1

192 3011

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman

 Noah Joshua Phillips

Rohit Chopra

 Rebecca Kelly Slaughter

Christine S. Wilson

 

In the Matter of

TAPPLOCK, INC., a corporation.

 DOCKET NO.

COMPLAINT

The Federal Trade Commission (“Commission”), having reason to believe that Tapplock, 

Inc. (“Respondent” or “Tapplock”) has violated the provisions of the Federal Trade Commission 

Act, and it appearing to the Commission that this proceeding is in the public interest, alleges: 

1. Respondent Tapplock, Inc. is a Canadian corporation with its principal office or place of 

business at 121 Richmond Street West, Toronto, Ontario M5H 2K1, Canada.

2. The acts or practices of Respondent alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act 

and constitute “deceptive acts or practices involving foreign commerce” as set forth in 

Section 5 of the FTC Act. 

RESPONDENT’S BUSINESS PRACTICES

3. Respondent is an Internet of Things (“IoT”) company that, among other things, sells 

Internet-connected, fingerprint-enabled padlocks (“smart locks”) to U.S. consumers. 

Respondent’s smart locks interact with a companion mobile application (“app”) that U.S. 

users are able to download onto their mobile devices. This app logs usernames, e-mail 

addresses, profile photos, location history, and the precise geolocation of a user’s smart 

lock, and it allows users to lock and unlock their smart locks when they are within 

Bluetooth range. 

4. Respondent designs the smart locks it sells to U.S. consumers, is responsible for 

remediating security vulnerabilities and other flaws associated with those locks, and 

directly or through its distributors markets and advertises its locks to U.S. consumers. 
2

5. Respondent advertises to U.S. consumers through its website, www.tapplock.com, and 

has previously advertised through the online crowd funding website Indiegogo.com. 

These websites advertised Respondent’s smart locks in U.S. dollars. 

6. Further, Respondent contracted with a U.S.-based third-party service provider to fulfill 

orders and ship its products to U.S. consumers.

7. Respondent shipped its devices to its service provider’s U.S.-based warehouse in order to 

fulfill orders to U.S. customers. Respondent also referenced the U.S.-based warehouse in 

public statements to customers (e.g., “Our warehouse is in New Jersey”).

RESPONDENT’S DECEPTIVE 

SECURITY PRACTICES

8. Respondent advertised its smart locks to consumers as “Bold. Sturdy. Secure.” 

9. Respondent’s advertisements touted that its “secure” smart locks were also:

• “strengthened with double-layered lock design;” 

• designed with “anti-shim and anti-pry technologies” (Shimming refers to 

inserting a foreign object into the latch, and prying refers to using a lever to force 

open a padlock); and 

• designed to be “unbreakable,” as follows,
3

10. Respondent makes additional claims about its information security practices in its privacy 

policy, accessible online to its U.S. customers, stating in part:

To protect your personal information, we take reasonable precautions and 

follow industry best practices to make sure it is not inappropriately lost, 

misused, accessed, disclosed, altered or destroyed.

11. Respondent also claims that users can share access to their locks with an unlimited 

number of other people, and that users can subsequently limit or revoke such shared 

access.

12. Despite these claims, Respondent’s smart locks were not secure. In June 2018, three 

separate security researchers identified critical physical and electronic vulnerabilities 

with Respondent’s smart locks.

13. With respect to physical security, one security researcher demonstrated that he could 

unlock some of Respondent’s smart locks within a matter of seconds, simply by

unscrewing the back panel. 

14. Researchers also discovered reasonably foreseeable electronic security vulnerabilities that

could have been avoided if Respondent had implemented simple, low-cost steps. For 

example:

a. One vulnerability in Respondent’s API allowed researchers to bypass the account 

authentication process in order to gain full access to the accounts of all Tapplock 

users and their personal information, including usernames, e-mail addresses, 

profile photos, location history, and precise geolocation of smart locks. A 

researcher who logged in with a valid user credential could then access another 

user’s account without being re-directed back to the login page, thereby allowing 

the researcher to circumvent Respondent’s authentication procedures altogether.

b. A second vulnerability allowed researchers to lock and unlock any nearby 

Tapplock smart lock. Because Respondent failed to encrypt the Bluetooth 

communication between the lock and the app, researchers were able to easily 

discover and replicate how Respondent generated the private keys necessary to 

lock and unlock user’s smart locks.

c. A third vulnerability prevented users from effectively revoking access to their 

smart lock once they had provided other users access to that lock. This 

vulnerability allowed the researchers to “sniff” data packets for the information 

necessary to authenticate their access to the lock. With that information, 

researchers were able to continue accessing the lock even after their access had 

been revoked.
4

15. Contrary to the statements described in Paragraphs 8-11, Respondent did not take 

reasonable measures to secure its locks, or take reasonable precautions or follow industry 

best practices for protecting consumers’ personal information. In fact, Respondent did 

not have a security program prior to the discovery of the vulnerabilities described in 

Paragraph 13 and 14. For example, Respondent: 

a. failed to identify reasonably foreseeable risks to the security of its smart locks or 

the security of customers’ personal accounts, such as through vulnerability or 

penetration testing, and assess the sufficiency of any safeguards in place to 

control those risks;

b. failed to employ sufficient measures to detect and prevent users from bypassing 

the authentication procedures in Respondent’s API to gain access to other users’ 

accounts;

c. failed to adopt and implement written data security standards, policies, 

procedures, or practices; and

d. failed to implement adequate privacy and security guidance or training for its 

employees responsible for designing, testing, overseeing, and approving software 

specifications and requirements.

16. As a result of these failures, consumers’ personal information was exposed, as described 

in Paragraph 14, and consumers’ personal property was put at risk.

VIOLATIONS OF THE FTC ACT

Deceptive Representation Regarding Security

(Count I)

17. Through the means described in Paragraphs 8-9, Respondent has represented, directly or 

indirectly, expressly or by implication, that its smart locks were secure.

18. In truth and in fact, as described in Paragraphs 12-16, Respondent’s smart locks were not 

secure. Therefore, the representation set forth in Paragraph 17 is false or misleading.

Deceptive Representation Regarding Protection of Personal Information

(Count II)

19. Through the means described in Paragraph 10, Respondent has represented, directly or 

indirectly, expressly or by implication, that it took reasonable precautions and followed 

industry best practices to protect the personal information provided by consumers. 

20. In truth and in fact, as described in Paragraphs 14-16, Respondent failed to take 

reasonable precautions and follow industry best practices to protect the personal 
5

information provided by consumers. Therefore, the representation set forth in Paragraph 

19 is false or misleading.

Violation of Section 5

21. The acts and practices of Respondent as alleged in this complaint constitute deceptive 

acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act.

THEREFORE, the Federal Trade Commission this ___ day of ____, 2019, has issued this 

complaint against Respondent. 

By the Commission. 

[April J. Tabor]

[Acting Secretary]

SEAL: