LifeLock 2015 Annual Report Download - page 274

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 116 of 289
involved, Sprint and USAA, were not part of LifeLock’s network. See http://www.ktvu.com/news/news/special-reports/industry-leader-identity-theft-
protectionrecently/nWf9P/.
36. Thus, LifeLock’s proclaimed “comprehensive” network that purportedly trolls “a trillion data points” is misleading and/or fails to inform
customers that LifeLock’s services do not cover some of the largest credit card companies and/or businesses, or car loans.
37. In addition to falsely and/or misleadingly representing LifeLock’s diminished network, LifeLock misrepresents the value of its services, many of
which are available for free. For example, LifeLock’s black market website monitoring is essentially worthless. With regard to this service, LifeLock has no
authority or power to prevent personal information from being posted or shared on these websites, and any “threat” is detected after the theft has already
occurred -- not “before it happens.” As such, this service provides limited to zero value to LifeLock’s customers, and it misleads LifeLock’s customers about
the quality and characteristics of LifeLock’s services. Indeed, upon information and belief, even if LifeLock sends a “black market” alert, it does not have the
ability to inform customers about the specific information on the website, how it was obtained, or who obtained it, heightening the potential for incorrect
and/or unreliable information from LifeLock in this context.
38. LifeLock also fails to adequately inform its customers that it does not provide 3bureau credit monitoring to subscribers of its Standard package.
Most consumers understand LifeLock’s representations to include this service in each of its Membership Plans. However, this is not the case, and, upon and
information and belief, when consumers call LifeLock to inquire about the disparity between the services advertised and those actually provided by
LifeLock, they are told they must increase their Membership Plan and Membership Fees to be covered, despite the fact that customers can obtain their own
credit data for free.
39. Thus, LifeLock only provides credit monitoring to subscribers of LifeLock’s Ultimate Plan, those paying the highest monthly premium of $30 a
month. However, credit monitoring is an antiquated service that is not very effective, and not worth the heightened premium. Indeed, a 2013 Department of
Justice study found that less than 1% of existing account
1279432.1 - 10 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258