attorney general of washington consumer...
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STATE OF WASHINGTON KING COUNTY SUPERIOR COURT
STATE OF WASHINGTON,
Plaintiff, v. iYOGI, INC., a New York corporation; and VISHAL DHAR, individually and on behalf of his marital community, as President of iYogi, Inc.,
Defendants.
NO. COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW, AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
COMES NOW PLAINTIFF, State of Washington, by and through its attorneys Robert
W. Ferguson, Attorney General; Daniel Davies, Assistant Attorney General; and Andrea
Alegrett, Special Assistant to the Attorney General, and brings this action against Defendants
named herein, alleging as follows on information and belief:
I. INTRODUCTION
1.1 Defendant, iYogi, Inc. (“iYogi”), sells computer technical support services to
consumers throughout the country. iYogi induces consumers to purchase its services by
making a series of misrepresentations in violation of Washington’s Consumer Protection Act,
RCW 19.86 et seq. First, iYogi deceives people into believing it is a part of major computer
software and hardware companies like Norton, Microsoft, or Apple. iYogi representatives then
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
1 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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use iYogi proprietary software to remotely access consumers’ computers in order to identify
complex looking files they misrepresent are “infected files” harming the computer. The
representatives then convince consumers they need to download iYogi’s diagnostic software to
fully identify their computer problems. The software by design flashes a variety of warning
signs causing a “Critical” computer status regardless of the computer’s health, and iYogi’s
representative again falsely claims that malware or computer viruses have infected the
consumer’s computer. After making these claims, iYogi proceeds to sell the consumer
technical support plans costing between $149.99 and $379.90, claiming the services are
necessary to “fix” the consumer’s non-existent problems. iYogi also misrepresents that
consumers’ computers lack any anti-virus programs, in order to induce them to purchase
iYogi’s own anti-virus software. Numerous Washington consumers have purchased iYogi’s
technical support services and anti-virus software based on these deceptive actions.
1.2 iYogi also violates the Computer Spyware Act, RCW 19.270.040, by inducing
Washington computer owners and operators to install its proprietary software onto their
computers by misrepresenting that it is necessary to repair and protect the computer’s security.
In truth, the iYogi software by design provides alarmist reports regardless of the computer’s
health or is redundant to anti-virus software already on the consumer’s computer.
II. JURISDICTION AND VENUE
2.1 This Complaint is filed and these proceedings are instituted under the provisions
of the Unfair Business Practices – Consumer Protection Act, Chapter 19.86 RCW, and the
Computer Spyware Act, Chapter 19.270 RCW.
2.2 The violations alleged in this Complaint have been made and are being
committed in whole or in part in King County, Washington, by Defendants named herein.
2.3 The violations alleged in this Complaint are injurious to the public interest.
2.4 Authority of the Attorney General to commence this action is conferred by
RCW 19.86.080, RCW 19.86.140, and RCW 19.270.060.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
2 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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III. DEFENDANTS
3.1 Defendant iYogi, Inc. is a New York corporation with its principal place of
business located at 291 Broadway, Suite 305, New York, New York 10007.
3.2 Defendant Vishal Dhar was, at all material times to this lawsuit, the President and
co-founder of iYogi, and as such, controlled its policies, activities, and practices, including those
alleged in the Complaint herein. Defendant Dhar resides in New York, New York. Defendant
Dhar is married to Sarah Killough-Dhar, and together they constitute a marital community. All
actions taken by Defendant Dhar as alleged in the Complaint herein were and are for the
benefit of his marital community.
IV. FACTS
A. iYogi
4.1 iYogi, Inc. is the United States-based part of one of the largest retailers of
consumer technical support services in the world. The iYogi organization as a whole has over
3 million customers, operates in at least 11 countries, and has several business entities around
the world. It maintains a large online presence, consisting of at least 245 Internet domains,
with some of those domains directed to the United States, United Arab Emirates, Canada,
India, the United Kingdom, Spain, France, Italy, Australia, and Germany. In addition to its
web presence, iYogi uses or has used at least 17 phone numbers for its call center.
4.2 According to iYogi, its technical support includes the following services:
computer diagnostics and repair, general troubleshooting, updates to computer drivers, security
protection against online threats, help connecting to the Internet, and PC speed and
performance optimization.
B. iYogi’s Advertisements
4.3 Consumers learn of iYogi through a variety of methods, including performing a
search for specific technical support and finding iYogi’s online advertisements. iYogi
purchases advertising on Internet search engines linked to specific terms relating to various
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
3 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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computer and software companies. For example, if a consumer searches for “Apple tech
support” or “HP tech support” in Google, she will find iYogi as a top search result:
Figure 1, Search for “Apple Technical Support” at https://www.google.com, dated July 16, 2015.
4.4 When a consumer contacts iYogi, the representative who fields the telephone
call associates himself with Apple, Hewlett Packard, or whatever specific company the
consumer inquires about. For example, the iYogi representative will claim he is a certified
Microsoft technician but may fail to disclose that Microsoft has not hired him to provide
technical support services to customers. Likewise, if a consumer calls iYogi thinking she is
speaking with a company like Symantec Corp., the producer of Norton Antivirus software, the
iYogi representative will not correct the consumer’s misunderstanding.
C. iYogi Claims to Diagnose Problems with the Consumer’s Computer
4.5 After introducing himself, the iYogi representative asks the consumer several
technical-sounding questions about her computer, including inquiries about its manufacturer
and operating system. Next, the representative directs the consumer to navigate to iYogi’s
owned and operated website, www.1mb.com, to grant the technician permission to remotely
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
4 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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access the consumer’s computer. Through this remote access, the representative is able to
perform activities directly on the consumer’s computer as if physically present with the
consumer. The consumer watches on-screen as the technician moves the mouse, types on the
screen, and opens files and folders.
4.6 iYogi’s representative manually performs what appear to be technologically
complex diagnostic tasks. The consumer watches the computer screen while these tasks are
being performed. At the conclusion of the purported diagnostic tasks, the representative
highlights various items on the consumer’s screen and claims that the items are malware,
infected files, or other serious defects harming the computer:
Figure 2, Screenshot of iYogi highlighting purported infected files on a consumer’s computer, dated Oct. 21, 2015.
4.7 Contrary to the iYogi representative’s claims, the highlighted items often are
routine programs or files that pose no harm to the consumer’s computer.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
5 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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4.8 The representative then tells the consumer that she must install iYogi’s
“Support Dock” and “PCDiagnostics” software (together, the “Diagnostic Software”) to
diagnose any problems with the computer. The representative claims the Diagnostic Software
is necessary to repair and protect the security of the consumer’s computer.
4.9 The Diagnostic Software displays alarming warning signs when it runs a “scan”
of the consumer’s computer:
Figure 3, Screenshot of iYogi diagnostic report, dated Oct. 21, 2015
4.10 In the screenshot above, the consumer sees on the scan a “warning” for “junk
content” and a “caution” message indicating that 27 errors were detected during the “registry
check.” The consumer is also told that there is a “Windows update error” present and a
problem with the computer’s restore function. The Diagnostic Software displays warnings
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
6 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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even when a computer is free from defects, indicating that the consumer’s overall “System
State” is “Critical.” In fact, most of these “warnings” are related to routine computer
functions. Contrary to the iYogi representative’s statements, they do not indicate that there is a
problem with the consumer’s computer that will render it inoperable.
D. iYogi Offers to Sell Technical Support Services
4.11 Once iYogi has alarmed the consumer, it offers to sell the consumer technical
support services. iYogi’s support service contracts vary, but include offers to sell a five-year
computer support service contract for $379.90 or a one-year support contract for prices ranging
from $149.99 to $179.99. iYogi offers to include an upgrade from a Windows 7 operating
system to Windows 10 as part of its five-year support service contract, adding that failing to
update will harm the computer and render it inoperable, which is untrue. iYogi states that
upgrading to Windows 10 will cost $199 if the consumer does not purchase a five-year
contract. If a consumer declines the five-year contract, iYogi offers to sell the consumer
Windows 10 for $80. Microsoft currently provides free upgrades from Windows 7 to
Windows 10.
E. iYogi Offers to Sell Consumers Computer Security Software in Addition to Its Technical Support Services
4.12 After a consumer purchases iYogi’s technical support services, iYogi attempts
to sell the consumer its additional TechGenie computer security software (the “TechGenie
Software”) for $79.00. iYogi informs the consumer that she does not have a security system
installed on her computer, reiterates that the consumer’s computer is infected with malware,
and states that the TechGenie Software is necessary to remove the malware and protect the
computer from any future viruses. iYogi makes these claims even when the consumer already
has an anti-virus or other computer security program installed on her computer.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
7 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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V. CLAIMS
COUNT I: CONSUMER PROTECTION ACT, RCW 19.86.020
5.1 Plaintiff realleges paragraphs 1.1 through 4.12 and incorporates them as if fully
set forth herein.
5.2 In the context of marketing and selling its technical support services, iYogi
makes numerous implied and express deceptive statements; including, but not limited to, the
following:
5.2.1 iYogi deceives consumers into believing it is a part of various software
and hardware providers like Microsoft, Apple, Hewlett-Packard, and
Symantec through the net impression of its representations to
consumers; including, but not limited to, the following:
a. iYogi positions itself so that a consumer who is searching for
“Microsoft tech support,” “Apple tech support,” or “HP tech
support” through a search engine, such as Google, will find
iYogi as a top search result rather than the relevant company’s
own technical support webpage. iYogi purchases placement on
search engines so that its advertising will be featured more
prominently than the software and hardware companies for
which the consumer is actually searching. Consumers who speak
with iYogi’s representatives often believe they are speaking with
representatives of the company for which they originally
searched.
b. iYogi further implies it is a part of other computer companies by
telling consumers that its representatives are “certified
technicians” of companies like Microsoft.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
8 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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c. iYogi fails to correct consumers who indicate to iYogi that they
believe they are speaking with representatives of other computer
companies like Microsoft or Symantec.
5.2.2 The Diagnostic Software displays deceptive visual warnings and
diagnostic results, which misrepresent that a consumer’s computer
suffers from defects and infected files. For example, in one instance the
Diagnostic Software scan displayed a final “Critical” PC score of 64%
and indicated that attention was required for the following four items:
1. System Restore – Caution. No restore points detected. 2. Registry Check – Caution. 27 Registry errors detected. 3. Windows Update – Warning. Windows update error detected. 4. Junk Content – Warning. 307 MB Junk files detected.
(See Figure 3.) However, none of the items identified were actual
defects or infected files.
5.2.3 In addition to the deceptive warning signs produced by the Diagnostic
Software scan, iYogi representatives also misrepresent that a consumer’s
computer is infected with malware, computer viruses, or suffers from
other serious defects. For example, iYogi has made the following
deceptive representations to Washington consumers regarding the state
of their computers’ health:
a. iYogi claimed that a user’s network settings showed that her
computer may have been compromised and allowed people to
misuse her personal and financial information. In fact, the
network settings were standard settings and did not provide
anyone access to the user’s information.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
9 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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b. iYogi falsely claimed that most of the programs on a consumer’s
computer had stopped working and should be running. The
computer, however, had no defective programs on it.
c. iYogi claimed that a consumer’s computer had low CPU usage,
which was problematic. Low CPU usage means that the CPU
has extra capacity. It does not indicate anything is wrong with
the computer.
d. iYogi claimed that “junk” files took up more than half of the
memory of a consumer’s computer. The files iYogi identified as
“junk” files were actually temporary files that took up nowhere
near half of the computer’s memory.
e. iYogi claimed that the unused portion of a computer’s memory
was being used by “junk” files. This was false. The unused
portion of memory is just that: physical memory in the machine
that is not being used.
f. After the Diagnostic Software scan was finished it showed two
purported errors with the word “Warning” in red. The
representative claimed that it was “registry junk” and that the
registry was the most important part of the computer and that
even a single error would be a point of concern. The
representative further stated that these purported issues showed
that the consumer’s network might have been compromised. The
“registry junk” identified were benign and did not suggest that
the consumer’s computer network was compromised.
5.2.4 In addition to iYogi’s deceptive conduct relating to its sales of technical
support services, iYogi also engages in deceptive conduct when it tries
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
10 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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to sell consumers its TechGenie Software. Specifically, iYogi
misrepresents that a consumer’s computer does not have any anti-virus
programs installed, when the computer, in fact, has a common computer
security program like Microsoft Security Essentials. It uses this
deceptive statement to convince the consumer to purchase its TechGenie
Software, so that the consumer’s computer will purportedly be
adequately protected.
5.2.5 iYogi misrepresents the value of its technical support services contracts
by inflating the benefit of the services with an overvalued upgrade to the
Windows 10 operating system as part of the package. iYogi tells the
consumer that upgrading to Windows 10 from Windows 7 or 8 costs
$199.00 if the upgrade is done independently, but that the upgrade is
“included” for free as part of iYogi’s five-year service package or for
$80 as part of iYogi’s one-year package. In fact, an upgrade to
Windows 10 is free for Windows 7 or 8 users who choose to do so
independently. In addition, iYogi incorrectly tells consumers that their
computers will stop working if they do not upgrade to Windows 10
soon.
5.3 Defendant Vishal Dhar is the Chief Executive Officer of Defendant iYogi, and as
such, controls and has the authority to control the unfair and deceptive policies and activities that
form the core of iYogi’s sales practices.
5.4 iYogi’s actions affect the public interest because it repeatedly engaged in the
conduct described above and made the claims to dozens—if not hundreds or thousands—of
Washington consumers.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
11 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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5.5 The conduct described in paragraphs 5.1 through 5.4 constitutes unfair and
deceptive acts or practices in trade or commerce and unfair methods of competition in violation
of RCW 19.86.020.
COUNT II: COMPUTER SPYWARE STATUTE, RCW 19.270.040
5.6 Plaintiff realleges paragraphs 1.1 through 5.5 and incorporates them as if fully
set forth herein.
5.7 Washington’s Computer Spyware Statute, RCW 19.270 et seq., prohibits a
person from inducing a computer owner to install software by deceptively misrepresenting the
extent to which installing the software is necessary for maintenance or repair of the computer
or computer software, for security or privacy reasons, or for the proper operation of the
computer. iYogi induces consumers to install both its Diagnostic Software and TechGenie
Software in a manner that violates the Computer Spyware Statute.
5.8 With respect to the Diagnostic Software, iYogi representatives deceptively
misrepresent that it is necessary to install the software in order to properly diagnose and
identify problems with a user’s computer that needs repair or maintenance. However, the
Diagnostic Software displays warning signs regardless of whether a computer has any defects
or not. iYogi uses the Diagnostic Software as a method of alarming consumers in order to
convince them to purchase both technical support services and the TechGenie Software.
5.9 iYogi representatives also claim that consumers’ computers lack any anti-virus
programs when the computers are, in fact, running anti-virus programs like Microsoft Security
Essentials. iYogi makes this misrepresentation to convince consumers that installation of
iYogi’s TechGenie security software is necessary for the security of their computers.
5.10 iYogi induces Washington computer owners and operators to install its
Diagnostic Software and TechGenie Software components onto their computers by deceptively
misrepresenting the extent to which installing the software is necessary for maintenance,
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
12 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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repair, and security of their computers and their computers’ software, and for proper operation
of their computers.
5.11 The conduct described in paragraphs 5.6 through 5.10 violates RCW
19.270.040.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiff, STATE OF WASHINGTON, prays that this Court grant the
following relief:
6.1 That the Court adjudge and decree that Defendants have engaged in the conduct
complained of herein.
6.2 That the Court adjudge and decree that the conduct complained of in Paragraphs
5.1 through 5.4 constitutes unfair or deceptive acts or practices and unfair methods of
competition in violation of the Consumer Protection Act, Chapter 19.86 RCW.
6.3 That the Court adjudge and decree that the conduct complained of in Paragraphs
5.6 through 5.10 constitutes violations of the Computer Spyware Act, Chapter 19.270 RCW.
6.4 That the Court issue a permanent injunction enjoining and restraining
Defendants and their representatives, successors, assignees, officers, agents, servants,
employees, and all other persons acting or claiming to act for, on behalf of, or in active concert
or participation with Defendants from continuing or engaging in the unlawful conduct
complained of herein.
6.5 That the Court assess civil penalties pursuant to RCW 19.86.140 of up to $2,000
per violation against Defendants for each and every violation of RCW 19.86.020 caused by the
conduct complained of herein.
6.6 That the Court assess damages pursuant to RCW 19.270.060 in the amount of
$100,000 per violation of the Computer Spyware Act, RCW 19.270.
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
13 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
6.7 That the Court make such orders pursuant to RCW 19.86.080 as it deems
appropriate to provide for restitution to consumers of money or property acquired by
Defendants as a result of the conduct complained of herein.
6.8 That the Court make such orders pursuant to RCW 19.86.080 and RCW
19.270.070 to provide that Plaintiff, State of Washington, have and recover from Defendants
the costs of this action, including reasonable attorney's fees.
6.9 That the Court order such other relief as it may deem just and proper to fully
and effectively dissipate the effects of the conduct complained of herein, or which may
otherwise seem proper to the Court.
DATED this I C-11\ day of December, 2015.
Presented by:
ROBERT W. FERGUSON Attorney General
DANIEL DAVIES, WSBA #41793 Assistant Attorney General ANDREA ALEGRETT Special Assistant to the Attorney General Attorneys for Plaintiff State of Washington
COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF UNDER THE CONSUMER PROTECTION ACT, CHAPTER 19.86 RCW AND THE COMPUTER SPYWARE ACT, CHAPTER 19.270 RCW
14 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188 (206) 464-7745
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