LifeLock 2015 Annual Report Download - page 270

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 112 of 289
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19. LifeLock markets, offers, and sells the following fee-based membership plans to consumers (collectively referred to as the “Membership Plans”):
LifeLock Standard, LifeLock Advantage, and LifeLock Ultimate Plus.
20. LifeLock Standard purports to offer identity theft detection and alerts within its network, lost wallet protection, address change verification,
black market website surveillance, reduced pre-approved credit card offers, and a $1 million total service guarantee for $9.99/mo.
21. LifeLock Advantage purports to offer LifeLock Standard services plus fictitious identity monitoring, court records scanning, data breach
notifications, credit reports and scores, financial account activity alerts, and a $1 million total service guarantee for $19.99/mo.
22. LifeLock Ultimate Plus protection purports to provide LifeLock Advantage services plus bank account takeover alerts, enhanced credit
application alerts, file-sharing network searches, sex offender registry reports, credit reports and scores, monthly credit score tracking, and a $1 million total
service guarantee for $29.99.
23. As an add-on service, a subscriber of one of these three Membership Plans can enroll in LifeLock Junior, which is marketed and sold as providing
monitoring services for the member’s children’s personal information. LifeLock Junior protection purportedly provides identity theft detection and alert
notifications, credit file detection, black market website surveillance, file-sharing network searches, and a $1 million total service guarantee. According to
LifeLock, “LifeLock Junior – it’s relentless protection for your kids and peace of mind for you.”
24. Each of LifeLock’s Membership Plans is governed by LifeLock’s Service Terms and Conditions, which specifically provide that
These LifeLock Service Terms and Conditions (the “Service Terms”) are a legally binding agreement between LifeLock, Inc. (“LifeLock,” “we”
“our” or “us”) and you (“you,” “your” or “yours”), and describe the terms under which you agree to use the LifeLock identity programs, including
any applicable Stolen Identity Insurance (the “Protection Programs””), credit monitoring service (the “Credit Monitoring Service”) and any other
service or product which may be made available to you by us for which you have registered or enrolled or have been
1279432.1 - 6 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258