LifeLock 2015 Annual Report Download - page 286

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 128 of 289
applications, which he did not in fact apply for. Justin L. further states that whoever was attempting to open these new accounts in his name, also got into his
bank account. Justin L. then states that he signed up for LifeLock and has had no problems since. This testimonial falsely and/or misleadingly leads
consumers to believe that the result a customer can expect after signing up with LifeLock is a complete reduction in identity theft threats, i.e. that LifeLock’s
services will prevent identity theft. Further, this testimonial falsely and/or misleadingly conveys the message that LifeLock’s services provide complete
protection and/or greater protection than credit card companies provide. Also, this testimonial falsely and/or misleadingly conveys the message that when
someone tries to misuse a customer’s information LifeLock automatically kicks in.
90. Another testimonial used by LifeLock, and found at http://www.reviewsonlife.com/life-reviews/life-testimonial.html, states, “As the owner of a
small business my employees are an extension of my family. I looked into LifeLock and immediately paid to sign everyone up.” This testimonial is false
and/or misleading because it conveys the message that LifeLock provides protection for all business activities, when, in fact, it does not. See below.
91. The testimonials described above are unsubstantiated and/or falsely and/or misleadingly overstate the services provided by LifeLock and the
benefits and results achieved by utilizing LifeLock’s services. In truth, LifeLock’s network is extremely limited and is dependent upon the exchange of
electronic information, meaning it does not have the capacity to monitor paper applications. Moreover, the scope, quality, and characteristics of its services
do not provide the protections promised because LifeLock’s safety protocols are not sufficient, LifeLock’s suffers from lack of adequate personnel, and many
of LifeLock’s services are available to a consumer for free.
92. In this same vein, celebrity endorsements from Rush Limbaugh, Rudy Guiliani, Montel Williams, and others falsely and misleadingly convey
the effectiveness of LifeLock’s services. Indeed, each of these paid advertisers give LifeLock customers a false sense of security
1279432.1 - 22 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258