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DAVID SHONKA 

Acting General Counsel 

LAURA D. BERGER (FL Bar No. 11762) 

Federal Trade Commission 

901 Market Street, Suite 570 

San Francisco, CA 94103 

P: (202) 326-2471/F: (415) 848-5184 

lberger@ftc.gov; 

KEVIN H. MORIARTY (DC Bar No. 975904) 

CATHLIN TULLY (NY Bar) 

Federal Trade Commission 

600 Pennsylvania Ave N.W. 

Washington, DC 20580 

P: (202) 326-3644/F: (202) 326-3062 

kmoriarty@ftc.gov; ctully@ftc.gov 

Attorneys for Plaintiff Federal Trade Commission 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

____________________________________ 

FEDERAL TRADE COMMISSION, ) 

 ) Case No. ______________________ 

 Plaintiff, ) 

 ) 

v. ) 

 ) 

D-LINK CORPORATION ) 

 ) COMPLAINT FOR 

and ) PERMANENT INJUNCTION AND 

 ) OTHER EQUITABLE RELIEF

D-LINK SYSTEMS, INC., ) 

corporations, ) 

) 

 Defendants. ) 

___________________________________ ) 

1. Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint, brings this 

action under Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. 

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§ 53(b), to obtain permanent injunctive relief and other equitable relief against Defendants for 

engaging in unfair or deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a), in connection with Defendants’ failure to take reasonable steps to secure the 

routers and Internet-protocol cameras they designed for, marketed, and sold to United States 

consumers. 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345, and 15 U.S.C. §§ 45(a) and 53(b). 

3. Venue in the Northern District of California is proper under 28 U.S.C. § 1391(b) 

and (c) and 15 U.S.C. § 53(b). 

PLAINTIFF 

4. The FTC is an independent agency of the United States Government created by 

statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), 

which prohibits unfair or deceptive acts or practices in or affecting commerce. 

5. The FTC is authorized to initiate federal district court proceedings, by its own 

attorneys, to enjoin violations of the FTC Act and to secure such other equitable relief as may be 

appropriate in each case. 15 U.S.C. §§ 53(b), 56(a)(2)(A). 

DEFENDANTS 

6. Defendant D-Link Corporation (“D-Link”) is a Taiwanese corporation with its 

principal office or place of business at No. 289, Xinhu 3rd Rd., Neihu District, Taipei City, 

Taiwan 114. D-Link transacts or has transacted business in this district and throughout the 

United States. At all times material to this Complaint, acting alone or in concert with others, DLink purposefully directed its activities to the United States by designing, developing, marketing, 

and manufacturing routers, Internet-protocol (“IP”) cameras, and related software and services, 

intended for use by consumers throughout the United States. 

7. Defendant D-Link Systems, Inc., (“DLS”) is a California corporation with its 

principal office or place of business at 17595 Mt. Herrmann St., Fountain Valley, California 

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92708. DLS transacts or has transacted business in this district and throughout the United States. 

At all times material to this Complaint, acting alone or in concert with others, DLS has 

advertised, marketed, distributed, or sold routers, IP cameras, and related software and services, 

intended for use by consumers throughout the United States. The Chairman of DLS’s Board of 

Directors has served as D-Link’s Chief Executive Officer and the two entities have coordinated 

closely regarding the security of Defendants’ routers and IP cameras. 

8. The FTC’s claims against D-Link and DLS arise from or relate to Defendants’ 

acts or practices aimed at or taking place in the United States. 

COMMERCE 

9. At all times material to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS PRACTICES 

10. D-Link is a hardware device manufacturer that designs, develops, markets, and 

manufactures networking devices, including devices with core functions that relate to security, 

such as consumer routers and IP cameras. D-Link designs, develops, and manufactures these 

products, their marketing materials, and related software and services for distribution or sale to 

United States consumers through its subsidiary, DLS. 

 When releasing new software for such 

routers and IP cameras, D-Link uses a digital signature issued in its name, known as a “private 

key,” to sign the software, in order to assure entities, such as browsers and operating systems, 

that the software comes from an authentic or “trusted” source and is not malware. 

11. DLS is a subsidiary of D-Link and is nearly 98% owned by D-Link and its 

holding company, D-Link Holding Company, Ltd. DLS provides marketing and after-sale 

services integral to D-Link’s operations, including by marketing and acting as the sole 

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distributor of Defendants’ routers and IP cameras throughout the United States. 

 Among other services, DLS acts as the primary point-of-contact for 

problems that United States consumers have with Defendants’ routers, IP cameras, or related 

software and services; 

 DLS also assists in notifying 

United States consumers about the availability of security updates through means such as 

DLS’s websites. 

12. Defendants have provided software applications that enable users to access their 

routers and IP cameras from a mobile device (“mobile apps”), including a free “mydlink Lite” 

mobile app. Defendants designed the mydlink Lite app to require the user to enter a user name 

and password (“login credentials”) the first occasion that a user employs the app on a particular 

mobile device. After that first occasion, the app stores the user’s login credentials on that 

mobile device, keeping the user logged into the mobile app on that device. 

DEFENDANTS’ ROUTERS 

13. Defendants’ routers, like other routers, operate to forward data packets along a 

network. In addition to routing network traffic, they typically play a key role in securing 

consumers’ home networks, functioning as a hardware firewall for the local network, and 

acting as the first line of defense in protecting consumer devices on the local network, such as 

computers, smartphones, IP cameras, and other connected appliances, against malicious 

incoming traffic from the Internet. 

DEFENDANTS’ IP CAMERAS 

14. Defendants’ IP cameras, akin to many such IP cameras, play a key security role 

for consumers, by enabling consumers to monitor private areas of their homes or businesses, to 

detect any events that may place the property or its occupants at risk. In many instances, 

Defendants offer them as a means to monitor the security of a home while consumers are away, 

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or to monitor activities within the household, including the activities of young children, while a 

consumer is at home. Consumers seeking to monitor the security of their homes or the safety 

of young children may access live video and audio feeds (“live feeds”) from their cameras over 

the Internet, using a mobile device or other computer. 

DEFENDANTS’ SECURITY FAILURES 

15. Defendants have failed to take reasonable steps to protect their routers and IP 

cameras from widely known and reasonably foreseeable risks of unauthorized access, including 

by failing to protect against flaws which the Open Web Application Security Project has ranked 

among the most critical and widespread web application vulnerabilities since at least 2007. 

Among other things: 

a. Defendants repeatedly have failed to take reasonable software testing and 

remediation measures to protect their routers and IP cameras against wellknown and easily preventable software security flaws, such as “hard-coded” 

user credentials and other backdoors, and command injection flaws, which 

would allow remote attackers to gain control of consumers’ devices; 

b. Defendant D-Link has failed to take reasonable steps to maintain the 

confidentiality of the private key that Defendant D-Link used to sign 

Defendants’ software, including by failing to adequately restrict, monitor, and 

oversee handling of the key, resulting in the exposure of the private key on a 

public website for approximately six months; and 

c. Defendants have failed to use free software, available since at least 2008, to 

secure users’ mobile app login credentials, and instead have stored those 

credentials in clear, readable text on a user’s mobile device. 

THOUSANDS OF CONSUMERS AT RISK 

16. As a result of Defendants’ failures, thousands of Defendants’ routers and 

cameras have been vulnerable to attacks that subject consumers’ sensitive personal 

information and local networks to a significant risk of unauthorized access. In fact, the press 

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has reported that Defendants’ routers and cameras have been vulnerable to a range of such 

attacks and have been compromised by attackers, including by being made part of large scale 

networks of computers infected by malicious software, known as “botnets.” 

17. The risk that attackers would exploit these vulnerabilities to harm consumers was 

significant. In many instances, remote attackers could take simple steps, using widely available 

tools, to locate and exploit Defendants’ devices, which were widely known to be vulnerable. For 

example, remote attackers could search for vulnerable devices over the Internet and obtain their 

IP addresses using readily available tools, such as a popular search engine that can locate devices 

running particular software versions or operating in particular locations. Alternatively, attackers 

could use readily accessible scanning tools to identify vulnerable devices operating in particular 

areas or on particular networks. In many instances, an attacker could then take simple steps to 

exploit vulnerabilities in Defendants’ routers and IP cameras, impacting not only consumers who 

purchased these devices, but also other consumers, who access the Internet in public or private 

locations served by the routers or who visit locations under the IP cameras’ surveillance. 

18. By creating these vulnerabilities, Defendants put consumers at significant risk of 

harm in a variety of ways. An attacker could compromise a consumer’s router, thereby obtaining 

unauthorized access to consumers’ sensitive personal information. For example, using a 

compromised router, an attacker could re-direct consumers seeking a legitimate financial site to a 

spoofed website, where they would unwittingly provide the attacker with sensitive financial 

account information. Alternatively, using a compromised router, an attacker could obtain 

consumers’ tax returns or other files stored on the router’s attached storage device or could use 

the router to attack other devices on the local network, such as computers, smartphones, IP 

cameras, or connected appliances. Similarly, by exploiting the vulnerabilities described in 

Paragraph 15, an attacker could compromise a consumer’s IP camera, thereby monitoring 

consumers’ whereabouts to target them for theft or other criminal activity or to observe and 

record over the Internet their personal activities and conversations or those of their young 

children. In many instances, attackers could carry out such exploits covertly, such that 

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consumers would have no reason to know that an attack was ongoing. Finally, during the time 

Defendant D-Link’s private key was available on a public website, consumers seeking to 

download legitimate software from Defendants were at significant risk of downloading malware, 

signed by malicious actors using D-Link’s private key. 

DEFENDANTS’ SECURITY STATEMENTS 

19. Defendants have disseminated or caused to be disseminated to consumers 

statements regarding the security of their products, including their routers and IP cameras.

SECURITY EVENT RESPONSE POLICY 

20. From approximately December 2013 until early September 2015, after highlypublicized security flaws were found to affect many of its products, Defendant DLS posted a 

Security Event Response Policy on its product support webpage, 

http://support.dlink.com/securityadvisories.aspx, in the general form of Exhibit 1. Within 

its Security Event Response Policy, under a bolded heading “D-Link’s commitment to Product 

Security,” Defendant DLS stated: 

D-Link prohibits at all times, including during product development by D-Link or its 

affiliates, any intentional product features or behaviors which allow unauthorized access 

to the device or network, including but not limited to undocumented account 

credentials, covert communication channels, ‘backdoors’ or undocumented traffic 

diversion. All such features and behaviors are considered serious and will be given the 

highest priority. 

PROMOTIONAL CLAIMS 

21. Defendants highlight their routers’ security features in a wide range of materials 

available on Defendant DLS’s website, including user manuals and promotional brochures, 

which describe these features alongside language that specifically references the device’s 

“security”. Such materials include, but are not limited to, brochures in the general form of 

Exhibits 2-5, which state: 

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a. Under a bolded, italicized, all-capitalized heading, “EASY TO SECURE,” that 

the router: 

supports the latest wireless security features to help prevent unauthorized 

access, be it from over a wireless network or from the Internet. Support for 

WPATM and WPA2TM standards ensure that you will be able to use the best 

possible encryption, regardless of your client devices. In addition [the router] 

utilizes dual active firewalls (SPI and NAT) to prevent potential attacks from 

across the Internet. 

Delivering great wireless performance, network security and coverage [the 

router] is ideal for upgrading your existing wireless network. (See PX 2). 

b. Under a bolded, italicized, all-capitalized heading, “ADVANCED NETWORK 

SECURITY,” that the router: 

ensures a secure Wi-Fi network through the use of WPA/WPA2 wireless 

encryption. Simply press the WPS button to quickly establish a secure 

connection to new devices. The [router] also utilizes dual-active firewalls 

(SPI and NAT) to prevent potential attacks and intrusions from across the 

Internet. (See PX 3). 

c. Under a bolded heading, “Advanced Network Security,” that the router: 

supports the latest wireless security features to help prevent unauthorized 

access, be it from over a wireless network or from the Internet. Support for 

WPATM and WPA2TM standards ensure that you will be able to use the best 

possible encryption method. In addition, this [router] utilizes Stateful Packet 

Inspection Firewalls (SPI) to help prevent potential attacks from across the 

Internet. (See PX 4). 

d. Under a heading “128-bit Security Encryption,” that the router: 

protects your network with 128-bit AES data security encryption – the same 

technology used in E-commerce or online banking. Create your own network 

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name and password or put it at the tip of your fingers with ‘Push Button 

Security’ standard on every Amplifi device. With hassle-free plug and play 

installation, and advanced Wi-Fi protected setup, the [router] is not only one 

of the fastest routers available, its [sic] also one of the safest. (See PX 5). 

22. Defendants highlight the security of their IP cameras in a wide range of 

materials available on Defendant DLS’s website, including user manuals and promotional 

brochures, which describe these features alongside language that specifically references the 

device’s “security”. Such materials include, but are not limited to, brochures in the general 

form of Exhibit 6, which display the word “SECURITY” in large, capital letters, in a vividlycolored footer across the bottom of each page. (See PX 6). In addition, Defendants have 

designed their IP camera packaging, including in the general form of Exhibit 7, to display 

security-related terms. Such terms include the words “secure connection,” next to a lock icon, 

among the product features listed on the side of the box (see PX 7). 

INTERACTIVE SECURITY FEATURES 

23. Defendants’ routers offer numerous security features that Defendants present 

alongside instructions that specifically reference the device’s “security”. In particular, in many 

instances, to begin using the router, users must access a graphical user interface (hereinafter, 

“Defendants’ router GUI”), in the general form of Exhibits 8 and 9, which includes 

instructions, such as: 

a. “To secure your new networking device, please set and verify a password 

below” (see PX 8); and 

b. “It is highly recommended that you create a password to keep your router 

secure.” (See PX 9). 

24. Defendants’ IP cameras offer numerous security features that Defendants 

present alongside language that specifically references the device’s “security”. In particular, to 

begin using the camera, in many instances, users must access a GUI (hereinafter “Defendants’ 

IP camera GUI”), in the general form of Exhibits 10 and 11, which include language, such as: 

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a. instructions to “Set up an Admin ID and Password” or “enter a password” in 

order “to secure your camera” (see PX 10); and 

b. security-related banners, including, but not limited to, the words “SECURICAM 

Network,” alongside a lock icon, across the top of the GUI (see PX 11).

D-LINK DIRECTS ITS PRACTICES TO U.S. CONSUMERS 

25.

VIOLATIONS OF THE FTC ACT

26. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” 

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27. Acts or practices are unfair under Section 5 of the FTC Act if they cause or are 

likely to cause substantial injury to consumers that consumers cannot reasonably avoid 

themselves and that is not outweighed by countervailing benefits to consumers or competition. 15 

U.S.C. § 45(n). 

COUNT I 

Unfairness 

28. In numerous instances, Defendants have failed to take reasonable steps to secure 

the software for their routers and IP cameras, which Defendants offered to consumers, 

respectively, for the purpose of protecting their local networks and accessing sensitive personal 

information. 

29. Defendants’ practices caused, or are likely to cause, substantial injury to 

consumers in the United States that is not outweighed by countervailing benefits to consumers or 

competition and is not reasonably avoidable by consumers. 

30. Therefore, Defendants’ acts and practices as described in Paragraphs 15-18 of this 

Complaint constitute unfair acts or practices in or affecting commerce, in violation of Section 5 

of the FTC Act, 15 U.S.C. §§ 45(a) and 45(n). 

COUNT II 

Security Event Response Policy Misrepresentation 

31. Through the means described in Paragraph 20, Defendant DLS has represented, 

directly or indirectly, expressly or by implication, that Defendants took reasonable steps to 

secure their products from unauthorized access. 

32. In truth and in fact, as described in Paragraphs 15-18, Defendants did not take 

reasonable steps to secure their products from unauthorized access. 

33. Therefore, the making of the representation set forth in Paragraph 31 of this 

Complaint constitutes a deceptive act or practice, in or affecting commerce in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT III 

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Router Promotional Misrepresentations 

34. Through the means described in Paragraph 21, Defendants have represented, 

directly or indirectly, expressly or by implication, that the routers described by these claims were 

secure from unauthorized access.

35. In truth and in fact, as described in Paragraphs 15-18, Defendants’ routers were 

not secure from unauthorized access and control. 

36. Therefore, the making of the representation set forth in Paragraph 34 of this 

Complaint constitutes a deceptive act or practice, in or affecting commerce in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT IV 

IP Camera Promotional Misrepresentations 

37. Through the means described in Paragraph 22, Defendants have represented, 

directly or indirectly, expressly or by implication, that the IP cameras described by these claims 

were secure from unauthorized access and control. 

38. In truth and in fact, as described in Paragraphs 15-18, Defendants’ IP cameras 

were not secure from unauthorized access and control. 

39. Therefore, the making of the representation set forth in Paragraph 37 of this 

Complaint constitutes a deceptive act or practice, in or affecting commerce in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT V 

Router GUI Misrepresentations 

40. Through the means described in Paragraph 23, Defendants have represented, 

directly or indirectly, expressly or by implication, that the routers described by these claims were 

secure from unauthorized access. 

41. In truth and in fact, as described in Paragraphs 15-18, Defendants’ routers were 

not secure from unauthorized access and control. 

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42. Therefore, the making of the representation set forth in Paragraph 40 of this 

Complaint constitutes a deceptive act or practice, in or affecting commerce in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT VI 

IP Camera GUI Misrepresentations 

43. Through the means described in Paragraph 24, Defendants have represented, 

directly or indirectly, expressly or by implication, that the IP cameras described by these claims 

were secure from unauthorized access and control. 

44. In truth and in fact, as described in Paragraphs 15-18, Defendants’ IP cameras 

were not secure from unauthorized access and control. 

45. Therefore, the making of the representation set forth in Paragraph 43 of this 

Complaint constitutes a deceptive act or practice, in or affecting commerce in violation of 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

CONSUMER INJURY 

46. Consumers are likely to suffer substantial injury as a result of Defendants’ 

violations of the FTC Act. Absent injunctive relief by this Court, Defendants are likely to injure 

consumers and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

47. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC. 

PRAYER FOR RELIEF 

 Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), 

and the Court’s own equitable powers, requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC Act by 

Defendants; and 

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B. Award Plaintiff the costs of bringing this action, as well as such other and 

additional relief as the Court may determine to be just and proper. 

 Respectfully submitted, 

 DAVID SHONKA 

 Acting General Counsel 

Dated: January 5, 2017 /s/ Cathlin Tully________________ 

 LAURA D. BERGER 

 KEVIN H. MORIARTY 

 CATHLIN TULLY 

 

 Attorneys for Plaintiff 

 FEDERAL TRADE COMMISSION 

 

 

 

 

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