To extract this data, comScore’s Surveillance Software injects code into the user’sweb browser to monitor everything viewed, clicked, or inputted online. In addition, the softwareopens ports,
modifies the consumer’s firewall, and places “root certificates”
on the affectedcomputer to ensure unimpeded access.7.
The scope and breadth of data that comScore collects from unsuspectingconsumers is terrifying. By way of illustration, comScore’s Surveillance Software constantlycollects and transmits the following data, among others, from a consumer’s computer tocomScore’s servers:a)
the monitored consumer’s usernames and passwords; b)
queries on search engines like Google;c)
the website(s) the monitored consumer is currently viewing;d)
credit card numbers and any financial or otherwise sensitive informationinputted into any website the monitored views;e)
the goods purchased online by the monitored consumer, the price paid bythe monitored consumer for the goods, and amount of time the monitoredconsumer views the goods before purchase;f)
specific advertisements clicked by the monitored consumer.8.
After the Surveillance Software is installed on a monitored consumer’s computer,all
Internet traffic from the consumer’s computer is re-routed through comScore servers beforereaching a destination website.9.
Furthermore, comScore’s Surveillance Software seeks out and scans every file onthe monitored consumer’s computer (including word processing documents, emails, PDFs,image files, spreadsheets, etc.), and sends information resulting from examination of those filesto comScore’s servers.
In this context, “ports” are incoming and outgoing portals on a system which facilitatecommunications between computers over the Internet.
“Root certificates” are more fully explained in ¶¶ 60-66 of this Complaint.
Case: 1:11-cv-05807 Document #: 1 Filed: 08/23/11 Page 3 of 27 PageID #:3