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    The document summarizes recent orders Apple has received from various US courts compelling them to assist law enforcement in accessing iOS devices. It details an order from California that would force Apple to load custom software to hack an iPhone's passcode security. It also provides a table listing 14 other similar orders received, with details on jurisdiction, device, iOS version, and Apple's response. Apple intends to challenge these orders but notes the issue remains pressing as they continue receiving such demands.

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    The document summarizes recent orders Apple has received from various US courts compelling them to assist law enforcement in accessing iOS devices. It details an order from California that would force Apple to load custom software to hack an iPhone's passcode security. It also provides a table listing 14 other similar orders received, with details on jurisdiction, device, iOS version, and Apple's response. Apple intends to challenge these orders but notes the issue remains pressing as they continue receiving such demands.

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    The document summarizes recent orders Apple has received from various US courts compelling them to assist law enforcement in accessing iOS devices. It details an order from California that would force Apple to load custom software to hack an iPhone's passcode security. It also provides a table listing 14 other similar orders received, with details on jurisdiction, device, iOS version, and Apple's response. Apple intends to challenge these orders but notes the issue remains pressing as they continue receiving such demands.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    138 views48 pages

    Show Multidocs

    Uploaded by

    kmccoynyc
    The document summarizes recent orders Apple has received from various US courts compelling them to assist law enforcement in accessing iOS devices. It details an order from California that would force Apple to load custom software to hack an iPhone's passcode security. It also provides a table listing 14 other similar orders received, with details on jurisdiction, device, iOS version, and Apple's response. Apple intends to challenge these orders but notes the issue remains pressing as they continue receiving such demands.

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    You are on page 1of 48

    Case 1:15-mc-01902-JO Document 27 Filed 02/17/16 Page 1 of 3 PageID #: 570

    1900 M Street, NW, Ste. 250, Washington, D.C. 20036


    marc@zwillgen.com

    Marc J. Zwillinger
    (202) 706-5202 (phone)
    (202) 706-5298 (fax)
    February 17, 2016
    VIA ELECTRONIC FILING UNDER SEAL
    The Honorable James Orenstein
    United States Magistrate Judge
    United States District Court
    Eastern District of New York
    225 Cadman Plaza East
    Brooklyn, NY 11201
    Re:

    In re Order Requiring Apple Inc. to Assist in the Execution of a Search Warrant


    Issued by the Court, No. 15-MC-1902

    Dear Judge Orenstein:


    I write in response to this Courts February 16, 2016 order (the Order) requesting that Apple
    provide certain additional details regarding other requests it has received during the pendency of this
    matter that are of a similar nature to the one at issue in the instant case.
    As recently as yesterday, Apple was served with an order by the United States Attorneys
    Office for the Central District of California. (See Exhibit A.) The government obtained that order on
    the basis of an ex parte application pursuant to the All Writs Act (see Exhibit B), regarding which
    Apple had no prior opportunity to be heard (despite having specifically requested from the
    government in advance the opportunity to do so). The attached order directs Apple to perform even
    more burdensome and involved engineering than that sought in the case currently before this Court
    i.e., to create and load Apple-signed software onto the subject iPhone device to circumvent the
    security and anti-tampering features of the device in order to enable the government to hack the
    passcode to obtain access to the protected data contained therein. (See Exhibit A.) As invited by the
    California courts order, Apple intends to promptly seek relief. But, as this recent case makes
    apparent, the issue remains quite pressing.
    In addition to the aforementioned order, Apple has received other All Writs Act orders during
    the pendency of this case, certain details of which are set forth in the table below. In particular, for
    each such request Apple provides the following categories of information requested in the Order:

    Case 1:15-mc-01902-JO Document 27 Filed 02/17/16 Page 2 of 3 PageID #: 571

    (1) the jurisdiction in which the request was made, (2) the type of device at issue in the request, (3) the
    version of iOS being used on that device, and (4) Apples response to the request and/or its current
    status, as applicable.
    Date
    Received

    Jurisdiction

    Device Type

    iOS Version

    Status

    10/8/2015

    Southern District
    of New York

    iPhone 4S

    7.0.4

    Apple objected (12/9/2015)

    10/30/2015 Southern District


    of New York

    iPhone 5S

    7.1

    Apple objected (12/9/2015)

    11/16/2015 Eastern District of


    New York

    iPhone 6 Plus

    8.1.2

    Apple objected (12/9/2015)

    iPhone 6

    8.1.2

    11/18/2015 Northern District


    of Illinois

    iPhone 5S

    7.1.1

    12/4/2015

    iPhone 6

    8.0 (or higher) Apple objected (12/9/2015)

    iPhone 3

    4.2.1

    iPhone 3

    6.1.6

    Northern District
    of California

    12/9/2015

    Northern District
    of Illinois

    iPhone 5S

    7.0.5

    Apple requested copy of


    underlying Motion but has
    not received it yet
    (2/1/2016)

    1/13/2016

    Southern District
    of California

    N/A
    (device ID not
    yet provided)

    N/A
    (device ID not
    yet provided,
    but the
    requesting
    agent advised
    device is preiOS 8)

    Apple was advised by the


    requesting agent that she is
    seeking a new warrant.
    Apple has not yet received
    this warrant.

    2/2/2016

    Northern District
    of Illinois

    iPad 2 Wifi

    7.0.6

    Apple objected (2/5/2016)

    2/9/2016

    District of
    Massachusetts

    iPhone 6 Plus

    9.1

    Apple objected (2/11/2016)

    Apple objected (12/9/2015)

    Case 1:15-mc-01902-JO Document 27 Filed 02/17/16 Page 3 of 3 PageID #: 572

    With respect to the other categories of information sought in the Order (specifically, categories
    4-6), Apple responds that following its objection or other response to each request there has not been
    any final disposition thereof to Apples knowledge, and Apple has not agreed to perform any services
    on the devices to which those requests are directed.1
    Sincerely,
    /s/ Marc J. Zwillinger
    Marc J. Zwillinger
    cc:

    All Counsel of Record (via ECF)

    Apple further notes that shortly preceding the pendency of the instant case, it received additional
    All Writs Act ordersspecifically, two from the Southern District of Ohio (both on September 24,
    2015) and Northern District of Illinois (on October 6, 2015). Apple objected to each of these
    orders, and to Apples knowledge there have been no further developments since such objections
    were lodged.
    3

    Case 1:15-mc-01902-JO Document 27-1 Filed 02/17/16 Page 1 of 4 PageID #: 573

    Exhibit A

    Case 1:15-mc-01902-JO Document 27-1 Filed 02/17/16 Page 2 of 4 PageID #: 574

    Case 1:15-mc-01902-JO Document 27-1 Filed 02/17/16 Page 3 of 4 PageID #: 575

    Case 1:15-mc-01902-JO Document 27-1 Filed 02/17/16 Page 4 of 4 PageID #: 576

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 1 of 41 PageID #: 577

    Exhibit B

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 2 of 41 PageID #: 578

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 3 of 41 PageID #: 579

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 4 of 41 PageID #: 580

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 5 of 41 PageID #: 581

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 6 of 41 PageID #: 582

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 7 of 41 PageID #: 583

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 8 of 41 PageID #: 584

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 9 of 41 PageID #: 585

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 10 of 41 PageID #: 586

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 11 of 41 PageID #: 587

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 12 of 41 PageID #: 588

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 13 of 41 PageID #: 589

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 14 of 41 PageID #: 590

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 15 of 41 PageID #: 591

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 16 of 41 PageID #: 592

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 17 of 41 PageID #: 593

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 18 of 41 PageID #: 594

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 19 of 41 PageID #: 595

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 20 of 41 PageID #: 596

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 21 of 41 PageID #: 597

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 22 of 41 PageID #: 598

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 23 of 41 PageID #: 599

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 24 of 41 PageID #: 600

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 25 of 41 PageID #: 601

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 26 of 41 PageID #: 602

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 27 of 41 PageID #: 603

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 28 of 41 PageID #: 604

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 29 of 41 PageID #: 605

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 30 of 41 PageID #: 606

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 31 of 41 PageID #: 607

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 32 of 41 PageID #: 608

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 33 of 41 PageID #: 609

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 34 of 41 PageID #: 610

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 35 of 41 PageID #: 611

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 36 of 41 PageID #: 612

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 37 of 41 PageID #: 613

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 38 of 41 PageID #: 614

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 39 of 41 PageID #: 615

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 40 of 41 PageID #: 616

    Case 1:15-mc-01902-JO Document 27-2 Filed 02/17/16 Page 41 of 41 PageID #: 617

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