seedling
planted 2026-03-08 · tended 2026-03-10
unverified — check
Placeholder note
Structure is real; the analysis is not written yet. [draft — Peter to write]
The 12(b)(6) motion asks whether a complaint states a claim on which relief can be granted. Since Twombly and Iqbal, that question is really about plausibility — and in privacy cases, it often collapses into a standing question first.
see also
Compare the state-court version in the CPLR 3211 side-by-side.
Plausibility, concretely
[draft — Peter to write] — the two-step Iqbal analysis, the “well-pleaded facts” line, and how the tracking-pixel complaints try to clear it.