastings.com/insights/ph-privacy/biometrics-litigation-update-first-class-action-complaint-filed-under-washingtons-my-health-my-data-act-is-your-company-ready"],["https://oag.ca.gov/privacy/privacy-enforcement-actions"],["https://www.hipaajournal.com/marinhealth-meta-pixel-class-action-settlement/"],["https://blogs.duanemorris.com/classactiondefense/wp-content/uploads/sites/56/2025/09/Sweat-v.-Houston-Methodist-Hospital-Opinion.pdf"],["https://www.curvecompliance.com/pixel-settlements-to-date-running-reference"],["https://www.curvecompliance.com/pixel-settlements-to-date-running-reference"],["https://www.curvecompliance.com/pixel-settlements-to-date-running-reference"],["https://topclassactions.com/lawsuit-settlements/open-lawsuit-settlements/12-5m-allina-health-system-pixel-tracking-class-action-settlement/"],["https://www.classaction.org/news/1.8m-atrium-health-pixel-settlement-ends-class-action-lawsuit-over-alleged-patient-data-tracking"],["https://www.sec.gov/Archives/edgar/data/0001773751/000177375126000163/hims-20260630.htm","https://www.healthcaredive.com/news/ftc-sues-hims-hers-alleged-privacy-violations-deceptive-billing/826582/"],["https://www.hipaajournal.com/five-healthcare-providers-pixel-class-action-settlements/"],["https://www.hipaajournal.com/five-healthcare-providers-pixel-class-action-settlements/"],["https://www.hipaajournal.com/cvs-health-criteo-american-wellness-corp-data-breach-settlements/"],["https://www.hipaajournal.com/cvs-health-criteo-american-wellness-corp-data-breach-settlements/"],["https://topclassactions.com/lawsuit-settlements/open-lawsuit-settlements/4-25m-wellstar-health-tracking-pixel-class-action-settlement/"],["https://topclassactions.com/lawsuit-settlements/closed-settlements/1-76m-cone-health-pixel-tracking-class-action-settlement/"],["https://cand.uscourts.gov/cases-e-filing/cases/322-cv-03580-who/re-meta-pixel-healthcare-litigation","https://www.courtlistener.com/docket/63392738/in-re-meta-pixel-healthcare-litigation/"]]}