PARKER v. BARCLAYS BANK DELAWARE

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 29, 2025
Docket2:25-cv-02217
StatusUnknown

This text of PARKER v. BARCLAYS BANK DELAWARE (PARKER v. BARCLAYS BANK DELAWARE) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PARKER v. BARCLAYS BANK DELAWARE, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA JEFFREY PARKER, on behalf of himself and all others similarly situated, Plaintiffs, CIVIL ACTION NO. 25-2217 v. BARCLAYS BANK DELAWARE, Defendant. Pappert, J. September 29, 2025 MEMORANDUM Jeffrey Parker brings a putative class action against Barclays Bank Delaware, alleging negligence, unjust enrichment, breach of confidence, and violations of the Pennsylvania Wiretapping and Electronic Surveillance Control Act, the Pennsylvania Unfair Trade Practices and Consumer Protection Law, unfair and deceptive trade practices statutes in six other states, and the Electronic Communications Privacy Act. Barclays moves to dismiss for lack of personal jurisdiction and failure to state claims upon which relief can be granted. Because the Court lacks personal jurisdiction over Barclays, the Court grants Barclays’s motion on that basis and dismisses his claims without prejudice. I Barclays operates a website, https://cards.barclaycardus.com/, where consumers can apply for credit cards and other financial products. (Am. Compl. ¶ 2, Dkt. No. 16.)

Barclays’s website uses cookies, known as Adobe Tracking Pixels, to monitor a consumer’s online activities. See (Id. ¶ 11, 13, 29–31). Barclays transmits that data to third parties like Adobe, which use that information for “marketing and other pecuniary purposes.” (Id. ¶ 21.) Specifically, Barclays collects and discloses a consumer’s email address, the webpage they visited, their interactions with its website, and other “unique identifiers” like their “geographic location” and “device

specifications.” (Id. ¶¶ 17, 30–31.) Parker applied from Pennsylvania for a Barclays credit card through its website. (Id. ¶ 13.) After Parker entered his “personal and financial information,” Barclays denied his application. (Id.) During this process, Barclays purportedly “deployed” Pixels to Parker’s computer, “causing [his] device to contemporaneously in real time and invisibly re-direct [his] personally identifiable guest records and communications to third parties like Adobe.” (Id. ¶¶ 11, 22.) Soon after, Parker noticed targeted advertisements from Barclays related to financial products and services, “including Facebook advertisements for Barclays credit cards but also for other credit cards too.”

(Id. ¶ 13). Barclays acted without Parker’s knowledge or consent. (Id.) Had Parker known what Barclays would do, he would have applied for a credit card with another bank. (Id.) II A To withstand a motion to dismiss under Federal Rule of Civil Procedure 12(b)(2), “a plaintiff bears the burden of establishing the court’s jurisdiction over the moving defendants.” Miller Yacht Sales, Inc. v. Smith, 384 F.3d 93, 97 (3d Cir. 2004). Such a motion “is inherently a matter which requires resolution of factual issues outside the pleadings, i.e., whether in personam jurisdiction actually lies.” Time Share Vacation Club v. Atl. Resorts, Ltd., 735 F.2d 61, 66 n.9 (3d Cir. 1984). But “when the court does not hold an evidentiary hearing on the motion to dismiss, the plaintiff need only establish a prima facie case of personal jurisdiction and the plaintiff is entitled to have its allegations taken as true and all factual disputes drawn in its favor.” Miller Yacht,

384 F.3d at 97. Still, a plaintiff must prove personal jurisdiction by a preponderance of the evidence. Carteret Sav. Bank, FA v. Shushan, 954 F.2d 141, 146 (3d Cir. 1992). Once the defense has been raised, “the plaintiff must sustain its burden of proof in establishing jurisdictional facts through sworn affidavits or other competent evidence” and may not “rely on the bare pleadings alone.” Patterson v. FBI, 893 F.2d 595, 603–04 (3d Cir. 1990) (quoting Time Share, 735 F.2d at 67 n.9). Indeed, the “plaintiff must respond with actual proofs, not mere allegations.” Id. B Courts sitting in diversity apply the law of the forum state to determine whether

jurisdiction is proper. See Metcalfe v. Renaissance Marine, Inc., 566 F.3d 324, 330 (3d Cir. 2009). Pennsylvania's long-arm statute permits personal jurisdiction “based on the most minimum contact with th[e] Commonwealth allowed under the Constitution of the United States.” See 42 Pa. Cons. Stat. Ann. § 5322(b); see also Mellon Bank (E.) PSFS, Nat’l Ass’n v. Farino, 960 F.2d 1217, 1221 (3d Cir. 1992) (“The Pennsylvania statute permits the courts of that state to exercise personal jurisdiction over nonresident defendants to the constitutional limits of the Due Process Clause of the Fourteenth Amendment.” (citation modified)). Personal jurisdiction can be general or specific. Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351, 352 (2021). Barclays is not subject to general jurisdiction in Pennsylvania because Parker never establishes that Barclays is incorporated or has its principal place of business here. See Daimler AG v. Bauman, 571 U.S. 117, 137 (2014) (“With respect to a corporation, the place of incorporation and principal place of business are paradigm bases for general jurisdiction.” (citation modified)).

III Specific jurisdiction exists when the “plaintiff’s cause of action is related to or arises out of the defendant’s contacts with the forum.” Pinker v. Roche Holdings Ltd., 292 F.3d 361, 368 (3d Cir. 2002). The Supreme Court “has articulated two tests for specific jurisdiction: (1) the ‘traditional’ test—also called the ‘minimum contacts’ or purposeful availment test . . . and (2) the ‘effects’ test.” Hasson v. FullStory, Inc., 114 F.4th 181, 186 (3d Cir. 2024) (first quoting Int’l Shoe Co. v. State of Wash., Off. of Unemployment Comp. & Placement, 326 U.S. 310, 316 (1945); then quoting Calder v. Jones, 465 U.S. 783, 787 & n.6 (1984)). These tests, though similar, “have distinct

requirements,” and courts assess specific jurisdiction under both. See id. at 189. A The traditional test has three elements. First, the plaintiff must show that the defendant has “minimum contacts” with the forum such that it “purposefully avail[ed] itself of the privilege of conducting activities within the forum” and “invok[ed] the benefits and protections of [the forum’s] laws.” Id. at 186 (alterations in original) (quoting Asahi Metal Indus. Co. v. Superior Ct. of Calif., 480 U.S. 102, 109 (1987)). Second, the plaintiff’s claims “must ‘arise out of or relate to’ at least some of the defendant’s contacts,” “evidencing a strong relationship among the defendant, the forum, and the litigation.” Id. (quoting Ford Motor, 592 U.S. at 365). And third, exercising jurisdiction over the defendant must “comport[] with traditional notions of fair play and substantial justice” such that “the defendant ‘should reasonably anticipate being haled into court’ in that forum.” Id. (alteration in original) (quoting World-Wide Volkswagen Corp. v.

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Bluebook (online)
PARKER v. BARCLAYS BANK DELAWARE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-barclays-bank-delaware-paed-2025.