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The company, Ringleader Digital, uses HTML5's client-side database storage capability as a substitute for the traditional cookie tracking employed by all major online ad companies.
Mobile Safari users visiting sites with Ringleader ads are assigned a globally unique ID number which is stored by the browser, and recalled by Ringleader whenever they revisit.
But the tracker, labeled RLDGUID, does not go away when one clears cookies from the browser...
This action follows a similar July lawsuit against MTV and five other companies [wired.com] for using Adobe's Flash player storage to recreate deleted cookies. Such actions allegedly violate the US computer intrusion law.