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In addition to Apple's significant safety concerns for its consumers, these products, which are consistently poorly constructed, are unlikely to function as well as genuine Apple products.

As a result, consumers will erroneously come to think that Apple's products are of inferior quality and lose trust in the Apple brand, damaging the enormous goodwill associated with the Apple trademarks.

These counterfeits have the potential to overheat, catch fire, and deliver a deadly electric shock to consumers while in normal use.

A white paper recently published by the consumer product safety and testing organization UL (formerly Underwriters Laboratories) reported that counterfeit Apple charging products often "lack the safety features necessary to protects users from shock and fire hazards," and UL tested twelve counterfeit Apple power adapters that "were so poorly designed and constructed that they posed a risk of lethal electrocution to the user."1 The safety of Apple's customers is of paramount importance to Apple, and Apple devotes significant resources to ensuring its power products meet industry safety standards and are subjected to rigorous testing for safety and reliability.

Apple makes great efforts to combat the distribution and sale of counterfeit Apple products bearing its trademarks.

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Each month, Apple identifies and reports many thousands of listings for counterfeit and infringing Apple products to under its notice and takedown procedures.

Over the last nine months, Apple, as part of its ongoing brand protection efforts, has purchased well over 100 i Phone devices, Apple power products, and Lightning cables sold as genuine by sellers on and delivered through Amazon's "Fulfillment by Amazon" program.

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