In a recent ruling arising from certain certified questions in Tyler v. Michaels Stores, Inc., Civ. No. 11-10920-WGY (D. Mass. Jan. 6, 2012, the Massachusetts Supreme Court interpreted “personal identification information” under Mass. Gen. Laws, ch. 93, § 105(a) Section 105(a) to include a consumer’s ZIP code and determined that collecting such personal information is a violation of state privacy law for which the consumer can sue (see slip opinion).