Exhibit 21

To Declaration of Jarad Brown in Support of 

Federal Trade Commission’s 

Motion for Summary Judgment

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Kevin H. Moriarty (DC Bar No. 975904) 

Shameka Walker (DC Bar No. 493891) 

Cathlin Tully (NY Bar) 

Jarad Brown (CA Bar No. 294516) 

Katherine E. McCarron (DC Bar No. 486335) 

James A. Trilling (DC Bar No. 467273) 

Federal Trade Commission 

600 Pennsylvania Avenue NW, Mail Drop CC-8232 

Washington, DC 20580 

P: (202) 326-2949/F: (202) 326-3062 

kmoriarty@ftc.gov; swalker@ftc.gov; ctully@ftc.gov; 

jbrown4@ftc.gov; kmccarron@ftc.gov; jtrilling@ftc.gov 

Attorneys for Plaintiff Federal Trade Commission 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

D-LINK SYSTEMS, INC., 

 Defendant. 

Civil Action No. 

3:17-cv-00039-JD 

Declaration of Jamie Elliott Hine 

Pursuant to 28 U.S.C. § 1746 

I, Jamie E. Hine, hereby state that I have personal knowledge of the facts as set forth 

below. If called as a witness, I could and would testify as follows: 

1. I am a citizen of the United States and am over eighteen (18) years of age. I am a 

general attorney at the Federal Trade Commission (“FTC” or “Commission”). I am presently 

assigned to the Division of Privacy and Identity Protection of the FTC’s Bureau of Consumer 

Protection. My work address is 600 Pennsylvania Avenue, NW, Mail Stop, CC-8232, 

Washington, D.C. 20580. 

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2. On August 16, 2018, I supervised the purchase of two DCS-2310L cameras from 

amazon.com and newegg.com. Attached hereto as Exhibit A are the order details from these 

purchases. 

Amazon-Purchased Camera 

3. On August 17, 2018, the DCS-2310L camera purchased from amazon.com was 

delivered by UPS to the FTC’s office at 400 7th Street SW in Washington, DC. I opened the 

exterior packaging from Amazon and inspected the packaging of the camera. The serial number 

ended with the numbers “100.” The information on the packaging confirmed that this was a 

DCS-2310L camera (hereinafter “Amazon/100 Camera”). The information on the box stated 

that the firmware version of this device was firmware version 1.00. The following images 

capture this information: 

Image 1 

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Image 2 

4. On August 23, 2018, I set up the Amazon/100 Camera purchased from 

amazon.com. In order to set-up the Amazon/100 Camera, I followed the instructions on the 

included pamphlet titled “Quick Install Guide,” which directed me to (1) visit a webpage at the 

URL www.mydlink.com/download; (2) click on the icon for my camera model; and (3) select 

and download the “Wizard” for my operating system. After finding the DCS-2310L, I clicked 

on the text “Windows Setup Wizard” under “For H/W Rev. A:”. That action opened up a 

window that suggested downloading the mydlink Mobile App, but that also provided a button 

labeled “Download Windows Setup Wizard.” I clicked on the button “Download Windows 

Setup Wizard.” This prompted me to run or save a file named “autorun.exe.” I saved it to the 

computer. After following other instructions in the “Quick Install Guide,” I double-clicked on 

“autorun.exe,” which opened an application called mydlink Setup Wizard, with “DCS-2310L 

Setup Wizard” displayed in the window. I captured the installation process using a software tool 

called Camtasia. I have provided all unedited videos to FTC counsel. 

5. On August 23, 2018, I captured video from the administration pages of the DCS2310L purchased from amazon.com using Camtasia. A screenshot from the video I captured on 

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August 23, 2018 is pasted below. This screenshot establishes that the firmware on the DCS2310L purchased on August 16, 2018 from amazon.com was firmware version 1.00.03. 

Image 3 (image redacted to omit FTC DNS information). 

6. On August 28, 2018, I logged out of the administrator account of the DCS-2310L 

purchased from amazon.com. I closed the browser I was using. When I re-opened the browser 

and entered the IP address assigned by the network to the Amazon/100 Camera, I was asked for 

my credentials. For username, I entered “guest,” and for password, I entered “guest.” After 

entering the “guest/guest” credentials, I was able to view the video feed from the Amazon/100 

Camera I had just set up. I captured video of this process using Camtasia, and I have included a 

screenshot of this video feed while logged in as “guest.” 

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Image 4 

Newegg-Purchased Camera 

7. On August 20, 2018, the DCS-2310L camera purchased from newegg.com was 

delivered by USPS to the FTC’s office at 400 7th Street SW in Washington, DC. I opened the 

exterior packaging from Newegg and inspected the packaging of the camera. The serial number 

ended with the numbers “714.” The information on the packaging confirmed that this was a 

DCS-2310L camera (hereinafter “Newegg/714 Camera”). The information on the box also 

stated that the firmware version of this device was firmware version 1.00. The following images 

capture this information: 

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Image 5 

Image 6 

8. On August 28, 2018, I set up the Newegg/714 Camera purchased from 

newegg.com on a separate computer from the computer used to set up the Amazon/100 Camera. 

In order to set-up the Newegg/714 Camera, I followed the instructions on the included pamphlet 

titled “Quick Install Guide,” which directed me to (1) visit a webpage at the URL 

www.mydlink.com/download; (2) click on the icon for my camera model; and (3) select and 

download the “Wizard” for my operating system. After finding the DCS-2310L, I clicked on the 

text “Windows Setup Wizard” under “For H/W Rev. A:”. That action opened up a window that 

suggested downloading the mydlink Mobile App, but that also provided a button labeled 

“Download Windows Setup Wizard.” I clicked on the button “Download Windows Setup 

Wizard.” This prompted me to run or save a file named “autorun.exe.” I saved it to the 

computer. After following other instructions in the “Quick Install Guide,” I double-clicked on 

“autorun.exe,” which opened an application called mydlink Setup Wizard, with “DCS-2310L 

Setup Wizard” displayed in the window. I captured the installation process using a software 

tool called Camtasia. I have provided all unedited videos to FTC counsel. 

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9. On August 28, 2018, I captured video of administration pages of the DCS-2310L 

purchased from newegg.com using Camtasia. In the video, I navigate through several screens 

over to the “Maintenance” tab and down to the “Firmware Upgrade” sub-tab. This screenshot 

from the video I captured on August 28, 2018 is pasted below. This screenshot establishes that 

the firmware on the DCS-2310L purchased on August 16, 2018 from newegg.com was firmware 

version 1.00.03. 

Image 7 

10. On August 28, 2018, I logged out of the administrator account of the DCS-2310L 

purchased from newegg.com. I closed the browser I was using. When I re-opened the browser 

and entered the IP address assigned by the network to the Newegg/714 Camera, I was asked for 

my credentials. For username, I entered “guest,” and for password, I entered “guest.” After 

entering the “guest/guest” credentials, I was able to view the video feed from the Newegg/714 

Camera I had just set up. I captured video of this process using Camtasia, and I have included a 

screenshot of this video feed while logged in as “guest.” 

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1 ,vr vrnro SETUP ADVANCED 

TTns secnon shows your camera's hve video. You ran control your settings using the buttons below. 

Current resolution is 1280 x 800. 

LIVE VIDEO 

Image 8 

I declare under penalty of perjury that the foregoing is true and correc/4. , 

Date: August 28, 2018 Signed: L~z. L_!_ 

Jamie E. Hine 

8 

Case 3:17-cv-00039-JD Document 178-23 Filed 09/21/18 Page 9 of 12
Exhibit A 

Case 3:17-cv-00039-JD Document 178-23 Filed 09/21/18 Page 10 of 12
Newegg.com - Newegg shopping upgraded TM 

We've updated our Privacy Poilc-y. Le,,rn More 

<JiB,uu 

ORDER DETAILS 

ORD6R SUMMARY 

Order Date: 8/16/2018 at 01:27PM 

Sold and Shipped by Great Daily Buys 

Product Description Qty 

Shipped from Great Daily Buys 

D-Link DCS-2310L 1280 x 800 MAX Resolution Surveillance Camera 1 

Hem A: 9SIABt j4D1,:l.990 

Grand Subtotal 

Total Tax 

Total Shipping 

Grand Total 

Page 1 of 1 

Order# 436164771 

Invoice# 162465892 

Price 

Tracking# 9405511899223156480101 

$122.77 

$122.77 

$0.00 

$0.00 

$122.77 

X 

https://secure.newegg.com/NewMy Account/CartDetail.aspx?CartID=Kz8F6ibnpzGTGV n... 8/28/2018 

Case 3:17-cv-00039-JD Document 178-23 Filed 09/21/18 Page 11 of 12
Amazon.com - Order l 14-1529167-5289819 Page 1 of 1 

amazon.com· 

Final Details for Order #114-1529167-5289819 

Print this page for your records. 

Order Placed: August 16, 2018 

Amazon.com order number: 114-1529167-5289819 

Order Total: $103.58 

Shipped on August 16, 2018 

Items Ordered 

1 of: D-Link PoE IP 1 MP HD HD 720p Cube Indoor/Outdoor Camera with 

Remote Viewing (DCS-2310L) 

Price 

$95.99 

Sold by: A2ZWireless (seller profile) 

Condition: New 

Shipping Address: 

LaQuisha N. Hawkins 

600 PENNSYLVANIA AVE NW CC-8232 

WASHINGTON, DC 20580-0002 

United States 

Shipping Speed: 

Standard Shipping 

Item(s) Subtotal: $95.99 

Shipping & Handling: $7 .59 

Total before tax : $103.58 

Sales Tax : $0.00 

Total for This Shipment: $103.58 

Payment information 

Payment Method: 

MasterCard I Last digits: 4431 

Billing address 

LaQuisha N. Hawkins 

600 Pennsylvania Avenue NW 

CC-8232 

Washington, DC 20580 

United States 

Credit Card transactions 

Item(s) Subtotal: $95.99 

Shipping & Handling: $7.59 

Total before tax: $103.58 

Estimated tax to be collected: $0.00 

Grand Total:$103.58 

MasterCard ending in 4431: August 16, 2018: $103.58 

To view the status of your order, return to Order Summary. 

Conditions of Use I Privacy Notice© 1996-2018, Amazon.com, Inc. or its affiliates 

https://www .amazon.com/ gp/css/summary /print.html/ref=od _ aui _print_ invoice?ie= UTF8. .. 8/28/2018 

Case 3:17-cv-00039-JD Document 178-23 Filed 09/21/18 Page 12 of 12