browser, the next time the user goes to a webpage with the same [d]efendant’s advertisements, a copy of that request can be associated with the unique third-party cookie previously placed. Thus the tracker can track the behavior of the user[.]”59 If the information at issue is sent to the defendants in the ordinary course, then this description of the cookies makes sense. This is because in such a scenario the defendants need only associate information to track it, which can be successfully accomplished by affixing an identifier to that information. This is precisely how the complaint describes the defendants’ cookies’ function. With respect to Google, the complaint pleads installation of Google’s “id” cookie, “which is a unique and consistent identifier given to each user by Google for its use in tracking persons across the entire spectrum of websites on which Google places . . . cookies.”60 Google allegedly uses this cookie to “identif[y] users,” such that “the placement of the third-party cookies, placed by circumventing Plaintiffs’ and Class Members’ privacy settings, allows this identification to take place.”61 Likewise, as to two of the other defendants, the complaint says that “[t]he spokesman [for Vibrant] admitted Vibrant used the 59 Compl. ¶ 46. 60 Compl. ¶ 95. 61 Compl. ¶ 96. 31

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