The wave of litigation targeting Apple over its AirTag tracking devices is a useful case study for any company that manufactures or sells a product that could conceivably be misused by a bad actor. In a case pending in the U.S. District Court for the Middle District of Florida, a “Jane Doe” plaintiff alleges that a former romantic partner used AirTags to track her on at least three occasions in 2025 by concealing devices inside a suitcase and tablet, which were ultimately used to locate and take their daughter in violation of a custody order. The plaintiff alleges negligence, strict liability, invasion of privacy, and a violation of Florida’s Deceptive and Unfair Trade Practices Act. In
August 2026, U.S. District Judge Marcia Morales Howard struck the complaint as an impermissible “shotgun pleading” and directed the plaintiff to file a corrected version. However, the underlying theories of liability remain at issue and are illustrative of a broader trend among plaintiffs seeking to hold manufacturers responsible for the deliberate criminal conduct of third parties.