A California state Court of Appeals recently held that zip codes do not qualify as "personal identification information" under the Song-Beverly Credit Card Act of 1971, Cal. Civil Code § 1747, which prohibits businesses from requesting or requiring consumers to disclose "personal identification information" in order to complete a credit card transaction. See Party City Corporation v. Superior Court of San Diego County, No. D053530 (Cal. Ct. App. Dec. 19, 2008).  

In September 2007, plaintiff Rebecca Palmer filed a putative class action suit against Party City Corp. for allegedly violating the statute when a cashier requested her zip code before completing her credit card transaction.  

In granting Party City's summary judgment motion, the court held that zip codes are a "group identifier" and are neither specific nor personalized (unlike telephone numbers and addresses). As such, zip codes do not fall within the category of information protected by the statute.