In Nicole M. v. Sears, Roebuck & Co. (1999) 76 Cal.App.4th 1238, the Court of Appeal applied Ann M. v. Pacific Plaza Shopping Center (1993), to a situation in which the plaintiff was the victim of an attempted rape as she traversed the defendant's parking lot at night. She claimed the defendant could have prevented the sexual assault by providing better lighting and landscaping. There had been no prior sexual assaults at the location. The trial court granted the defendant's motion for summary judgment. On appeal, the plaintiff attempted to avoid the force of Ann M. by arguing a showing of prior similar incidents was necessary only if the negligence claim was based upon the failure to provide security guards but that a showing of prior similar incidents was not necessary when, as in her case, she simply sought lesser security measures such as more lighting and the trimming of bushes. The Court of Appeal rejected that argument. It reiterated that "the predicate of any duty to prevent criminal conduct is its foreseeability. Property owners have no duty to prevent unexpected and random crimes." ( Nicole M., supra, 76 Cal.App.4th at p. 1247.) It concluded "that the low lighting and overgrown bushes alone did not make the property inherently dangerous and further that these circumstances were not cause for the property owner to reasonably anticipate crime in the absence of prior similar incidents." ( Id. at p. 1248.)