VIA CERTIFIED MAIL AND EMAIL—RETURN RECEIPT REQUESTED
AllTrails, LLC
530 Bush Street, Suite 900
San Francisco, California 94108
legal@alltrails.com
Pre-Arbitration Notice of Individual Consumer Privacy Dispute
To Whom It May Concern:
I am sending this Notice of Dispute to notify AllTrails, LLC and its corporate affiliates, individually or collectively referred to here as “AllTrails,” of a dispute regarding my use of AllTrails.com and AllTrails’s use of tracking technology on that website, including TikTok- and Meta-related tracking technology, code, or related processes, to capture, record, decode, or transmit information about my electronic communications and website interactions without valid prior authorization.
Nature and Basis of the Dispute
I personally used AllTrails.com while I was physically located in California during approximately the past {withinThe}{36Months}{612Months}{12Years} before this Notice. I used AllTrails.com to {browsedThe} {searchedFor} {createdOr} {purchasedAn} {signedUp} {engagedIn}.
When I used AllTrails.com, I understood that I was communicating and interacting with AllTrails for ordinary trail-browsing, searching, or account-related purposes. I did not know or understand that information associated with my communications and interactions with AllTrails.com would be captured, recorded, decoded, transmitted, or otherwise processed through TikTok- and Meta-related tracking technology in the manner described below.
Based on my current understanding and counsel’s investigation, AllTrails.com set or caused to be set TikTok- and Meta-related tracking technology during website sessions, including TikTok pixel resources, the _ttp cookie, Meta pixel, and associated browser-side scripts, network requests, and related software processes (collectively, the “Tracking Tools”). Among other things, those tools generated or caused browser-side requests to TikTok- and Meta-related endpoints that reflected information associated with website sessions and user activity. Upon information and belief, the Tracking Tools loaded during my AllTrails.com sessions and generated or caused requests reflecting information associated with my activity on the website, including pages viewed, trails and trail-related content viewed, search queries and geographic coordinates entered on the site, and nearby trail searches, as applicable. The information transmitted, generated, or reflected included non-content routing, addressing, signaling, source-identifying, browser-identifying, device-identifying, session-identifying, and related tracking information associated with my interactions with AllTrails.com—e.g., page URLs, referrer information, pageview and event information, search-query information, geographic-coordinate information, timestamps, IP-address information, browser and device information, user-agent information, persistent identifiers, cookies, and session-related identifiers. This information matters because it was tied to the context and purpose of my AllTrails.com activity and interactions—including search queries and geographic coordinates entered on the site, trails and trail-related content viewed, and nearby trail searches, as applicable—not merely to a generic visit to a public webpage. Taken together, these identifiers, event signals, and contextual data points could be used by AllTrails, TikTok, Meta, and other recipients to link my AllTrails.com activity to my browser, device, session, location, trail-browsing activity, or trail-search and nearby-trail interests over time. As a result, I lost control over my AllTrails.com activity and tracking data and was deprived of the ability to make an informed privacy choice.
I contend that this conduct violated Cal. Penal Code § 638.51 because AllTrails installed, used, or caused the use of a pen register or trap-and-trace device, process, or functionality to capture, record, decode, or transmit non-content dialing, routing, addressing, signaling, source-identifying, device-identifying, URL/referrer, search-query, geographic-coordinate, content/trail-view, event, cookie, IP, user-agent, persistent identifier, hashed matching-related, session, pageview, or similar information about my electronic communications and activity with AllTrails.com without first obtaining a court order and without my valid consent or other lawful authorization.
I also preserve related claims and theories under Cal. Penal Code § 631 and the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510–2523, to the extent the facts show that AllTrails or any third party intercepted, read, attempted to read, learned, used, disclosed, or aided the interception or use of the contents or substance of my communications with AllTrails.com without valid consent. I do not waive any other statutory, common-law, contract, privacy-policy, consumer-protection, equitable, or related theory that may be supported by the facts and law.
I did not knowingly authorize AllTrails to use, enable, or cause the operation of code, processes, or software to capture, record, decode, transmit, or otherwise process my data in the manner described above. To the extent AllTrails contends that its terms of use, privacy policy, cookie policy, or other disclosures provided authorization for the challenged conduct, I dispute that contention. More specifically, I dispute that generalized disclosures concerning cookies, analytics, advertising, service providers, targeted advertising, website measurement, data sharing, or similar practices provided clear, prior, specific, informed, and valid authorization for the challenged tracking activity described in this Notice. Consent is especially lacking where, as here, AllTrails did not present any cookie consent popup, banner, or similar mechanism during website sessions, meaning the challenged tracking technology loaded and operated without providing me any opportunity to make a privacy choice, or to the extent the challenged tracking technology operated despite a rejection of non-essential advertising or analytics technologies or continued after an opt-out request or similar privacy preference signal.
I am not aware of any court order, judicial authorization, statutory authorization, or other lawful authority permitting AllTrails, TikTok, Meta, or any related vendor to install, use, or operate the challenged tracking technology in connection with my communications and interactions with AllTrails.com.
Relief Sought
I seek all relief available under applicable law and any applicable agreement, including statutory damages where available; restitutionary relief and disgorgement; injunctive and equitable relief requiring AllTrails to cease the challenged tracking practices unless and until it obtains valid consent and complies with applicable law; deletion, non-use, or de-identification of data derived from the challenged tracking practices; preservation and disclosure of records; attorneys’ fees, arbitration fees, costs, and any additional relief available under law, contract, arbitration rules, or equity.
My current good-faith demand is $5,000, subject to supplementation after AllTrails provides records sufficient to evaluate the full amount of statutory, actual, equitable, and other relief owed. Because the number, timing, nature, and scope of any violations depend on records presently within AllTrails’s possession, custody, or control, as well as records maintained by third-party vendors and service providers, I reserve the right to supplement my damages calculation and requested relief after those records become available.
I request that AllTrails preserve all records and ESI relating to this dispute, including data, logs, code, configurations, communications, contracts, and materials in AllTrails’s possession, custody, or control or reasonably accessible through its vendors, service providers, contractors, or agents. AllTrails should suspend any routine deletion, overwriting, rotation, or destruction process that could affect records relevant to my interactions, the challenged tracking, the data collected or transmitted, relief, or resolution. I authorize AllTrails to communicate with my counsel identified below regarding this dispute and to produce to them all records and information concerning my account or associated with my use of AllTrails.com that are reasonably necessary to evaluate and resolve this dispute.
Informal Resolution
I am providing this Notice in good faith before initiating formal proceedings in order to afford AllTrails an opportunity to discuss an informal resolution of my dispute. Please confirm receipt of this Notice and contact my counsel within 14 business days. If AllTrails believes that additional information is required to evaluate or resolve this dispute, please identify the specific information requested and the contractual or legal basis for the request.
Without conceding that any 45-day period is contractually required, enforceable, or necessary to satisfy any condition precedent, I am willing to allow 45 days after AllTrails receives this Notice for informal resolution discussions. If the dispute is not resolved within that period, I intend to pursue my rights in any available forum and through any available procedure, including through individual arbitration before NAM. (AllTrails, LLC, Terms of Service (last updated Dec. 17, 2025), alltrails.com/terms.)
In doing so, I expressly reserve all arguments and objections to the validity, enforceability, applicability, interpretation, effect, or satisfaction of any AllTrails arbitration, waiver, limitation, forum, governing-law, mass-arbitration, public-injunction, unilateral-modification, informal-resolution, condition-precedent, or dispute-resolution provision, including objections concerning formation, assent, notice, scope, delegation, unconscionability, waiver, fees, costs, limitations periods, venue, arbitral rules, public injunctive relief, representative relief, and consistency with applicable law. I also reject, and do not consent to, any unilateral modification of AllTrails’s terms, privacy policy, or any other purportedly applicable terms unless I affirmatively agree in a separate signed writing.
This Notice is not a complete statement of all facts, claims, legal theories, damages, remedies, defenses, objections, responses, or grounds. I reserve the right to amend, supplement, refine, narrow, expand, or otherwise modify this Notice and my requested relief based upon additional investigation, records, technical analysis, discovery, expert review, arbitration proceedings, litigation proceedings, or other information.
Please direct all communications concerning this dispute to my counsel identified below.
Sincerely,