PayPal Secures Fourth Victory in Honey Browser Extension Litigation

PayPal and its subsidiary Honey Science Corp. secured their fourth win in a series of class actions targeting their Honey browser extension when they obtained a dismissal with prejudice of a false advertising class action proceeding in a California federal court on behalf of 6.8 million UK residents.

The victory, which was covered in The Recorder, followed three rounds of motion to dismiss briefing after PayPal already secured dismissals of the first two complaints.

• The plaintiffs in Campbell v. Honey Sci, LLC et al alleged that PayPal misrepresented that the Honey browser extension-a browser extension that individuals use to identify coupon codes or secure rewards for online purchases-would find shoppers the "best" deals. They claimed that Honey partners with merchants in a manner that withholds better deals from shoppers.
• Following multiple rounds of oral argument by Orrick's Rich Jacobsen and Marc Shapiro, the Court on June 15 agreed with PayPal that the plaintiffs failed to state either a claim under California's Unfair Competition Law or an unjust enrichment claim because they in fact received a benefit and they could not connect their proposed remedy-"restitution" of all commissions Honey earned-to what they purportedly lost by virtue of not receiving the "best" discount.
• This win follows a California federal court dismissal without prejudice in November 2025 in Wendover Productions v. PayPal - another Honey lawsuit involving influencers who engage in affiliate marketing - which Rich Jacobsen also argued.

Led by Rich, the Orrick team included Marc Shapiro, Jennifer Keighley, Sarah Ungeheuer and Shalani Maline.