complaint calls them “cookie blockers.” The cookie blockers of two browsers are at issue in this case. One is Microsoft’s Internet Explorer, which featured an “opt-in” cookie blocker that a user could elect to activate. The other is Apple’s Safari browser, which featured an “opt-out” cookie blocker that was activated by default. The complaint notes that the main Apple website page dedicated to Safari advertised its opt-out cookie blocker as a unique feature, stating that, “to better protect[] your privacy[,] Safari accepts cookies only from the websites you visit.”4 Likewise, the Safari browser labeled its default cookie setting as “Block cookies: From third parties and advertisers.”5 According to the complaint, the Safari and Internet Explorer cookie blockers were well-known to industry participants, including as to their existence, functionality, and purpose. More is alleged about Google in particular. Google’s Privacy Policy explained that “most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.”6 Google provided further assurances about the Safari cookie blocker specifically. Google offered a proprietary cookie blocker, a so-called “opt-out cookie” that, when downloaded, would prevent the installation of tracking cookies. On the public webpage Google maintained to describe its opt-out cookie, Google assured visitors that “Safari is set by default 4 Compl. ¶ 69. 5 Compl. ¶ 71. 6 Compl. ¶ 80. 8