Kiloh Smith’s appeal against Target Corporation was dismissed by the Arizona Court of Appeals. Smith alleged that Target violated Arizona’s Telephone, Utility and Communication Service Records Act (TUCSRA) by embedding spy pixels in marketing emails to extract data without consent. The court upheld the superior court’s dismissal, agreeing with prior cases that TUCSRA does not cover information collected through marketing emails. Smith’s claims were found not to be protected under TUCSRA as they did not involve records held by communication service providers.
Source: 1CACV250120_Smith_v_Target_Corporation_Opinion_Arizona_Court_of_Appeals.pdf
