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National Basketball Association v. Michael Salazar

Paid petition · United States Court of Appeals for the Second Circuit, No. 23-1147 · judgment October 15, 2024


Certiorari denied · December 8, 2025
Pre-decision estimate: 4% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for counsel who has won certiorari before and a Second Circuit decision below.

Questions presented

The Video Privacy Protection Act prohibits any “video tape service provider” from “knowingly disclos[ing] … personally identifiable information concerning any consumer of such provider.” 18 U.S.C. § 2710(b)(1). The statute defines “video tape service provider” as “any person, engaged in the business … of rental, sale, or delivery of prerecorded video cassette tapes or similar audio visual materials.” Id. § 2710(a)(4). It defines “consumer” as “any renter, purchaser, or subscriber of goods or services from a video tape service provider.” Id. § 2710(a)(1). The NBA shows basketball highlights on its free public-facing website, and also allows fans to subscribe to a free online newsletter. Michael Salzar subscribes to the NBA’s newsletter. Separately, he claims he watched videos on the NBA’s website. He claims that the NBA’s website discloses his video viewing history to Meta, the company that operates Facebook, so that Meta can send him targeted ads. He does not allege that Meta ever has, or will, disclose his viewing history to the general public. The questions presented are:

  1. Whether a consumer claiming that he was harmed by disclosure of his personal information must plead that his information was revealed to the public to establish Article III standing, as the Third, Seventh, Tenth, and Eleventh Circuits have held, or whether the consumer need only plead that his information was disclosed to any third party without his consent, as the Second Circuit held below.

  2. Whether the VPPA bars a business from disclosing information about consumers who do not subscribe to its audiovisual goods or services.

Counsel of record

For petitioner
Shay Dvoretzky
Skadden, Arps, Slate, Meagher & Flom LLP

For respondent
Joshua Ian Hammack
Bailey & Glasser, LLP

Case

Conference history
Distributed for 8 conferences

Amicus briefs
2 cert-stage

Linked docket
24A629

Proceedings

  1. Dec 08 2025
    Petition DENIED.
  2. Dec 04 2025
    Supplemental brief of petitioner National Basketball Association filed.
  3. Dec 01 2025
    DISTRIBUTED for Conference of 12/5/2025.
  4. Nov 18 2025
    Rescheduled.
  5. Nov 17 2025
    DISTRIBUTED for Conference of 11/21/2025.
  6. Nov 10 2025
    DISTRIBUTED for Conference of 11/14/2025.
  7. Nov 10 2025
    Rescheduled.
  8. Nov 03 2025
    DISTRIBUTED for Conference of 11/7/2025.
  9. Nov 03 2025
    Rescheduled.
  10. Oct 15 2025
    Rescheduled.
  11. Oct 14 2025
    DISTRIBUTED for Conference of 10/17/2025.
  12. Oct 07 2025
    Rescheduled.
  13. Oct 07 2025
    Supplemental brief of respondent Michael Salazar filed.
  14. Oct 06 2025
    DISTRIBUTED for Conference of 10/10/2025.
  15. Sep 23 2025
    Rescheduled.
  16. Sep 02 2025
    Supplemental brief of respondent Michael Salazar filed. (Distributed)
  17. Aug 29 2025
    Supplemental brief of petitioner National Basketball Association filed. (Distributed)
  18. Aug 28 2025
    Letter of National Basketball Association not accepted for filing. (To be submitted as supplemental brief - August 29, 2025)
  19. Aug 15 2025
    Supplemental brief of petitioner National Basketball Association filed. (Distributed)
  20. Aug 13 2025
    Supplemental brief of respondent Michael Salazar filed. (Distributed)
  21. Jul 16 2025
    DISTRIBUTED for Conference of 9/29/2025.
  22. Jul 16 2025
    Reply of petitioner National Basketball Association filed. (Distributed)
  23. Jun 30 2025
    Brief of respondent Michael Salazar in opposition filed.
  24. May 02 2025
    Brief amicus curiae of National Football League filed.
  25. May 02 2025
    Brief amici curiae of National Retail Federation, et al. filed.
  26. Apr 24 2025
    Motion to extend the time to file a response is granted and the time is extended to and including July 1, 2025.
  27. Apr 22 2025
    Motion to extend the time to file a response from May 2, 2025 to July 1, 2025, submitted to The Clerk.
  28. Apr 02 2025
    Response Requested. (Due May 2, 2025)
  29. Mar 26 2025
    DISTRIBUTED for Conference of 4/17/2025.
  30. Mar 25 2025
    Waiver of right of respondent Michael Salazar to respond filed.
  31. Mar 14 2025
    Petition for a writ of certiorari filed. (Response due April 17, 2025)
  32. Jan 08 2025
    Application (24A629) granted by Justice Sotomayor extending the time to file until March 14, 2025.
  33. Dec 23 2024
    Application (24A629) to extend the time to file a petition for a writ of certiorari from January 13, 2025 to March 14, 2025, submitted to Justice Sotomayor.