A recent decision from the Southern District of California underscores a point courts have made increasingly clear after the Ninth Circuit’s precedential decision in Popa v. Microsoft: alleging the disclosure of online activity—even activity touching on sensitive health topics—is not enough, by itself to establish Article III standing.  As the Court put it, the mere allegation that a defendant disclosed “sensitive health related” search terms, without any indication in the search terms that they “were tied to his personal medical history,” cannot establish a concrete injury.  Maghoney v. Dotdash Meredith, Inc., 2026 WL 497402 (S.D. Cal. Feb. 23, 2026) (emphasis added).