NOTICE OF CLASS ACTION AND DEMAND

This Is Notice of Class Action and a Demand to Immediately Unlock

All Mobile Wireless Devices in the United States.
To: Apple
Sprint
T-Mobile
U.S. Cellular
Third Party Computer Vendors of Mobile Wireless Devices

From: Lauren Paulson on Behalf of The Class
Date: Tuesday, May 6, 2014
At all times material hereto, Apple, Sprint, T-Mobile, U.S. Cellular and
other mobile wireless manufacturers, carriers and providers have conspired to
engage in uncompetitive and illegal practices known as locking a
consumers mobile wireless device (here telephones). Locking forces
consumers to needlessly purchase a new telephone when switching mobile
wireless device carriers. Consumers of mobile wireless devices do not know
the device nor mobile wireless carrier services are locked when securing or
purchasing said devices or services.
This practice and these locking practices are an illegal collusive
practice in restraint of trade in violation of the Sherman Act of 1890,
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the Clayton Act of 1914, the Federal Trade Commission Act of 1914, The
Consumer Code For Wireless Service and the intentional violation of the
Federal Communications Announcement dated December 11, 2013: in
which there was a voluntary commitment among mobile wireless service
providers on standards for policies on unlocking mobile wireless devices.
Unlocking a device allows consumers to move their device from one
network to another compatible network.
Further, the CTIA-TheWireless Association is intentionally in violation
of their own adopted standards on mobile wireless device unlocking and their
said commitment thereto dated February 11, 2014 among other violations and
laws in illegal restraint of trade.
The above identified companies are in intentional and open violation of
the aforementioned laws, consents, commitments and agreements causing
known and unknown injuries to consumers such as Lauren Paulson, who is
acting on behalf of the class of consumers similarly situated all to their
damage in the amount of $10,000 each, or such amounts as are proved at
trial. These consumers are also entitled to punitive damages in an amount of
$500,000 or such amounts as are proved at trial for their failure to abide by
the federal and state anti-trust laws because such violations are intentional
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notwithstanding said voluntary consents and commitments to cease said
actions of locking mobile wireless networks and devices. These violations
cause the ordinary consumer to lose their telephone service or incur costs of
purchasing replacement telephones causing known and unknown damages to
vulnerable consumers in need of EMERGENCY MEDICAL CARE and are
unable to obtain needed medical care due to these illegal locking practices
aforesaid.
These parties have conspired with computer vendors known as Third
Party Vendors such as Software Electronics of Portland, Oregon who would
normally provide the unlocking of consumer telephones but refuse to do so
because of the illegal acts aforesaid.
Apple has colluded with said mobile wireless device carriers to lock
said telephones and refuses to unlock these devices in clear violations of the
antitrust laws, agreements, consents and commitments aforesaid.
Lauren, (email from Apple dated May 5, 2014)
I completely understand the frustration. #Apple only sells
contracted iPhones with subsidies or Unlocked/Full Price
iPhones without subsidies. #If you paid anything other than
the full price (starting in the neighborhood of $649 for
newer iPhones) for the device that would mean you
received a subsidized price from the company who's
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contracted cellular plan you signed with. #That would
require a "sim-locked" phone for that particular carrier.

The part that confuses me the most is that all resources I
have utlizied (sic) state that the Sprint iPhone does not
use the same radio bands as T-Mobile. #Essentially, the
iPhone 4S you have was never physically intended to
support T-Mobile's cellular technology, locked/unlocked
aside. #Which is why I nd it interesting that the phone was
functioning for you prior to this issue.

I understand that information does not resolve your issue.
#In short, I would continue partnering with John from T-
Mobile and even look into the loaner option he offered to
get you back up and running.

Long term, you will have to consider getting a phone that
is either unlocked for use on a GSM network (the
technology T-Mobile and AT&T use) and/or purchase a T-
Mobile specic iPhone. #You can looking (sic) into trade-in/
recycling options to recoup some value from your older
Sprint iPhone 4S.

Regards,

Nick Deao
Business Specialist
Apple Store, Pioneer Place

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THEREFORE,
THIS NOTICE IS BEING PROVIDED TO THE STATES
ATTORNEY GENERALS, THE U.S. DEPARTMENT OF JUSTICE,
THE FEDERAL TRADE COMMISSION, THE FEDERAL
COMMUNICATIONS COMMISSION AND OTHER RELEVANT
CONSUMER AGENCIES AND DEPARTMENTS. THESE ENTITIES
ARE CHARGED WITH ENFORCEMENT OF ILLEGAL ACTS IN
RESTRAINT OF TRADE AND THE ILLEGAL CREATION OF
MONOPOLIES AND SUCH ORDERS SHOULD BE ISSUED TO
IMMEDIATELY stop this illegal behavior and to impose necessary and
proper remedies, and issue appropriate Orders or Consent Decrees to
immediately cease and desist said illegal and improper locking or
failing to provide unlocking activities.


Private civil suits may be brought, in both state and federal court,
against violators of state and federal antitrust law. Federal antitrust
laws, as well as most state laws, provide for triple damages against
antitrust violators in order to encourage private lawsuit enforcement of
antitrust law.


/S/ Lauren Paulson on behalf of the Class
Contact: Lauren Paulson
827C Ransom Ave
Brookings, OR 97415
503 470 9709 (not functioning since April 18, 2014 due to said locking)
laurenjpaulson@gmail.com
bulletinsfromaloha.org

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