LifeLock 2015 Annual Report Download - page 281

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 123 of 289
63. Moreover, the Consumer Product Advisor reports that LifeLock’s products and services are marketed in a confusing and convoluted way,
masking their limitations, exclusions, and restrictions, and making it impossible for consumers to knowingly determine what these products cover and
whether they provide a worthwhile benefit.
64. LifeLock is able to perpetuate its maze-like services through use of its “affiliates.” As part of its marketing campaign, LifeLock uses an affiliate
program whereby people and/or businesses create websites and blogs that link to LifeLock.com. The affiliates receive a commission on each enrollment
generated from their site or review. Thus, LifeLock’s affiliates are incentivized to perpetuate LifeLock’s advertising and marketing scheme and mislead
consumers.
65. Moreover, even though the FTC Order requires LifeLock to distribute a copy of the FTC Order to LifeLock’s affiliates, upon information and
belief, LifeLock fails to provide its affiliates a copy of the FTC Order. Failure to do so is itself a violation of the FTC Order.
66. In addition, upon information and belief, LifeLock fails to adequately inform its members that the Company only runs a credit report once a year
and that the Sex Offender list maintained by LifeLock is not updated on a daily or weekly basis.
67. Upon further information and belief, Defendant’s customer service representatives employ an array of deceptive tactics to thwart members’
ability to cancel their Membership Plans, such as putting customers on hold for lengthy amounts of time, citing misleading identity theft statistics, and
telling consumers that without LifeLock’s services their identity will be stolen.
68. Indeed, various customer complaints posted on www.consumeraffairs.com/privacy/lifelock.html report that LifeLock does not timely respond to
cancellation requests and/or uses scare tactics to bully or mislead customers into believing that they are unsafe without LifeLock. Moreover, customers report
that even after canceling their accounts, or at least a portion thereof, they continued to be billed by LifeLock for the canceled services.
69. In sum, LifeLock’s marketing and sales representations misrepresent that Defendant’s services have many hidden, variable, and narrow
restrictions; that Defendant’s alert
1279432.1 - 17 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258