VIA CERTIFIED MAIL—RETURN RECEIPT REQUESTED
URBN Legal Department
5000 South Broad St
Philadelphia, PA 19112
Attn: General Counsel
Re: Notice of Individual Dispute Concerning TikTok-Related Tracking on Anthropologie.com
To Whom It May Concern:
I am sending this Notice of Dispute to notify Urban Outfitters, Inc., its subsidiary, URBN US Retail LLC d/b/a Anthropologie and their corporate affiliates, individually or collectively referred to here as “Anthropologie,” of a dispute regarding my use of Anthropologie.com and Anthropologie’s use of tracking technology on that website, including TikTok-related tracking technology, code, or related processes, to capture, record, decode, or transmit information about my electronic communications and website interactions without valid prior authorization.
Nature and Basis of the Dispute
I personally used Anthropologie.com while I was physically located in California. I used Anthropologie.com to {typeA161}, or engage in other shopping- or account-related activity. To the best of my recollection, this occurred on or about the {pleaseComplete} before this Notice.
When I used Anthropologie.com, I understood that I was communicating and interacting with Anthropologie for ordinary shopping, account, or purchasing purposes. I did not know or understand that information associated with my communications and interactions with Anthropologie would be captured, recorded, decoded, transmitted, or otherwise processed through TikTok-related tracking technology in the manner described below.
Based on my current understanding and counsel’s investigation, Anthropologie.com set or caused to be set TikTok-related tracking technology during website sessions, including TikTok pixel resources, the _ttp cookie, and associated browser-side scripts, network requests, tag-management processes, and related software processes (collectively, the “TikTok Tracking Tools”). Counsel’s testing reflected TikTok-related requests initiated through Anthropologie/URBN tag-management infrastructure, including Tealium-related scripts. Those tools generated or caused browser-side requests to TikTok-related endpoints that reflected information associated with website sessions and user activity. Upon information and belief, the TikTok Tracking Tools loaded during my Anthropologie.com sessions and generated or caused requests reflecting information associated with my activity on the website, including pages viewed, category and collection pages viewed, products viewed, product selections, and cart or add-to-cart activity, as applicable. The information transmitted, generated, reflected, or included non-content routing, addressing, signaling, source-identifying, browser-identifying, device-identifying, session-identifying, event-identifying, and related tracking information associated with my interactions with Anthropologie.com—e.g., page URLs, referrer information, pageview and event information, click-event information, timestamps, IP-address information, browser and device information, user-agent information, persistent identifiers, cookies including _ttp, TikTok session-related identifiers, and product/cart-related event parameters. This information matters because it was tied to the context and purpose of my Anthropologie.com activity and interactions—including categories, collections, and products viewed, product interests, product selections, and cart or add-to-cart activity, as applicable—not merely to a generic visit to a public webpage. Taken together, these identifiers, event signals, and contextual data points could be used by Anthropologie, TikTok, and other recipients to link my Anthropologie.com activity to my browser, device, session, location, shopping activity, product interests, product selections, cart activity, or related activity over time. As a result, I lost control over my Anthropologie.com activity and tracking data and was deprived of the ability to make an informed privacy choice.
I contend that this conduct violated Cal. Penal Code § 638.51 because Anthropologie installed, used, or caused the use of a pen register or trap-and-trace device, process, or functionality to capture, record, decode, or transmit non-content dialing, routing, addressing, signaling, source-identifying, device-identifying, URL/referrer, product/content-view, cart-related, checkout-related, event, cookie, IP, user-agent, persistent identifier, hashed matching-related, session, pageview, or similar information about my electronic communications and activity with Anthropologie.com without first obtaining a court order and without my valid consent or other lawful authorization.
I also preserve related claims and theories under Cal. Penal Code § 631 and the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510–2523, to the extent the facts show that Anthropologie or any third party intercepted, read, attempted to read, learned, used, disclosed, or aided the interception or use of the contents or substance of my communications with Anthropologie.com without valid consent. I do not waive any other statutory, common-law, contract, privacy-policy, consumer-protection, equitable, or related theory that may be supported by the facts and law.
I did not knowingly authorize Anthropologie to use, enable, or cause the operation of TikTok-related tracking technology to capture, record, decode, transmit, or otherwise process my data in the manner described above. To the extent Anthropologie contends that its terms of use, privacy policy, cookie policy, or other disclosures provided authorization for the challenged conduct, I dispute that contention. More specifically, I dispute that generalized disclosures concerning cookies, analytics, advertising, service providers, targeted advertising, website measurement, data sharing, or similar practices provided clear, prior, specific, informed, and valid authorization for the challenged TikTok-related tracking activity described in this Notice. Consent is especially lacking to the extent the challenged tracking technology loaded or operated before I had a meaningful opportunity to make a privacy choice, operated despite a rejection of non-essential advertising or analytics technologies or continued after an opt-out request or similar privacy preference signal.
I am not aware of any court order, judicial authorization, statutory authorization, or other lawful authority permitting Anthropologie, TikTok, or any related vendor to install, use, or operate the challenged tracking technology in connection with my communications and interactions with Anthropologie.com.
Relief Sought
I seek all relief available under applicable law and any applicable agreement, including statutory damages where available; restitutionary relief and disgorgement; injunctive and equitable relief requiring Anthropologie to cease the challenged tracking practices unless and until it obtains valid consent and complies with applicable law; deletion, non-use, or de-identification of data derived from the challenged tracking practices; preservation and disclosure of records; attorneys’ fees, arbitration fees, costs, and any additional relief available under law, contract, arbitration rules, or equity.
My current good-faith demand is $5,000, subject to supplementation after Anthropologie provides records sufficient to evaluate the full amount of statutory, actual, equitable, and other relief owed. Because the number, timing, nature, and scope of any violations depend on records presently within Anthropologie’s possession, custody, or control, as well as records maintained by third-party vendors and service providers, I reserve the right to supplement my damages calculation and requested relief after those records become available.
I request that Anthropologie preserve all records and ESI relating to this dispute, including data, logs, code, configurations, communications, contracts, and materials in Anthropologie’s possession, custody, or control or reasonably accessible through its vendors, service providers, contractors, or agents. Anthropologie should suspend any routine deletion, overwriting, rotation, or destruction process that could affect records relevant to my interactions, the challenged tracking, the data collected or transmitted, relief, or resolution. I authorize Anthropologie to communicate with my counsel identified below regarding this dispute and to produce to them all records and information concerning my account or associated with my use of Anthropologie.com that are reasonably necessary to evaluate and resolve this dispute.
Informal Resolution
I am providing this Notice in good faith before initiating formal proceedings in order to afford Anthropologie an opportunity to discuss an informal resolution of my dispute. Please confirm receipt of this Notice and contact my counsel within 14 business days. If Anthropologie believes that additional information is required to evaluate or resolve this dispute, please identify the specific information requested and the contractual or legal basis for the request.
Without conceding that any 60-day period is contractually required, enforceable, or necessary to satisfy any condition precedent, I am willing to allow 60 days after Anthropologie receives this Notice for informal resolution discussions. If the dispute is not resolved within that period, I intend to pursue my rights in any available forum and through any available procedure, including through individual arbitration before JAMS. See Anthropologie, Dispute Resolution Procedure (last updated June 17, 2026).
In doing so, I expressly reserve all arguments and objections to the validity, enforceability, applicability, interpretation, effect, or satisfaction of any Anthropologie arbitration, waiver, limitation, forum, governing-law, mass-arbitration, public-injunction, unilateral-modification, informal-resolution, condition-precedent, or dispute-resolution provision, including objections concerning formation, assent, notice, scope, delegation, unconscionability, waiver, fees, costs, limitations periods, venue, arbitral rules, public injunctive relief, representative relief, and consistency with applicable law. I also reject, and do not consent to, any unilateral modification of Anthropologie’s terms, privacy policy, or any other purportedly applicable terms unless I affirmatively agree in a separate signed writing.
This Notice is not a complete statement of all facts, claims, legal theories, damages, remedies, defenses, objections, responses, or grounds. I reserve the right to amend, supplement, refine, narrow, expand, or otherwise modify this Notice and my requested relief based upon additional investigation, records, technical analysis, discovery, expert review, arbitration proceedings, litigation proceedings, or other information.
Please direct all communications concerning this dispute to my counsel identified below.
Sincerely,