The court of appeals expanded the definition of "address" in Corporations Code §8330(a) to include email addresses for purposes of inspection and copying rights in a case involving timeshares. Worldmark v. Wyndham Resort. The courts have not ruled on whether it applies to common interest developments.

Applicability to HOAs? HOAs are governed by a similar provision in Civil Code §1365.2(a)(1)(I)(1) which allows members to inspect and copy "Membership lists, including name, property address, and mailing address." If an association maintains a membership list with everyone's email address and if the Worldmark decision applies to homeowner associations, boards could be required to provide membership lists that include email addresses to those members who request it (except for those homeowners who opt out of the membership list).

RECOMMENDATION: Because the ruling did not address the statute involving homeowners associations, its applicability to HOAs is in question. Boards should consult legal counsel on how best to respond to an owner's request for emails.