LifeLock 2015 Annual Report Download - page 292

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 134 of 289
accord with Plaintiff Ebarle’s understanding, he submitted his, his wife’s, and his children’s personal information to LifeLock.
117. In or around August of 2014, Plaintiff Ebarle opened a Discover account; however, Plaintiff Ebarle did not receive an alert from LifeLock in
connection with this new account opening.
118. Similarly, in or around October 2014, Plaintiff Ebarle opened a new account with US bank and Wells Fargo. Yet again, however, Plaintiff Ebarle
did not receive any notifications from LifeLock in connection with these account openings.
119. In comparison to LifeLock’s inability and/or failure to detect and report these activities, each of the three (3) instances described above was
detected and reported to Plaintiff Ebarle through his alternative account with Protect My ID, a LifeLock competitor.
120. Consequently, it is clear that Plaintiff Ebarle did not receive the services and/or support promised by LifeLock and paid for by Plaintiff Ebarle,
and that LifeLock does not provide the superior “comprehensive” services promised.
121. Additionally, during the period from March through December 2014, while Plaintiff Ebarle received approximately six alerts pertaining to his
wife’s personal information from Protect My ID, he did not receive a single alert from LifeLock. Upon contacting LifeLock, Plaintiff Ebarle learned that
despite paying for services for himself and his wife, LifeLock was not servicing the account for his wife, even though Plaintiff Ebarle had been charged for
and paid for these services.
122. Plaintiff Jeanne Stamm subscribed to LifeLock in 2008. Since that time, Plaintiff Stamm has paid LifeLock a fee of $9 per month, or $108 a
year.
123. Based on LifeLock’s advertisements and representations, Plaintiff Stamm understood and/or had the impression that LifeLock would protect
against any attempt to steal her identity or fraudulently procure credit under her name and send her timely alert notifications. Based on her understanding,
Plaintiff Stamm submitted her personal information to LifeLock.
124. At no time relevant hereto was Plaintiff Stamm aware that LifeLock was not permitted to submit fraud alerts on her behalf; that LifeLock’s
consumer alert notification
1279432.1 - 28 - AMENDED CLASS ACTION COMPLAINT
CASE NO. 3:15-CV-258