VIA EMAIL
Cars.com, Inc.
1209 Orange Street
Wilmington, DE 19801
legal@carscommerce.inc
Pre-Arbitration Notice of Individual Consumer Privacy Dispute
To Whom It May Concern:
I am sending this Notice of Dispute to notify Cars.com, Inc., together with its subsidiaries, affiliates, agents, and related entities (collectively, “Cars.com”), of my individual dispute arising from my use of Cars.com’s websites and associated digital services, including Cars.com (collectively, “Cars.com”), and Cars.com’s use or enablement of third-party tracking code, together with related scripts and processes, to capture, record, decode, read, learn, transmit, disclose, or otherwise process information associated with my electronic communications and interactions without my valid prior consent or other lawful authorization.
Nature and Basis of the Dispute
I personally used Cars.com while I was physically located in {answer_2}. During my use of Cars.com, I {answer_3} and engaged in other account- or transaction-related activity. To the best of my recollection, I did so within the past {typeA279} preceding this Notice.
When I used Cars.com, I understood that I was communicating and interacting with Cars.com for informational, search, review, purchase, account or other consumer purposes. I did not know or understand that information associated with my communications and interactions with Cars.com would be captured, recorded, decoded, read, learned, transmitted, disclosed, or otherwise processed through third-party tracking code in the manner described below.
Based on my current understanding and counsel’s investigation, Cars.com deployed, enabled, or caused to be deployed or enabled third-party tracking code associated with TikTok and Meta/Facebook and potentially other third-parties on Cars.com. These tracking codes, together with related scripts and processes, are referred to in this Notice as the “Tracking Tools.”
Upon information and belief, TikTok Pixel and Facebook (Meta) Pixel operated during my use of Cars.com and caused or permitted the contents of my communications and information associated with my interactions, browser, device, or session to be transmitted or otherwise made available to those third parties. The transmitted information included or reflected, as applicable, Search events transmitting full vehicle search information directly to TikTok as a discrete event type, while Facebook records Search events transmitting full vehicle search information including make, model, and zip code. ViewContent events and EngagedUserEvents were also tracked.
The Tracking Tools also captured, recorded, transmitted, or otherwise processed non-content routing, addressing, signaling, source-identifying, browser-identifying, device-identifying, session-identifying, event-identifying, and related information associated with my use of Cars.com (e.g., IP addresses, URLs, referring URLs, timestamps, user agent information, cookies, advertising or persistent identifiers, or session identifiers).
This information was tied to the context and purpose of my use of Cars.com—including the make and model of vehicles I searched for or considered—and was not limited to information showing only that an unidentified person visited a generic public webpage or opened an application. Taken together, the transmitted communications, contextual information, event signals, and identifiers could permit Cars.com, Meta/Facebook, TikTok, or other recipients to associate my use of Cars.com with my browser, device, session, approximate location, account, identity, communications, searches, interests, selections, or other activity over time.
I did not knowingly authorize Cars.com to use, enable, or cause the operation of the Tracking Tools to capture, record, decode, read, learn, transmit, disclose, or otherwise process my information in the manner described above. To the extent Cars.com contends that its terms of service, privacy policy, cookie policy, consent notice, or other disclosures provided authorization for the challenged conduct, I dispute that contention. More specifically, I dispute that generalized disclosures concerning cookies, pixels, analytics, advertising, service providers, personalization, targeted advertising, website or application measurement, data sharing, or similar practices provided clear, prior, specific, informed, and valid authorization for the particular tracking, interception, or transmission described in this Notice. Consent is especially lacking to the extent the Tracking Tools operated before I had a meaningful opportunity to review a relevant disclosure or make a privacy choice, operated before I affirmatively accepted non-essential tracking code, operated despite my rejection of such technologies, or continued to operate 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 Cars.com, Meta/Facebook, TikTok, or any related entity to install, use, or operate the challenged Tracking Tools in connection with my electronic communications and interactions with Cars.com.
As a result of Cars.com’s conduct, I lost control over information associated with my use of Cars.com and was deprived of the ability to make an informed privacy choice.
I contend this conduct violated federal and state privacy, and anti-wiretapping laws, including laws prohibiting interception, unlawful disclosure or use of intercepted communications, and the procurement, inducement, or assistance of such conduct. This includes related claims and theories under The Federal Wiretap Act, as amended by the Electronic Communications Privacy Act of 1986 (“ECPA”), 18 U.S.C. §§ 2510–2523, and analogous state anti-wiretapping statutes.
I further contend that Cars.com violated California Penal Code § 638.51, because Cars.com 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 routing, addressing, signaling, and related information about my electronic communications without first obtaining a court order and without my valid consent or other lawful authorization.
I expressly reserve all other statutory, common-law, contract, privacy-policy, consumer-protection, equitable, or related claim or theory that may be supported by the facts and law.
Relief Sought
I seek all relief available under applicable law, including statutory damages where available; restitution and disgorgement; injunctive and equitable relief requiring Cars.com to cease the challenged tracking practices; attorney 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 Cars.com provides records sufficient to evaluate the total amount and full scope of relief available. Because the number, timing, nature, and scope of any violations depend on records presently within Cars.com’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.
Please preserve all records reasonably related to the challenged tracking practices, including tracking-activation logs from my sessions; configuration and deployment records for those technologies; installation, modification, and removal records for each; vendor and personnel records identifying who deployed or configured the tracking technologies and the third parties who received the data; and account, session, device, and consent records tied to me.
Informal Resolution
I am providing this Notice in good faith to give Cars.com an opportunity to discuss an informal resolution of my dispute before formal proceedings become necessary. Without conceding that any pre-dispute notice, informal-resolution process, waiting period, or other condition precedent is contractually required, applicable, enforceable, or unsatisfied, I am willing to engage in good-faith informal-resolution discussions during the 60 days following Cars.com’s receipt of this Notice. I reserve the right to initiate arbitration or another proceeding sooner if reasonably necessary to preserve my claims.
If the dispute is not resolved, I am prepared to initiate individual arbitration before AAA and pursue any other available remedy. See Cars.com Terms of Service, https://www.cars.com/about/terms (last visited August 4, 2026). If arbitration becomes necessary, I will seek all recoverable attorneys’ fees and, to the fullest extent permitted by applicable law, contract, and arbitral rules, the maximum permissible allocation to Cars.com of filing fees, administrative fees, arbitrator compensation, and other arbitration-related costs. My election to pursue arbitration does not concede that arbitration is mandatory or exclusive.
I expressly reserve all arguments and objections concerning the existence, validity, formation, assent, notice, identity and applicable version, applicability, scope, interpretation, and enforceability of any arbitration or related dispute-resolution terms Cars.com may invoke. These reservations include any term concerning pre-dispute notice, informal resolution, cure, waiting periods, or other conditions precedent; contractual deadlines or limitations periods; governing law, forum, venue, administrator or arbitrator selection, arbitral rules, or delegation; confidentiality; individual-only, consolidated, coordinated, batched, bellwether, or mass-filing procedures; fees, deposits, costs, or fee shifting; waivers or restrictions on claims, procedures, remedies, or relief; and amendments or modifications. I also reserve all arguments that any such requirement was satisfied, substantially complied with, waived or forfeited by Cars.com, excused, inapplicable, or unenforceable. Nothing in this Notice waives any claim, remedy, objection, defense, or right to proceed in any otherwise available forum.
I authorize Cars.com to communicate with my counsel identified below regarding this dispute and to produce to them all records and information associated with me that are reasonably necessary to evaluate and resolve this dispute.
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. If Cars.com 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.
Please direct all communications concerning this dispute to my counsel identified below.
Sincerely,