throbber
Case 4:21-cv-03002 Document 1 Filed on 09/15/21 in TXSD Page 1 of 16
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF TEXAS
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`
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`CASE NO.
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`
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`
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`JURY TRIAL DEMANDED
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`
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`JAMARQUIS ETHERIDGE,
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`
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`v.
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`AT&T, INC. AND AT&T MOBILITY, LLC
`
`
`
`
`Plaintiff
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`Defendants.
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`
`
`COMPLAINT
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`Plaintiff Jamarquis Etheridge (“Etheridge”) is an individual and citizen of the State of Texas, by
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`and through his counsel, Richard E. Brown of Richard E. Brown Attorney at Law, PC, complains
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`and alleges based on his personal knowledge with respect to his own acts and on information and
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`belief with respect to all other matters as follows:
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`I.
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`INTRODUCTION
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`1.
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`Plaintiff Etheridge is a current wireless telephone customer of Defendants AT&T,
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`Inc., and AT&T Mobility, LLC (collectively referred to as “AT&T” or “Defendant”). This is an
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`action for damages and remedies for violations of, inter alia, the Federal communications Act,
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`47 U.S.C. § 201, arising in part from AT&T's failure to provide reasonable and appropriate
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`security to maintain the security of and prevent unauthorized access to Plaintiff Etheridge's
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`wireless account.
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`2.
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`On or about September 10, 2020 AT&T improperly allowed wrongdoers access to
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`Plaintiff Etheridge's wireless account and, without his authorization. AT&T was unable to
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`contain this security breach until the next day, enabling wrongdoers to drain Plaintiff Etheridge's
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`cryptocurrency exchange account.
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`db/20-12011/Complaint
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`3.
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`As a result of this breach of security, Plaintiff Etheridge's exchange account was
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`subjected to unauthorized transfers; he was deprived of his use of his cell phone number and
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`required to expend time, energy, and expense to address and resolve this financial disruption and
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`mitigate the consequences; and he also suffered consequent emotion distress.
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`II.
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`JURISDICTION AND VENUE
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`4.
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`This Court has jurisdiction over this matter under 28 U.S.C. §§ 1331 and 1367 on
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`the grounds of federal question jurisdiction and supplemental jurisdiction over the state law
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`claims because all the claims are derived from a common nucleus of operative facts and are such
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`that Plaintiff would ordinarily be expected to try them in one action.
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`5.
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`Venue is proper in this Court under 28 U.S.C. § 1391(b)(2) and (c). A substantial
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`part of the events or omissions giving rise to this Complaint occurred in this District. AT&T is
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`also headquartered and has its principal place of business in this District. Wireless services
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`subject of this Complaint were entered into in part in this District. AT&T has received
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`compensation as a result of its acts and practices in this District.
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`6.
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`The Court has jurisdiction over the lawsuit under 28 U.S.C. §1332(a)(1) because
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`Plaintiff and Defendants are citizens of different U.S. states, and the amount in controversy
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`exceeds $75,000, excluding interest and costs.
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`7.
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`Unless this Court permanently restrains and enjoins AT&T, AT&T will continue
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`to engage in the acts and practices alleged in this Complaint.
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`8.
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`Venue is proper in the Southern District of Texas.
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`III. PARTIES
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`9.
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`Plaintiff Etheridge is an individual and a resident of Harris County, Texas. Since
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`in or about 2009 Plaintiff Etheridge has been an accountholder and subscriber with AT&T.
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`Plaintiff Etheridge entered into the contract with AT&T in Harris County, Texas.
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`db/20-12011/Complaint
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`10.
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`Defendant AT&T, Inc. is a Delaware corporation doing business in Texas and
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`may be served with process by serving its Registered Agent, CT Corporation System at 1999
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`Bryan St., Ste. 900, Dallas, Texas 75201-3136 or wherever it may be found.
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`11.
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`Defendant AT&T Mobility, LLC. is a Delaware limited liability company doing
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`business in Texas and may be served with process by serving its Registered Agent, CT
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`Corporation System at 1999 Bryan St., Ste. 900, Dallas, Texas 75201-3136 or wherever it may be
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`found.
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`12.
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`Plaintiff reserves the right to move the Court to convert and certify this action as a
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`class action on behalf of the yet undefined class of individuals residing within Texas and/or
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`elsewhere who were subjected to the same circumstances set forth here.
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`PRELIMINARY STATEMENT
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`13. This action brought by Plaintiff Etheridge, an AT&T customer who lost hundreds of
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`thousands of dollars in an incident of a rapidly-emerging identity theft crime: “SIM swapping” or
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`“SIM hijacking”.
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`14. A subscriber identity module, widely known as a “SIM card,” stores user data in
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`phones on the Global System for Mobile (GSM) network – the radio network used by AT&T to
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`provide cellular telephone service to its subscribers.
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`15. SIM cards are principally used to authenticate cellphone subscriptions; as without a
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`SIM card, GSM phones are not able to connect to AT&T’s telecommunications network.
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`16. Not only is a SIM card vital to using a phone on the AT&T network, the SIM card
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`also holds immeasurable value as a tool to identify the user of the phone – a power that can be
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`corrupted to steal property and the identity of that user.
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`17. AT&T’s Code of Business Conduct specifically promises that AT&T will “protect
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`the privacy of our customers’ communication” because “[n]ot only do our customers demand
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`this, but the law requires it. Maintaining the confidentiality of communication with AT&T’s
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`duties and obligations under the Federal Communications Act of 1934 and the pertinent
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`implementing regulations.
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`18. Moreover, AT&T was well aware of the pervasive harm posed by SIM swapping,
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`as AT&T has issued public advisories warning customers of the “industry-wide” threat and
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`assuring those customers that AT&T was exercising adequate measures to prevent authorized
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`SIM swapping from happening to its accountholders.
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`19. Notwithstanding AT&T’s knowledge of the prevalence of SIM swapping and its
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`assurance that it was actively protecting its customers, those measures did not adequately protect
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`Plaintiff Etheridge from the harm he suffered.
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`20. As a result of AT&T’s failures if not active participation in SIM swap theft that was
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`inflicted upon him, Plaintiff Etheridge has had over 159.8 ETHEREUM Tokens of assets stolen
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`from him.
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`21. Plaintiff Etheridge seeks compensatory and equitable relief restoring to him 159.8
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`ETHEREUM Tokens that were illegally taken from him as a result of AT&T’s conduct and as
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`alleged herein.
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`22. Since in or about 2009, Plaintiff Etheridge has been an accountholder and
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`subscriber with AT&T.
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`
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`OTHER LIABLE PERSONS/ENTITIES
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`23.
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`In addition to the entity set forth as Defendants herein, there are likely other parties
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`who may well be liable to Plaintiff Etheridge, but respecting whom Plaintiff Etheridge currently
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`lacks specific facts to permit him to name such person or persons as a party-respondent. By not
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`db/20-12011/Complaint
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`naming such persons or entities at this time, Plaintiff Etheridge is not waiving the right to amend
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`this pleading to add such parties, should the facts warrant adding such parties.
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`IV. FACTS
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`24.
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`AT&T markets and sells wireless telephone service through standardized wireless
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`service plans at various retail locations, online sales, and over the telephone. In connection with
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`its wireless services, AT&T maintains wireless accounts enabling its customers to have access to
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`information about the services they purchase from AT&T.
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`25.
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`It is widely recognized that mishandling of customer wireless accounts can
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`facilitate identify theft, related consumer harms, including the theft of third parties of
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`consumers, including Plaintiff Etheridge.
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`26.
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`Among other things, AT&T's sales and marking materials state "we have
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`implemented various policies and measures to ensure that our interactions are with you or those
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`you authorize to interact with us on your behalf – and not with others pretending to be you or
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`claiming a right to access your information."1
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`27.
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`AT&T's sales and marking materials further state that, unless AT&T can verify
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`the caller's identity through certain personal information or a PIN if requested by customer,
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`AT&T's policy is not to release any account specific information.
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`28.
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`Despite these statements and other similar statements, AT&T failed to provide
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`reasonable and appropriate security to prevent unauthorized access to customer accounts. Under
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`AT&T's procedures, an unauthorized person, including AT&T's own agents and employees
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`acting without the customer's permission, can be authenticated and then access and make
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`changes to all the information the legitimate customer could access and make changes to if the
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`customers were so authorized. As set forth in this Complaint, AT&T also fails to disclose or
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`11 Emphasis added.
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`db/20-12011/Complaint
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`discloses misleadingly that its automated processes or human performances often fall short of its
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`express and implied representations or promises.
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`In or about 2009, Plaintiff Etheridge entered into a service agreement with AT&T.
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`This agreement was for service on one (1) wireless telephones, for Plaintiff
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`29.
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`30.
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`Etheridge.
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`31.
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`On or about September 10, 2020, Plaintiff noticed his phone service was not
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`working and immediately called AT&T to find out that his service was compromised.
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`32. Without obtaining Plaintiff’s permission, his phone service had a four (4) digit
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`passcode as well. While on the phone with the agent, Plaintiff was told to update a new passcode
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`to his account and the agent would add “extra” security measures to Plaintiff’s account.
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`33.
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`Plaintiff’s phone was restored hours later. The following day, Plaintiff’s phone
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`service was not working again and Plaintiff immediately called AT&T to see why this was
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`happening and the agent said it was because the first agent only added Plaintiff’s SIM back to the
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`account and did not disable the fraudulent SIM. The actions of the first agent was how the
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`fraudsters were able to deplete most of Plaintiff’s cryptocurrency account.
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`34.
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`The neglect of on behalf of AT&T’s first agent/employee is clear, since Plaintiff’s
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`services have not been compromised since the second agent restored Plaintiff’s services and
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`completed the job properly.
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`35. Meanwhile, however, as a result of AT&T's failure to provide reasonable and
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`appropriate security to prevent unauthorized access to Plaintiff Etheridge's wireless account, after
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`getting control of Plaintiff Etheridge's phone number, wrongdoers were able to change Plaintiff
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`Etheridge's password on one of his cryptocurrency accounts and remove most of the contents –
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`159.8 ETHEREUM Tokens (“Plaintiff Etheridge’s 159.8 ETHEREUM Tokens”).
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`36.
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`After the incident, ETH price reached more than $4,200 per coin token.
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`37.
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`By its procedures, practices and regulations, AT&T engages in practices that,
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`taken together, fail to provide reasonable and appropriate security to prevent unauthorized access
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`to its customer wireless accounts, allowing unauthorized persons to be authenticated and then
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`granted access to sensitive customer wireless account data, including access and control over
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`159.8 ETHEREUM Tokens.
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`38.
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`In particular, AT&T has failed to establish or implement reasonable policies,
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`procedures, or regulations governing the creation and authentication of user credentials for
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`authorized customers accessing AT&T accounts, creating unreasonable risk of unauthorized
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`access. As such, at all times material hereto, AT&T has failed to ensure that only authorized
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`persons have such access and the customer accounts are secure.
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`39.
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`Among other things, AT&T:
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`a. failed to establish or enforce rules sufficient to ensure only authorized persons have
`access to AT&T customer accounts;
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`b. failed to establish appropriate rules, policies and procedures for the supervision and
`control of its officers, agents or employees;
`
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`c. failed to establish or enforce rules, or provide adequate supervision or training,
`sufficient to ensure that all its employees or agents follow the same policies and
`procedures. For example, it is often possible to persuade one of AT&T agents to not
`apply the stated security policy and allow unauthorized access without providing a
`PIN. similarly, on information and belief, AT&T agents or employees generally act
`on their own regardless of what is in the notes of a customer account, failing, among
`other things, to accommodate customers' security requests;
`
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`d. failed to adequately safeguard and protect its customers wireless accounts, including
`that of Plaintiff Etheridge, so wrongdoers were able to obtain access to his account;
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`e. permits the sharing of and access to user credentials among AT&T's agents or
`employees without a pending request from the customer, thus reducing likely
`detection of, and accountability for, unauthorized accesses;
`
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`f. failed to suspend user credentials after a certain number of unsuccessful access
`attempts. For example, wrongdoers would call numerous times trying to gain access
`to customer accounts before they finally got an agent on the line that would authorize
`access without requiring, for example, a PIN;
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`g. failed to adequately train and supervise its agents and employees in such a manner
`that allows its agents or employees, without authorization or approval to unilaterally
`access and make changes to customer accounts as if the customer were so authorized;
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`h. allows porting out of phone numbers without properly confirming that the request is
`coming from the legitimate customers;
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`lacked proper monitoring solutions and thus fails to monitor its systems for the
`presence of unauthorized access in a manner that would enable AT&T to detect the
`intrusion so that the breach of security and diversion of customer information was
`able to occur in Plaintiff Etheridge’s situation and continue until after his virtual
`currency account was compromised;
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`i.
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`j.
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`failed to implement simple, low-cost, and readily-available defenses to identity
`thieves such as delaying transfers from accounts on which the password was recently
`changed or simply delaying transfers from accounts to allow for additional
`verifications from the customers; and
`
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`k. failed to build adequate internal tools to help protect its customers against hackers
`and account takeovers, including compromise through phone porting and wrongdoing
`by its own agents or employees actin on their own behalf or on behalf or at the
`request of a third party.
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`40.
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`By the security practices and procedures described here, AT&T established user
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`credential structures that created an unreasonable risk of unauthorized access to customer
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`accounts, including that of Plaintiff Etheridge.
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`41.
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`On information and belief, AT&T has long been aware about the security risks
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`presents by, inter alia, its weak user credential structures or procedures. From prior attacks on
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`customer accounts, AT&T has long had notice of those risks. In addition, AT&T did not use
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`readily-available security measures to prevent or limit such attacks.
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`42.
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`As a result of AT&T's faulty security practices, an attacker could easily gain
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`access to a customer's account and then use it to gain access to the customer's sensitive
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`information such as bank accounts or virtual currency accounts, among other things.
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`43.
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`As such, AT&T's security measures were entirely inadequate to protect its
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`customers, including Plaintiff Etheridge.
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`db/20-12011/Complaint
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`44.
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`Lack of adequate security in AT&T's systems, practices, or procedures enabled
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`the wrongdoers to access Plaintiff Etheridge's wireless account, which then enabled the
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`wrongdoers to access and steal his virtual currency account and possibly other sensitive
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`information.
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`45.
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`As such, AT&T failed the responsibility it owed to Plaintiff Etheridge to protect
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`his account and his phone number. Even if the subject incident was due to an "inside" job or
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`human performance falling short, AT&T is responsible for its agent. And, while AT&T can
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`outsource customer service functions, AT&T cannot transfer accountability.
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`46.
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`Had AT&T provided adequate account security or exercised reasonable oversight,
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`Plaintiff Etheridge would not have lost his phone number and Plaintiff Etheridge’s 159.8
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`ETHEREUM Tokens or otherwise been damaged.
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`47. Making matters worse, Plaintiff Etheridge is not the only AT&T customer to
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`suffer as a result of AT&T's failure to ensure adequate security of its customer accounts.
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`48.
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`After the incident, Plaintiff Etheridge sent a letter to AT&T explaining the
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`predicament and trying to resolve this matter. AT&T responded with a low settlement offer.
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`49.
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`Plaintiff Etheridge believed that AT&T's actions were illegal. As such, he sought
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`assistance of counsel.
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`50.
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`As a direct consequence of AT&T's actions or inactions, Plaintiff Etheridge has
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`suffered and continues to suffer actual damages, including: (a) lost time; (b) embarrassment and
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`humiliation; (c) aggravation and frustration; (d) fear; (e) anxiety; (f) financial uncertainty; (g)
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`unease; (h) emotional distress; (i) expenses, including missed work, delayed projects, postage
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`expenses and attorney's fees and costs; and (j) lost value of Plaintiff Etheridge’s 159.8
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`ETHEREUM Tokens.
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`db/20-12011/Complaint
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`V. FEDERAL COMMUNICATIONS ACT
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`51.
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`Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`reference as if fully set forth herein.
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`52.
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`53.
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`The FCA regulates interstate telecommunications carriers such as Defendant.
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`Defendant is a common carrier engaged in interstate communication by wire for
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`the purpose of furnishing communication services within the meaning of section 201(a) of the
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`FCA. As "common carrier," Defendant is subject to the substantive requirements of sections 201
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`and 202 of the FCA.
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`54.
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`Under section 201(b), common carriers may impose only those practices,
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`classifications, and regulations that are "just and reasonable." and, under section 202(a) common
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`carriers are prohibited from making any unjust or unreasonable discrimination in "practices,
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`classifications, regulations, facilities, or services."
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`55.
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`Should a common carrier "omit to do any act, matter, or thing in this chapter
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`required to be done," section 206 dictates that the "common carrier shall be liable to the person
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`or persons injured thereby for the full amount of damages sustained in consequence of any such
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`violations … together with a reasonable counsel or attorney's fee[.]"
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`56.
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`Defendant's conduct, as alleged here, constitutes a knowing violation of section
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`201(b) and section 202(a). Further, under section 217, Defendant is also liable for the acts,
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`omissions, or failures, as alleged in this Complaint, of any of its offers, agents, or other persons
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`acting for or employed by Defendant.
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`57.
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`Additionally, Defendant is a "telecommunications carrier" within the meaning of
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`section 222, which requires every telecommunication carrier to protect, among other things, the
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`confidentiality of propriety information of, and relating to, customers.
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`db/20-12011/Complaint
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`58.
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`Defendant's conduct, as alleged here, constitutes a knowing violation of section
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`222. On information and belief, Defendant disclosed, without Plaintiff's approval, Plaintiff's
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`proprietary information to a third party or parties for reasons other than for emergency services.
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`Defendant also improperly permitted access to Plaintiff's customer proprietary network
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`information in Defendant's provisions of its services.
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`59.
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`As a direct consequence of Defendant's violations of the FCA, Plaintiff has been
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`damaged and continues to be damaged in an amount to be provide at trial.
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`VI. BREACH OF CONTRACT
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`60. Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`reference as if fully set forth herein.
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`61. Plaintiff entered into a contract both express and implied with Defendant.
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`62. Defendant offered to provide wireless phone service in consideration of payment for
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`services from Plaintiff. Under the terms of the agreement, Plaintiff was required to pay in full
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`the agree-to charges submitted to him on his bills. Failure to pay in full would cause a breach of
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`contract and discontinuance of wireless telephone service, among other things. Plaintiff accepted
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`the offer of services from Defendant and performed all the conditions, covenants, promises, and
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`agreements required of him under the terms of the contract, and all conditions precedent have
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`otherwise occurred or been waived.
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`63. Among other things, the express and implied terms of the contract were that
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`Defendant would provide reasonable and appropriate security to prevent unauthorized access to
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`his wireless account or otherwise safeguard and protect Plaintiff's private and confidential
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`account information and not transfer his phone number to anyone without his express
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`authorization.
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`64. Defendant has failed, neglected, and refused, and continues to fail, neglect, and
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`refuse to perform its part of the contract or to tender such performance.
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`65. In the absence of such implied and express contract terms, Plaintiff would have acted
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`differently in his purchasing decision or would not have agreed to entered into a contract with
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`AT&T. Nor would he have entered into the contract if AT&T had properly disclosed to him the
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`true extent of its account security measures or lack thereof.
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`66. As a direct consequence of Defendant's breach of the contract, Plaintiff has been
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`damaged and continues to be damaged in an amount to be proven at trial.
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`VII. NEGLIGENCE
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`67.
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`Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`references as if fully set forth herein.
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`68.
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`Defendant owed Plaintiff a duty of, inter alia, care in the handling and
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`safeguarding of his customer account for the purposes of providing wireless services.
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`69.
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`70.
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`Defendant breached the duties it owed to Plaintiff.
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`As a direct consequence of Defendant's negligence, Plaintiff has been damaged
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`and continues to be damaged in an amount to be proven a trial, no part of which has been paid.
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`VIII. VIOLATION OF TEXAS DECEPTIVE TRADE PRACTICES ACT
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`70.
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`Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`reference as if fully set forth herein.
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`71.
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`Plaintiff is a consumer as that term is defined under the Texas Deceptive Trade
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`Practices Act (“DTPA”). One or more of the Defendants engaged in deceptive acts or practices
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`in soliciting Plaintiff to use the AT&T cellular phone service. In particular, the false, misleading
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`and deceptive acts perpetrated by one or more of the Defendants included, but not limited to:
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`a. causing confusion or misunderstanding about the source, sponsorship, approval or
`certification of goods and services;
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`b. causing confusion or misunderstanding about affiliation, connection, or
`association with, or certification by another;
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`c. representing that goods or services have sponsorship, approval, characteristics, or
`benefits that they do not have;
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`d. advertising goods or services with the intent not to sell them as advertised;
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`e. representing that an agreement confers or involves rights, remedies or obligations
`that it does not, or that are prohibited by law;
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`f. misrepresenting the authority of the salesman, representative or agent to negotiate
`the final terms of a consumer transaction; and
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`g. failing to disclose information about goods or services that was known at the time
`of the transaction and the failure to disclose was intended to induce the consumer
`to enter into the transaction that consumer would not have entered into if the
`information had been disclosed.
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`72.
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`Plaintiff relied on the false, misleading or deceptive acts and practices engaged in
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`by one or more of the Defendants. As a result, Plaintiff suffered damages caused by the false,
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`misleading or deceptive acts or practices by one or more of the Defendants.
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`73.
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`Plaintiff has suffered economic damages as a result of the Defendants’ actions in
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`an amount to be determined at trial. In addition, because Defendants’ actions were knowing and
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`intentional violations of the DTPA, Plaintiff is entitled to treble damages under the statute. In
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`addition, Plaintiff is entitled to his reasonable and necessary attorneys’ fees incurred in the
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`prosecution of this action. Tex. Bus. Com. Code §17.50(d).
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`IX. NEGLIGENT HIRING, RETENTION, AND SUPERVISION
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`74.
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`Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`reference as if fully set forth herein.
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`db/20-12011/Complaint
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`75.
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`At all times material hereto, Defendant's agents, officers, and employees,
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`including those directly or indirectly responsible for or involved in transferring Plaintiff's phone
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`number to another carrier were under Defendant's direct, supervision, and control.
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`76.
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`Defendant further assumed this duty by holding its officers, agents, and
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`employees out to the public as competent representatives.
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`77.
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`On information and belief, Defendant negligently retained, controlled, trained,
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`and supervised its agents and employees when Defendant knew or should have known they
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`posted a security threat. Defendant knew or should have known that is agents or employees
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`would allow unauthorized access its customer accounts, including that of Plaintiff.
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`78.
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`On information and belief, Defendant negligently retained, controlled, trained,
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`and supervised its agents and employees so they committed the wrongful acts complained of
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`herein against Plaintiff and other members of the public. On information and belief, Defendant
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`failed to properly control and supervise them to ensure customer account safety.
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`79.
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`It was foreseeable to Defendant is agents and employees would compromise
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`customer account safety or engage in other acts complained of here. Despite this knowledge,
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`Defendant failed to exercise reasonable care to supervise or control its agents and employees.
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`On information and belief, Defendant engaged in the acts alleged herein and/or condoned,
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`permitted, authorized, and/or ratified the conduct of its agents and employees
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`80.
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`As a direct result of Defendant's negligent hiring, control, retention and
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`supervision, Plaintiff has suffered damages in an amount to be proven at trial.
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`X. NEGLIGENT INFLICTION OF EMOTION DISTRESS
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`81.
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`Plaintiff re-alleges the foregoing allegations and incorporates these allegations by
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`reference as if fully set forth herein.
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`82.
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`Defendant could foresee that is actions would harm Plaintiff.
`14
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`db/20-12011/Complaint
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`

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`Case 4:21-cv-03002 Document 1 Filed on 09/15/21 in TXSD Page 15 of 16
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`83.
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`84.
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`85.
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`Defendant had a duty to Plaintiff.
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`Defendant breached its duty to Plaintiff.
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`Defendant made false and material misrepresentations regarding its security
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`measures and failed to establish and implement reasonable policies and procedures governing the
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`creation and authentication of user credentials for persons accessing Defendant's databases and
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`customer information.
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`86.
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`Defendant's actions have resulted in severe emotion distress and/or garden variety
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`emotional distress for Plaintiff, and Defendant's reckless disregard for Plaintiff's customer
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`account has significantly deteriorated Plaintiff's health.
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`XI. PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff prays for the following relief:
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`Judgment against Defendant for actual damages;
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`Statutory damages for DTPA and Federal Communications Act violations;
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`Treble damages under DTPA, calculated from the damages determined by the
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`1.
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`2.
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`3.
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`Court;
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`4.
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`Award of reasonable attorney fees and reimbursement of all costs for the
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`prosecution of this action under DTPA and other statutory provisions;
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`5.
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`6.
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`7.
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`Pre – and post-judgment interest on any amounts awarded;
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`Punitive damages as applicable; and
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`Such other and further relief as the Court deems just and proper.
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`TRIAL BY JURY
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`
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`Under the seventh amended to the Constitution of the United States of America, Plaintiff
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`is entitled to, and demands, a trial by jury.
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`
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`db/20-12011/Complaint
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`15
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`

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`Case 4:21-cv-03002 Document 1 Filed on 09/15/21 in TXSD Page 16 of 16
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`DATED this 8th day of September 2021.
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`Respectfully submitted,
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`RICHARD E. BROWN ATTORNEY AT LAW, P.C.
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`/s/ Richard E. Brown
`RICHARD E. BROWN
`54 Sugar Creek Center Blvd., Suite 300
`Sugar Land, Texas 77478
`Tel:
`(713) 977-8178
`Fax:
`(281) 888-1723
`E-mail: brownreb34@aol.com
`State Bar of Texas No. 03162400
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`ATTORNEY FOR PLAINTIFF
`JAMARQUIS ETHERIDGE
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`db/20-12011/Complaint
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`16
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