IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, CHANCERY DIVISION
CHRISTINE DESANTIS, individually and ) on behalf of a class of similarly situated individuals, ) )
Plaintiff ) No.
) JURY TRIAL DEMANDED
v. )
) SEARS, ROEBUCK AND CO., ) a New York Corporation )
) Defendant )
CLASS ACTION COMPLAINT
Plaintiff Christine Desantis, on behalf of herself and a class of similarly situated
individuals, brings this action against defendant Sears, Roebuck and Co. ("Sears"). Upon
personal knowledge as to herself and her own acts and upon information and belief as to all other
matters, Desantis complains as follows:
VENUE
1. Venue is proper in Cook County because Sears resides in Cook County and
because the wrongful acts arose here.
PARTIES
2. Desantis is a resident of New Jersey.
3. Sears is an Illinois corporation with its principle place of business in Hoffman
Estates, Illinois, located in Cook County.
SEARS’S UNSECURED "MANAGEMYHOME" WEBPAGE
4. In an effort to promote its website and increase sales, Sears has established a web-based system to allow customers to view their purchase history on-line at www.managemyhome.com ("Managemyhome website").
5. Sears’s system, however, is fatally flawed and was designed in such a way as to significantly compromise the private information of its customers.
6. Sears’s system works as follows: A user goes to Managemyhome website, creates an account and logs-in. The user then need only enter in publicly-available information (such as the name, phone number and street address) of a Sears customer in order to view the customer’s history of on-line and even in-store purchases. The Managemyhome website provides detailed histories of past purchases, including model numbers, purchase dates, warranty information, and protection plans.
7. Moreover, the Managemyhome website will provide purchase history of all residents of a particular address, regardless of whether …
Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code.
-Marc
