On December 19, 2008, in Party City Corp. v. The Superior Court of San Diego County, the California Court of Appeal in the Fourth Appellate District held that zip codes are not “personal identification information” under California’s Song-Beverly Credit Card Act of 1971, California Civil Code Sec. 1747.08 (the “Act.”). The Act prohibits a retailer that accepts credit cards from, among other things, “request[ing], or require[ing] as a condition to accepting the credit card as payment in full or in part for goods or services, the cardholder to provide personal identification information, which the [retailer] writes, causes to be written, or otherwise records upon the credit card transaction form or otherwise.” Id. at § 1748.08(a)(2). Under the Act, “personal identification information” is “information concerning the cardholder, other than information set forth on the credit card, and including, but not limited to, the cardholder’s address and telephone number.” Id. at § 1747.08(b). Subdivision (e) of the statute provides that “[a]ny person who violates this section shall be subject to a civil penalty not to exceed two hundred fifty dollars ($250) for the first violation and one thousand dollars ($1,000) for each subsequent violation, to be assessed and collected in a civil action brought by the person paying with a credit card, by the Attorney General, or by the district attorney or city attorney of the county or city in which the violation occurred.”