Brown (groin) is considered day-to-day after being injured in Thursday night's loss to the Rams, Lindsey Pallares of the 49ers' official site reports.
Brown gets an extended break ahead of the 49ers' Week 16 game against the Dolphins, so his practice participation level will be monitored next week. Tashaun Gipson replaced Brown against Los Angeles and would be in line for an increased role if Brown is unable to play next week.