Defendants are notorious hackers—amoral 21st century mercenaries who have created highly sophisticated cyber-surveillance machinery that invites routine and flagrant abuse. They design, develop, sell, deliver, deploy, operate, and maintain offensive and destructive malware and spyware products and services that have been used to target, attack, and harm Apple users, Apple products, and Apple. For their own commercial gain, they enable their customers to abuse those products and services to target individuals including government officials, journalists, businesspeople, activists, academics, and even U.S. citizens…
In light of Apple’s formidable security features and defenses, all but a very few truly exceptional malware attacks on Apple devices are unsuccessful. These attacks have been very carefully designed and deliberately targeted by highly sophisticated parties with extraordinary resources and capabilities—typically nation-states and their agencies or instrumentalities, or, in some cases, those that do business with them. The Defendants associate themselves with these entities to enable their malicious hacking of iOS, Android, and other technologies.
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