Sterk v. Redbox Automated Retail, LLC

In class action alleging improper delay in destroying plaintiffs-customers' video rental records under section 2710(e) of Video Privacy Protection Act, Dist. Ct. erred in finding that violations under section 2710(e) could be enforced in private cause of action under section 2710(c) of said Act. Language of section 2710(c) makes clear that it applies only to violations under section 2710(b) pertaining to unlawful disclosures of customer identification, and plaintiffs' proposed lawsuit otherwise would suggest no injury to plaintiffs, where, as here, plaintiffs merely alleged that defendant retained records for longer than one-year period set forth in section 2710(e), but did not disclose information contained in said records.