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It'd be impossible for Google Analytics to not collect data from a incognito tab without it knowing that it is incognito somehow (like if Chrome attached a head

It'd be impossible for Google Analytics to not collect data from a incognito tab without it knowing that it is incognito somehow (like if Chrome attached a header to all outgoing requests that said incognito=1 or something). But then websites would know you are in incognito, and find some other way to track you without leaving cookies on your box (like logging the IP address for the request and merging all incognito requests into one profile, which would be accurate enough). What do they want Google to do? They warn you specifically of this anyway when you open an incognito tab: " You've gone incognito Now you can browse privately, and other people who use this device won't see your activity. However, downloads and bookmarks will be saved. Learn more... Chrome won't save the following information: Your browsing history Cookies and site data Information entered in forms Your activity might still be visible to: Websites you visit Your employer or school Your internet service provider "

crescentfresh 6y ago
> without it knowing that it is incognito somehow It has been a while since I was in js land but I do recall writing a browser extension that needed to know this, and in chrome it was made available to detect whether your script was running in incognito. It was a property of something. So I imagine as a starting point the Google Analytics client js could utilize this to avoid interacting with the analytics server altogether.
- gene91 6y ago
  The ability by websites to detect incognito cause real usability pains for users. (For example, certain news outlets refuse to show content when it detects that you're in incognito.) The mechanisms to detect incognito were/are unintended holes. Both FireFox and Chrome have been plugging them.
- ehsankia 6y ago
  Well your information is outdated, because there's been a long game of cat and mouse between chrome and sites likes NYT about detecting incognito, with every alternating version a new method coming up, and it being patched in the following version. [0] https://boingboing.net/2019/07/20/cookie-managers-r-us.html https://boingboing.net/2019/07/20/cookie-managers-r-us.html
- the_gipsy 6y ago
  Regular js is not able to distinguish incognito mode from some browser API. Extensions get access to a much broader API.
Espressosaurus 6y ago
It would be easy. They'd have to just not collect, collate, fingerprint, and otherwise acquire enough PII to de-anonymize anyone that touches a script that feeds back to their servers. > "Google tracks and collects consumer browsing history and other web activity data no matter what safeguards consumers undertake to protect their data privacy," reads the complaint. The search giant surreptitiously collects data through Google Analytics, Google Ad Manager, website plug-ins and other applications, including mobile apps, according to the complaint. The web worked fine in the days before Google started building a profile of everyone who interacts with the internet so that they can sell us garbage we don't need. So how about stopping with the voracious data collection feeding into a permanent profile? You know, like the web used to work? Just because it is now doesn't mean it hasn't been deliberately built into the thing that presently exists. edit: and if that makes certain ad-centric businesses obsolete, good.
- VikingCoder 6y ago
  Would you consider IP address enough to de-anonymize most people? Why not?
  - cmroanirgo 6y ago
    Definitely not. Case 1. Fixed home broadband often allocates a single IP that the household might have for weeks, months or years. There might be only one person in the house, and even if not it's easy to build a profile across websites visited on how many live there, what time they're active, etc. Case 2. Mobile broadband often allocates IP seemingly based on the tower you're connected to (in my country, I can notice this effect). So, looking at the surface of the you'd think it arguable that mobile IP is anonymised... Unfortunately, people are creatures of habit and ping the same towers repeatedly. So it's still possible to track. In short, if there's value to be had in storing any value (like an IP) for ad related purposes, then there's more than a good chance personal information is leaking.
    - SpicyLemonZest 6y ago
      Right, that's the point. Chrome will send "enough PII to de-anonymize" no matter how careful they try to be, because your IP address is very often enough.
brokencode 6y ago
Google could send the incognito flag to only their own websites to honor this setting while also preventing shady third parties from knowing you’re incognito. The point is that Google knows that you don’t want to be tracked, and has full control of both the server and browser, yet tracks you anyway.
- gene91 6y ago
  It's not clear to me whether you're being sarcastic here. People often complain that Chrome gives Google special treatment. Here on HN, people (incl me) will definitely be outraged if Google does what you're proposing.
enumjorge 6y ago
The article is very light on details, but am I understanding correctly that the problem is google analytics not honoring settings in chrome? If so, I can't think of a solution that doesn't involve a tighter integration between websites and chrome, and if anything I think we should be moving away from that.
- c22 6y ago
  They could set the do not track flag in incognito mode and honor the do not track flag on their web properties.
  - bonestamp2 6y ago
    Wow, I didn't realize google analytics doesn't respect the do not track flag. But I just independently verified that is correct. It sounds like this is a simple and elegant solution to the problem (and the moral solution too).
    - wilsonrocks 6y ago
      I used a google analytics plugin for Gatsby, and it had a respectDoNotTrack configuration option when you set it up, which does respect it - but I presume that just doesn't send the data to google in the first place.
- dehrmann 6y ago
  Incognito isn't a setting, per se, it's a policy. It scopes the cache, cookies, etc. to a sandbox that's deleted once all incognito windows are closed. Google Analytics doesn't even know this policy is in place. The only websites that "honor" incognito are media outlets with paywalls using tricks (tricks Google's always trying to fix) to detect that you're in incognito mode.
- mindslight 6y ago
  The problem isn't a technical one per se, but rather a legal one. Google the company is offering a browser that purports to make someone "incognito" while simultaneously working to track people who are using it - the exact opposite of what one would expect. Mozilla isn't getting sued for the failings of Firefox's private mode because Mozilla doesn't operate a surveillance system that exploits those failings, and Facebook isn't getting sued for their exploitative surveillance because they aren't offering a product that claims to protect you.
mtgp1000 6y ago
>What do they want Google to do? I don't know about "them" but I want Google to stop tracking me and building a secret profile of intimate and politically sensitive information on my person. Full God damn stop. I take as many steps as I can but even not using Google's services is no guarantee of protection and leaving the internet behind completely is not practical if you wish to succeed in modern society. Adtech is the cancer that is forming the foundation for unprecedented human rights abuses. Look at the state of the country, imagine what either political extreme would do with access to even a fraction of the data that platforms like Google and Facebook collect. A wet dream shared by every dictator in history, from Stalin to Hitler to Mao. I did not consent.
- staticassertion 6y ago
  OK but that isn't what the lawsuit is about.
burkaman 6y ago
They could spin off Analytics or Chrome into a separate company, so they don't have this inherent conflict of interest. They could also modify the warning text: " Google won't save the following information locally: Your browsing history Cookies and site data Information entered in forms Your activity might still be visible to: Google Websites you visit Your employer or school Your internet service provider "
josephcsible 6y ago
> like if Chrome attached a header to all outgoing requests that said incognito=1 or something Which, by the way, would be a disaster. There's already enough otherwise-legitimate sites that exploit browser bugs to detect incognito mode and replace all of their content with a paywall.
silverwind 6y ago
> if Chrome attached a header to all outgoing requests that said incognito=1 or something The "DNT" header already exists for this purpose, it's just that Chrome does not actually set in when incognito.
stiray 6y ago
They dont need to invent their own header. They just need to obey existing ones: https://en.wikipedia.org/wiki/Do_Not_Track https://en.wikipedia.org/wiki/Do_Not_Track I would expect that no script would be loaded from google analytics/tag manager domains once I turn it on. But this is obviously not the case. The article is too vague to actually understand more about what this lawsuit is but regarding: Google tracks and collects consumer browsing history and other web activity data no matter what safeguards consumers undertake to protect their data privacy," reads the complaint. The search giant surreptitiously collects data through Google Analytics, Google Ad Manager, website plug-ins and other applications, including mobile apps, according to the complaint. They are right. Google is doing that. I think that incognito mode was mentioned due to this statement: safeguards consumers undertake to protect their data privacy. They will probably build the case that they tried to protect themselfs but google was still tracking them. And if chrome is sending to google servers flag that user has turned on incognito mode (which I bet they are/did), then they are having a serious problem. "Poor user, this little girl with cute blue eyes, tried to protect itself from invasion of her privacy, they knew that but were still tracking her" If this is the case they will have to pay or bribe the judge. The law firm that is behind it is specialized into class action lawsuits with crew of around 300 lawyers so I expect a good show. I hope google wont settle outside the court.
- pacala 6y ago
  Does Google Chrome set DoNotTrack by default in incognito mode? If not, why not?
  - pmiller2 6y ago
    I'm not sure if they do, but one potential reason not to do it is that setting DNT literally gives the server 1 additional bit of information about your configuration. This could be used to track you more effectively.
    - pacala 6y ago
      1 extra bit is the last of my concerns, there's plenty of bits to uniquely fingerprint a browser anyways. I'd gladly trade one inconsequential bit, which requires malicious intent to misuse, to keep my privacy safe when dealing with honorable entities like, I presume, Google. https://blog.mozilla.org/internetcitizen/2018/07/26/this-is-your-digital-fingerprint https://blog.mozilla.org/internetcitizen/2018/07/26/this-is-... What goes into one's fingerprint: 1. navigator.userAgent, 2. navigator.language, 3. navigator.doNotTrack, 4. screen.width, 5. screen.height, 6. screen.colorDepth, 7. Intl.DateTimeFormat().resolvedOptions().timeZone, 8. navigator.platform, 9. navigator.hardwareConcurrency, 10. GPU vendor and renderer, 11. isTouch, 12. storage types, 13. font-list, 14. canvas-hash
UncleMeat 6y ago
I also wonder what makes Google unique here? Is it the browser? Firefox has an equivalent mode. Is it the web app? Virtually every single web app sets cookies even when you are in incognito mode.
- dahfizz 6y ago
  > I also wonder what makes Google unique here? They have tons of money and they are politically popular to hate on. There is no reason not to fine them.
  - SkyBelow 6y ago
    On a certain level fines and other punishments exist because they are politically popular.
  - BossingAround 6y ago
    They have also a ton of already existing information on you from platforms such as Android and gmail, can track you on multiple levels including your location, and serve you micro targeted ads. Saying they are politically popular to hate on sounds as if the criticism is not warranted.
    - three_seagrass 6y ago
      Hating on FAANG is a popular political stance these days. Some of it's justified, but a lot of it is also just posturing.
    - dahfizz 6y ago
      > Saying they are politically popular to hate on sounds as if the criticism is not warranted. The criticism is definitely warranted, but that is a very shallow take on things. Privacy issues with incognito mode have been known about for years[1]. But all of a sudden, suing Google (and making a spectacle of it) is a big priority. I think it is pretty likely that the government is trying to make some easy money and publicity points after current events have left them hurting for both. Maybe the government is full of altruists, doing what is warranted when it is warranted, but I think starting from that assumption is pretty naive. [1] https://nypost.com/2018/08/22/googles-incognito-mode-isnt-as-private-as-you-thought/ https://nypost.com/2018/08/22/googles-incognito-mode-isnt-as...
screamingninja 6y ago
https://en.wikipedia.org/wiki/Do_Not_Track https://en.wikipedia.org/wiki/Do_Not_Track `DNT=1` would have done the job. Unfortunately, the standard was not widely adopted and subsequently abandoned.
pwdisswordfish2 6y ago
"It'd be impossible for Google Analytics to not collect data from a incognito tab without it knowing that it is incognito somehow (like if Chrome attached a header to all outgoing requests that said incognito=1 or something)." Developer Tools allows users to block specific requests, e.g., to google-analytics.com, either by URL or by domain. It is possible (but not implemented by Google) to automatically activate such request blocking when an incognito tab is opened. This is one way to stop GA tracking when in incognito mode. The quoted warning "Your activity might be visible to:" lists a few third parties, e.g., "websites you visit", "Your employer or school", "Your internet servive provider". However it does not list Google, LLC or Alphabet, Inc. The complaint is against Google and Alphabet, not the other other third parties. Here is a copy of the complaint: https://www.classaction.org/media/brown-et-al-v-google-llc-et-al.pdf https://www.classaction.org/media/brown-et-al-v-google-llc-e... For those who will not read the complaint: In addition to GA, the complaint alleges Google tracks users without consent via Google Ad Manager, the "Sign in with Google" button, including Google Approved Pixels, despite incognito mode or privacy settings. It further alleges tracking without consent via Android, despite igcognito mode or privacy settings, as described in the following paper Douglas C. Schmidt, Google Data Collection, DIGITAL CONTENT NEXT 1 (Aug. 15, 2018), https://digitalcontentnext.org/blog/2018/08/21/google-data-collection-research/ https://digitalcontentnext.org/blog/2018/08/21/google-data-c... Finally, it alleges Google conducts tracking without consent, despite incognito mode or privacy settings, via the "X-client-data" header in Chrome (formerly "X-chrome-variations") as described in the article Thomas Claburn, Is Chrome Really Secretly Stalking You Across Google Sites Using Per-Install ID Numbers? We Reveal the Truth, THE REGISTER (Feb. 5, 2020), https://www.theregister.co.uk/2020/02/05/google_chrome_id_numbers/ https://www.theregister.co.uk/2020/02/05/google_chrome_id_nu... The complaint argues Google is representing to users that "You are in control" via Google's incognito mode and privacy settings however Google is nonethless tracking users via all of the above methods without user consent. This arguably constitutes misrepresentation. To recover damages, the wiretapping laws require that there must be some injury. If users' privacy is violated, what pecuniary loss do they suffer? This is usually why these lawsuits always fail. This complaint uses this source to try to estimate damages Tim Morey, What s Your Personal Data Worth?, DESIGN MIND (Jan. 18, 2011), https://web.archive.org/web/20140703174004/http://designmind.frogdesign.com/blog/what039s-your-personal-data-worth.html https://web.archive.org/web/20140703174004/http://designmind... Contact info: $4.20/yr Demographics info: $3.00/yr Web browsing histories: $52.00/yr The complaint also cites the "Google Screenwise Trends" program where Google pays users $3/week to be tracked. The complaint mentions the websites Latome and Killi where users can voluntarily sell their personal data, noting that Google OTOH takes such personal data without asking for permission and without providing compensation. The complaint also appears to suggest that the user's ability to obtain the maximum value from granting permission to collect and sell her personal data, e.g., via Latome or Killi, is decreased as a result of Google's unauthorised collection and sale of it without the user's consent.

crescentfresh 6y ago

> without it knowing that it is incognito somehow It has been a while since I was in js land but I do recall writing a browser extension that needed to know this, and in chrome it was made available to detect whether your script was running in incognito. It was a property of something. So I imagine as a starting point the Google Analytics client js could utilize this to avoid interacting with the analytics server altogether.

gene91 6y ago
The ability by websites to detect incognito cause real usability pains for users. (For example, certain news outlets refuse to show content when it detects that you're in incognito.) The mechanisms to detect incognito were/are unintended holes. Both FireFox and Chrome have been plugging them.
ehsankia 6y ago
Well your information is outdated, because there's been a long game of cat and mouse between chrome and sites likes NYT about detecting incognito, with every alternating version a new method coming up, and it being patched in the following version. [0] https://boingboing.net/2019/07/20/cookie-managers-r-us.html https://boingboing.net/2019/07/20/cookie-managers-r-us.html
the_gipsy 6y ago
Regular js is not able to distinguish incognito mode from some browser API. Extensions get access to a much broader API.

Espressosaurus 6y ago

It would be easy. They'd have to just not collect, collate, fingerprint, and otherwise acquire enough PII to de-anonymize anyone that touches a script that feeds back to their servers. > "Google tracks and collects consumer browsing history and other web activity data no matter what safeguards consumers undertake to protect their data privacy," reads the complaint. The search giant surreptitiously collects data through Google Analytics, Google Ad Manager, website plug-ins and other applications, including mobile apps, according to the complaint. The web worked fine in the days before Google started building a profile of everyone who interacts with the internet so that they can sell us garbage we don't need. So how about stopping with the voracious data collection feeding into a permanent profile? You know, like the web used to work? Just because it is now doesn't mean it hasn't been deliberately built into the thing that presently exists. edit: and if that makes certain ad-centric businesses obsolete, good.

VikingCoder 6y ago
Would you consider IP address enough to de-anonymize most people? Why not?
- cmroanirgo 6y ago
  Definitely not. Case 1. Fixed home broadband often allocates a single IP that the household might have for weeks, months or years. There might be only one person in the house, and even if not it's easy to build a profile across websites visited on how many live there, what time they're active, etc. Case 2. Mobile broadband often allocates IP seemingly based on the tower you're connected to (in my country, I can notice this effect). So, looking at the surface of the you'd think it arguable that mobile IP is anonymised... Unfortunately, people are creatures of habit and ping the same towers repeatedly. So it's still possible to track. In short, if there's value to be had in storing any value (like an IP) for ad related purposes, then there's more than a good chance personal information is leaking.
  - SpicyLemonZest 6y ago
    Right, that's the point. Chrome will send "enough PII to de-anonymize" no matter how careful they try to be, because your IP address is very often enough.

brokencode 6y ago

Google could send the incognito flag to only their own websites to honor this setting while also preventing shady third parties from knowing you’re incognito. The point is that Google knows that you don’t want to be tracked, and has full control of both the server and browser, yet tracks you anyway.

gene91 6y ago
It's not clear to me whether you're being sarcastic here. People often complain that Chrome gives Google special treatment. Here on HN, people (incl me) will definitely be outraged if Google does what you're proposing.

enumjorge 6y ago

The article is very light on details, but am I understanding correctly that the problem is google analytics not honoring settings in chrome? If so, I can't think of a solution that doesn't involve a tighter integration between websites and chrome, and if anything I think we should be moving away from that.

c22 6y ago
They could set the do not track flag in incognito mode and honor the do not track flag on their web properties.
- bonestamp2 6y ago
  Wow, I didn't realize google analytics doesn't respect the do not track flag. But I just independently verified that is correct. It sounds like this is a simple and elegant solution to the problem (and the moral solution too).
  - wilsonrocks 6y ago
    I used a google analytics plugin for Gatsby, and it had a respectDoNotTrack configuration option when you set it up, which does respect it - but I presume that just doesn't send the data to google in the first place.
dehrmann 6y ago
Incognito isn't a setting, per se, it's a policy. It scopes the cache, cookies, etc. to a sandbox that's deleted once all incognito windows are closed. Google Analytics doesn't even know this policy is in place. The only websites that "honor" incognito are media outlets with paywalls using tricks (tricks Google's always trying to fix) to detect that you're in incognito mode.
mindslight 6y ago
The problem isn't a technical one per se, but rather a legal one. Google the company is offering a browser that purports to make someone "incognito" while simultaneously working to track people who are using it - the exact opposite of what one would expect. Mozilla isn't getting sued for the failings of Firefox's private mode because Mozilla doesn't operate a surveillance system that exploits those failings, and Facebook isn't getting sued for their exploitative surveillance because they aren't offering a product that claims to protect you.

mtgp1000 6y ago

>What do they want Google to do? I don't know about "them" but I want Google to stop tracking me and building a secret profile of intimate and politically sensitive information on my person. Full God damn stop. I take as many steps as I can but even not using Google's services is no guarantee of protection and leaving the internet behind completely is not practical if you wish to succeed in modern society. Adtech is the cancer that is forming the foundation for unprecedented human rights abuses. Look at the state of the country, imagine what either political extreme would do with access to even a fraction of the data that platforms like Google and Facebook collect. A wet dream shared by every dictator in history, from Stalin to Hitler to Mao. I did not consent.

staticassertion 6y ago
OK but that isn't what the lawsuit is about.

burkaman 6y ago

They could spin off Analytics or Chrome into a separate company, so they don't have this inherent conflict of interest. They could also modify the warning text: " Google won't save the following information locally: Your browsing history Cookies and site data Information entered in forms Your activity might still be visible to: Google Websites you visit Your employer or school Your internet service provider "

josephcsible 6y ago

> like if Chrome attached a header to all outgoing requests that said incognito=1 or something Which, by the way, would be a disaster. There's already enough otherwise-legitimate sites that exploit browser bugs to detect incognito mode and replace all of their content with a paywall.

silverwind 6y ago

> if Chrome attached a header to all outgoing requests that said incognito=1 or something The "DNT" header already exists for this purpose, it's just that Chrome does not actually set in when incognito.

stiray 6y ago

They dont need to invent their own header. They just need to obey existing ones: https://en.wikipedia.org/wiki/Do_Not_Track https://en.wikipedia.org/wiki/Do_Not_Track I would expect that no script would be loaded from google analytics/tag manager domains once I turn it on. But this is obviously not the case. The article is too vague to actually understand more about what this lawsuit is but regarding: Google tracks and collects consumer browsing history and other web activity data no matter what safeguards consumers undertake to protect their data privacy," reads the complaint. The search giant surreptitiously collects data through Google Analytics, Google Ad Manager, website plug-ins and other applications, including mobile apps, according to the complaint. They are right. Google is doing that. I think that incognito mode was mentioned due to this statement: safeguards consumers undertake to protect their data privacy. They will probably build the case that they tried to protect themselfs but google was still tracking them. And if chrome is sending to google servers flag that user has turned on incognito mode (which I bet they are/did), then they are having a serious problem. "Poor user, this little girl with cute blue eyes, tried to protect itself from invasion of her privacy, they knew that but were still tracking her" If this is the case they will have to pay or bribe the judge. The law firm that is behind it is specialized into class action lawsuits with crew of around 300 lawyers so I expect a good show. I hope google wont settle outside the court.

pacala 6y ago
Does Google Chrome set DoNotTrack by default in incognito mode? If not, why not?
- pmiller2 6y ago
  I'm not sure if they do, but one potential reason not to do it is that setting DNT literally gives the server 1 additional bit of information about your configuration. This could be used to track you more effectively.
  - pacala 6y ago
    1 extra bit is the last of my concerns, there's plenty of bits to uniquely fingerprint a browser anyways. I'd gladly trade one inconsequential bit, which requires malicious intent to misuse, to keep my privacy safe when dealing with honorable entities like, I presume, Google. https://blog.mozilla.org/internetcitizen/2018/07/26/this-is-your-digital-fingerprint https://blog.mozilla.org/internetcitizen/2018/07/26/this-is-... What goes into one's fingerprint: 1. navigator.userAgent, 2. navigator.language, 3. navigator.doNotTrack, 4. screen.width, 5. screen.height, 6. screen.colorDepth, 7. Intl.DateTimeFormat().resolvedOptions().timeZone, 8. navigator.platform, 9. navigator.hardwareConcurrency, 10. GPU vendor and renderer, 11. isTouch, 12. storage types, 13. font-list, 14. canvas-hash

UncleMeat 6y ago

I also wonder what makes Google unique here? Is it the browser? Firefox has an equivalent mode. Is it the web app? Virtually every single web app sets cookies even when you are in incognito mode.

dahfizz 6y ago
> I also wonder what makes Google unique here? They have tons of money and they are politically popular to hate on. There is no reason not to fine them.
- SkyBelow 6y ago
  On a certain level fines and other punishments exist because they are politically popular.
- BossingAround 6y ago
  They have also a ton of already existing information on you from platforms such as Android and gmail, can track you on multiple levels including your location, and serve you micro targeted ads. Saying they are politically popular to hate on sounds as if the criticism is not warranted.
  - three_seagrass 6y ago
    Hating on FAANG is a popular political stance these days. Some of it's justified, but a lot of it is also just posturing.
  - dahfizz 6y ago
    > Saying they are politically popular to hate on sounds as if the criticism is not warranted. The criticism is definitely warranted, but that is a very shallow take on things. Privacy issues with incognito mode have been known about for years[1]. But all of a sudden, suing Google (and making a spectacle of it) is a big priority. I think it is pretty likely that the government is trying to make some easy money and publicity points after current events have left them hurting for both. Maybe the government is full of altruists, doing what is warranted when it is warranted, but I think starting from that assumption is pretty naive. [1] https://nypost.com/2018/08/22/googles-incognito-mode-isnt-as-private-as-you-thought/ https://nypost.com/2018/08/22/googles-incognito-mode-isnt-as...

screamingninja 6y ago

https://en.wikipedia.org/wiki/Do_Not_Track https://en.wikipedia.org/wiki/Do_Not_Track `DNT=1` would have done the job. Unfortunately, the standard was not widely adopted and subsequently abandoned.

pwdisswordfish2 6y ago

"It'd be impossible for Google Analytics to not collect data from a incognito tab without it knowing that it is incognito somehow (like if Chrome attached a header to all outgoing requests that said incognito=1 or something)." Developer Tools allows users to block specific requests, e.g., to google-analytics.com, either by URL or by domain. It is possible (but not implemented by Google) to automatically activate such request blocking when an incognito tab is opened. This is one way to stop GA tracking when in incognito mode. The quoted warning "Your activity might be visible to:" lists a few third parties, e.g., "websites you visit", "Your employer or school", "Your internet servive provider". However it does not list Google, LLC or Alphabet, Inc. The complaint is against Google and Alphabet, not the other other third parties. Here is a copy of the complaint: https://www.classaction.org/media/brown-et-al-v-google-llc-et-al.pdf https://www.classaction.org/media/brown-et-al-v-google-llc-e... For those who will not read the complaint: In addition to GA, the complaint alleges Google tracks users without consent via Google Ad Manager, the "Sign in with Google" button, including Google Approved Pixels, despite incognito mode or privacy settings. It further alleges tracking without consent via Android, despite igcognito mode or privacy settings, as described in the following paper Douglas C. Schmidt, Google Data Collection, DIGITAL CONTENT NEXT 1 (Aug. 15, 2018), https://digitalcontentnext.org/blog/2018/08/21/google-data-collection-research/ https://digitalcontentnext.org/blog/2018/08/21/google-data-c... Finally, it alleges Google conducts tracking without consent, despite incognito mode or privacy settings, via the "X-client-data" header in Chrome (formerly "X-chrome-variations") as described in the article Thomas Claburn, Is Chrome Really Secretly Stalking You Across Google Sites Using Per-Install ID Numbers? We Reveal the Truth, THE REGISTER (Feb. 5, 2020), https://www.theregister.co.uk/2020/02/05/google_chrome_id_numbers/ https://www.theregister.co.uk/2020/02/05/google_chrome_id_nu... The complaint argues Google is representing to users that "You are in control" via Google's incognito mode and privacy settings however Google is nonethless tracking users via all of the above methods without user consent. This arguably constitutes misrepresentation. To recover damages, the wiretapping laws require that there must be some injury. If users' privacy is violated, what pecuniary loss do they suffer? This is usually why these lawsuits always fail. This complaint uses this source to try to estimate damages Tim Morey, What s Your Personal Data Worth?, DESIGN MIND (Jan. 18, 2011), https://web.archive.org/web/20140703174004/http://designmind.frogdesign.com/blog/what039s-your-personal-data-worth.html https://web.archive.org/web/20140703174004/http://designmind... Contact info: $4.20/yr Demographics info: $3.00/yr Web browsing histories: $52.00/yr The complaint also cites the "Google Screenwise Trends" program where Google pays users $3/week to be tracked. The complaint mentions the websites Latome and Killi where users can voluntarily sell their personal data, noting that Google OTOH takes such personal data without asking for permission and without providing compensation. The complaint also appears to suggest that the user's ability to obtain the maximum value from granting permission to collect and sell her personal data, e.g., via Latome or Killi, is decreased as a result of Google's unauthorised collection and sale of it without the user's consent.