📆 August 13, 2026
Zillow Group Legal Department Responds to Ms. Englert
Source: 📧 Zillow Group Legal Department — Response to Data Delivery Demand Specifications
Zillow Reasserts Jean Scott Homes’ Data is Deleted
Zillow Group Legal Department states that it complied with Jean Scott Homes’ deletion demand and confirmed that all data had been deleted. It further argues that Jean Scott Homes ordered the destruction of its data. For that reason, Zillow concludes that it is not liable for allegations made in the draft complaint.
Zillow Group Legal Department declines Jean Scott Homes’ demands. It asserts that the draft complaint is meritless and that a pleading would be frivolous, and it threatens sanctions.
Except as Required by Law
The Zillow Group Legal Department misrepresents the contents of my Nov. 16, 2025, email. I assert Jean Scott Homes’ ownership of its IP and bar any license to use it. I ask Zillow to confirm in writing that deleted data will not be “processed, analyzed, retained, or used in any system” or spread across Zillow Group, “except as required by law.”
Source: 📧 Custodial Notice — Zillow CEO Jeremy Wacksman and Follow Up Boss Co-Founder Dan Corkill — Nov. 16, 2025 (on file)
Zillow Cites Customers’ Responsibility to Download Their Own Data
Zillow Group Legal Department cites the Follow Up Boss Terms of Service account-termination clause. It places the burden on customers to download their own data before closing an account.
The Customers’ Download is a Damaged Contact List
The Follow Up Boss 2-click, in-full download is a damaged contact list and not a backup of Jean Scott Homes’ data. I cover this fact in Chapter 6.
I had spent most of the four weeks prior to Nov. 15, 2025, attempting to download Jean Scott Homes’ data. A complete download is impossible. I cover the facts in Chapter 6, Chapter 7, and Chapter 8.
Four Weeks in Perspective
I have a ZIP file archive that contains the IP I was able to recover plus related log files. It is 2.07 GB. The entire file downloads from Apple’s iCloud in less than 60 seconds with one click on the iCloud icon in Finder.
Speedtest.net clocked my download speed at about 500 Mbps. Jean Scott Homes’ full dataset, including call recordings, images, and PDFs, should download in about 15 minutes.
The national median download speed, according to Speedtest.net, is about 300 Mbps. At that speed, the downloads would clock in at about a minute and 40 seconds and 25 minutes, respectively.
The Time Machine Problem Revisited
6.5 Deidentified or Aggregated Data
You agree that both before and after the term of the Terms, Zillow may collect, analyze, use, and retain Customer Data you submit or make available to the Services that does not directly or indirectly identify you, your End Customers, or any natural person, for the purpose of operating, analyzing, improving or marketing the Services, developing new products or services, including to perform AI/ML Activities, or for other purposes.
The Nov. 15, 2025, effective date for these policies and terms was meaningless. Under Section 6.5, Zillow granted itself retroactive permission to collect, analyze, use, and retain Jean Scott Homes’ IP, once stripped of anything that identifies a person, before the Terms even took effect. I could not find a date that indicates how far back this provision reaches. For all time is the only conclusion that I can come to.
Source: 📥 Follow Up Boss Terms of Service — Captured March 22, 2026
Source: 💁🏻♀️ Follow Up Boss Terms of Service — Section 6.5 Deidentified Data — Captured March 22, 2026
Zillow Group Legal Department Threatens Sanctions
For those reasons and myriad others, your draft complaint is frivolous. If JSH insists on moving forward with filing a claim, Zillow will vigorously defend itself, including seeking fees and sanctions pursuant to Fla. Stat. sec. 57.105, and as permitted by law.
Florida Statute Chapter 57: Court Costs
57.105 Attorney’s fee; sanctions for raising unsupported claims or defenses; exceptions; service of motions; damages for delay of litigation.—
Source: 🛜 Florida Statute 57.105 — Attorney’s Fee; Sanctions for Raising Unsupported Claims or Defenses
Zillow’s usurpation of consumer privacy and Jean Scott Homes’ IP is unrelenting.
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