LifeLock 2015 Annual Report Download - page 285

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 127 of 289
regularly fail to notify customers of new account openings, auto loans, and/or wireless account activity. In reality, it simply does not provide the promised
“comprehensive” protection that it purports other banks and credit companies cannot offer.
86. Moreover, LifeLock’s use of such statistics fails to inform consumers that LifeLock does not protect against tax and wage-related fraud, which
the FTC listed as the most common type of identity theft in 2012. See https://www.truthinadvertising.org/lifelocksprotection-leaves-much-to-be-desired/.
87. LifeLock is able to further perpetuate its commercial deception and mask the true scope of its network through use of false and/or misleading
testimonials. These testimonials are used to aid in the appearance of legitimacy; however, they falsely and misleading present the scope and effectiveness of
LifeLock’s services.
88. For example, a testimonial from Gene Z. on LifeLock’s website states that Gene Z. was contacted by a company that sold large computer
equipment and asked if he had purchased a computer, which he had not. Gene Z. states that while he was in the process of looking up his credit card
information, he received a call from LifeLock informing him that someone had tried to use his social security number to open a phone account. Gene Z.
further states that he informed LifeLock of the potential credit card fraud and asked LifeLock what he needed to do. Gene Z. states that LifeLock told him
“Don’t worry, we’ll take care of everything.” First, this testimonial falsely and/or misleadingly conveys the message that LifeLock protects against any and
all credit card fraud, which it does not. Second, this testimonial falsely and/or misleadingly conveys the message that LifeLock handles every aspect of a
customer’s ordeal while the customer has zero responsibility to take any action. In reality, LifeLock mandates a list of exclusions and preconditions that
substantially limit the applicability of LifeLock’s services and its $1 Million Total Service Guarantee. Third, this testimonial falsely and/or misleadingly
conveys the message that LifeLock’s services will prevent identity theft, a representation that LifeLock cannot guarantee.
89. Similarly, a second testimonial from Justin L., also on LifeLock’s website, recounts how Justin L. was contacted by several credit card companies
to verify credit
1279432.1 - 21 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258