LifeLock 2015 Annual Report Download - page 288

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 130 of 289
• Any loss arising from pollution;
• Any loss arising from radioactive Contamination;
• Any loss arising from contract frustration business;
• Any loss arising from failure to or delay in delivery or supply of any form of property whatsoever;
• Any loss arising from any form of financial guarantee, surety, or credit indemnity;
• Any loss arising from fraudulent withdrawals by immediate family members;
• Any loss not reported within 90 days;
• Any loss arising from any business activity;
• Any loss resulting from or arising out of the destruction, confiscation, or seizure by order of any government of public authority; and
• Any loss arising from a voluntary disclosure of any code or other security information.
In addition, the Master Policy has an exhaustive list of conditions precedent. These limitations and restrictions prevent consumers from being able to
decipher what is covered and what is not and/or the true value of the Master Policy.
99. The second component, the service guarantee, is described by LifeLock as follows: “If you become a victim of identity theft while you are a
LifeLock member we will spend up to $1 million to hire experts, lawyers, investigators, consultants, and whoever else it takes to help your recovery.” Thus,
the service guarantee is supposed to cover legal costs, remediation, service costs, and case management costs in the event of an identity theft.
100. However, LifeLock’s service guarantee is limited by the Master Policy, which provides as follows:
Remediation Service Cost. The amount of reasonable and necessary expenses paid to investigators and other third-party business providers who are
retained by LifeLock and provide any services that are reasonably necessary, 
 to restore the good name and identity of the Insured, or to recover Losses of the Insured in accordance with any Membership Program.
(emphasis added)
Consequently, because the service guarantee is given in the context of “LifeLock’s business and
1279432.1 - 24 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258