LifeLock 2015 Annual Report Download - page 272

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 114 of 289
2. that such product, service, or program prevents unauthorized changes to customers’ address information;
3. that such product, service, or program constantly monitors activity on each of its customers’ consumer reports;
4. that such product, service, or program ensures that a customer will always receive a phone call from a potential creditor before a
new credit account is opened in the customer’s name;
5. the means, methods, procedures, effects, effectiveness, coverage, or scope of such product, service, or program;
6. the risk of identity theft to consumers;
7. whether a particular consumer has become or is likely to become a victim of identity theft; and/or
8. the opinions, beliefs, findings, or experiences of an individual or group of consumers related in any way to any such product,
service, or program.
Such products, services, or programs include, but are not limited to, the placement of fraud alerts on behalf of consumers, searching the
internet for consumers’ personal data, monitoring commercial transactions for consumers’ personal data, identity theft protection for minors,
and guarantees of any such product, services, or programs.
B. misrepresenting in any manner, expressly or by implication, the manner or extent to which they maintain and protect the privacy,
confidentiality, or security of any personal information collected from or about consumers.
29. Despite the permanent injunction, LifeLock has continued to market and sell its products using the same and/or substantially similar marketing
ploys, promising customers “comprehensive” and “relentless” protection.
30. Despite promising “comprehensive” protection, LifeLock’s network only provides limited protection against only some forms of identity theft.
31. To begin with, LifeLock makes misleading declarations, via its advertisements and website, that “[e]nrollment takes just minutes and our 24/7
identity theft protection starts immediately.” In truth, however and as buried in the fine print in LifeLock’s Service Terms it can take up to four (4) weeks from
the date of a customer’s acceptance of the Service Terms to complete the enrollment process and for all services to be fully activated. As such, LifeLock’s
claims of “immediate” protection do not adequately portray the enrollment process or the scope and effectiveness of LifeLock’s services and/or operations.
1279432.1 - 8 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258