Bradshaw et al. v. Lowe's Companies, Inc. and Lowes Home Centers, LLC

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: October 4, 2026

Docket / citation: 25cv0742 DMS (MMP) · Filed: 2025-11-12

Summary

The Southern District of California granted in part and denied in part Defendants’ motion to dismiss in a case alleging use of TikTok and Microsoft trackers on lowes.com. The court dismissed Lowe’s Companies for lack of personal jurisdiction and found the pleadings lacked Article III standing, but rejected other dismissal arguments and granted leave to amend with a deadline of November 19, 2025.

Litigation Status

Status, direction, and weight describe how tracked public sources characterize this matter as of our last review — they are informational classifications, not legal assessments.

Procedural Posture

Defendants moved to dismiss the First Amended Complaint raising personal jurisdiction, Article III standing, and various merits arguments under the California Invasion of Privacy Act (CIPA); the court issued an order granting in part and denying in part the motion and granted Plaintiffs leave to amend.

Reported Holding

The court granted in part and denied in part Defendants’ motion to dismiss. It granted dismissal of Lowe’s Companies for lack of personal jurisdiction and granted dismissal for lack of Article III standing, but rejected the remainder of Defendants’ arguments. Plaintiffs were granted leave to file a Second Amended Complaint by November 19, 2025.

What the Court Decided

The court concluded it lacked personal jurisdiction over Lowe’s Companies and found the case, as pleaded, lacked Article III standing; it denied Defendants’ other dismissal arguments and allowed Plaintiffs leave to amend.

What the Court Did Not Decide

The court did not resolve the merits of Plaintiffs’ underlying CIPA-based substantive claims on the merits; resolution was limited to pleading-stage defects, personal jurisdiction, and standing issues.

Significance

Generally viewed as defense-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.

What This Page Does and Does Not Say

This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.

Technologies at Issue

• TikTok Pixel
• Microsoft/Bing tracker (bat.bing cookie)
• browser/device fingerprinting
• web pixels/cookies

Third parties named or identified in tracked sources: TikTok, Microsoft, Lowe's.

Statutes Invoked

• Cal. Penal Code §§ 638.50, 638.51

Claims Asserted

Claims identified in tracked public sources; pleadings may include additional or amended claims.

• California Invasion of Privacy Act (CIPA) — Cal. Penal Code §§ 638.50, 638.51 (pen register / trap and trace)
• Article III standing (constitutional standing)
• personal jurisdiction challenge

What This Matter May Mean for Website Operators

For operators using similar technologies, the recurring factual questions in matters like this one are whether advertising pixels transmit page URLs or hashed form data before a consent choice. Our scanner tests these behaviors empirically.

Because this matter is pending, anything reported here is procedural — allegations and interim rulings, not final determinations.

Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.

Related Intelligence

Sources

• ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ MOTION TO DISMISS (Bradshaw et al. v. Lowe's) — U.S. District Court (S.D. Cal.) / Justia · Tier A (Primary authority) · 2025-11-12

About This Page

Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.

How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.

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