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FOR THE
CENTRAL
DISTRICT
OF CALIFORNIA
IN
THE
MATTER
OF
THE
SEARCH
OF
No.
ED
15
- 0451M
APPLE
!PHONE
SEIZED
DURING
SEARCH
[PROPQSEf)]
ORDER
COMPELLING
APPLE,
A
BLACK
LEXUS
IS300,
INC.
TO
ASSIST
AGENTS
IN
SEARCH
CALIFORNIA LICENSE
PLATE
35KGD203
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flLElJ
ClERK
U
.S.
DISiRICT
COURT
EILEEN
M.
DECKER
United
States
Attorney
PATRICIA
A.
DONAHUE
liB I 6
20!6
J
Assistant
United
States
Attorney
Chief,
National
Security
Division
CENTRAL
DI
STRICT
Of
CALIF
,\
TRACY
L.
WILKISON
(California
Bar
No.
184948)
V
Assistant
United
States
Attorney
Chief,
Cyber
and
Intellectual
Property
Crimes
Section
ALLEN
W.
CHIU
(California
Bar
No.
240516)
Assistant
United
States
Attorney
Terrorism
and
Export
Crimes
Section
1500
United
States
Courthouse
312
North
Spring
Street
Los
Angeles,
California
90012
Telephqne:
(213)
894-0622/2435
0
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{213)
894-8601
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I
Tracy.
Wilkison@usdoj.gov
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Allen.
Chiu@usdoj.gov
Atturn.e~s
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for
Applicant
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UNITED STATES
DISTRICT
COURT
This
matter
is
before
the
Court
pursuant
to
an
application
pursuant
to
the
All
Writs
Act,
28
U.S.C.
§
1651,
by
Assistant
United
States
Attorneys
Tracy
Wilkison
and
Allen
Chiu,
requesting
an
order
directing
Apple
Inc.
("Apple"}
to
assist
law
enforcement
agents
in
enabling
the
search
of
a
digital
device
seized
in
the
course
of
a
previously
issued
search
warrant
in
this
matter.
For
good
cause
shown,
IT
IS
HEREBY
ORDERED
that:
1.
Apple
shall
assist
in
enabling
the
search
of
a
cellular
telephone,
Apple
make:
iPhone
SC,
Model:
Al532,
P/N:MGFG2LL/A,
S/N:FFMNQ3MTG2DJ,
IMEI:358820052301412,
on
the
Verizon
Network,
(the
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J
f'
J
,
"SUBJECT DEVICE")
pursuant
to
a
warrant
of
this
Court
by
providing
reasonable
technical
assistance
to
assist
law
enforcement
agents
in
obtaining
access
to
the
data
on
the
SUBJECT DEVICE.
2.
Apple's
reasonable
technical
assistance
shall
accomplish
the
following
three
important
functions:
(1)
it
will
bypass
or
disable
the
auto-erase
function
whether
or
not
it
has
been
enabled;
(2)
it
will
enable
the
FBI
to
submit
passcodes
to
the
SUBJECT DEVICE
for
testing
electronically
via
the
physical
device
port,
Bluetooth,
Wi-Fi,
or
other
protocol
available
on
the
SUBJECT DEVICE;
and
(3)
it
will
ensure
that
when
the
FBI
submits
passcodes
to
the
SUBJECT
DEVICE,
software
running
on
the
device
will
not
purposefully
introduce
any
additional
delay
between
passcode
attempts
beyond
what
is
incurred
by
Apple
hardware.
3.
Apple's
reasonable
technical
assistance
may
include,
but
is
not
limited
to:
providing
the
FBI
with
a
signed
iPhone
Software
file,
recovery
bundle,
or
other
Software
Image
File
("SIF")
that
can
be
loaded
onto
the
SUBJECT DEVICE.
The
SIF
will
load
and
run
from
Random
Access
Memory ("RAM")
and
will
not
modify
the
iOS
on
the
actual
phone,
the
user
data
partition
or
system
partition
on
the
device's
flash
memory.
The
SIF
will
be
coded
by
Apple
with
a
unique
identifier
of
the
phone
so
that
the
SIF
would
only
load
and
execute
on
the
SUBJECT DEVICE.
The
SIF
will
be
loaded
via
Device
Firmware
Upgrade
("DFU")
mode,
recovery
mode,
or
other
applicable
mode
available
to
the
FBI.
Once
active
on
the
SUBJECT DEVICE,
the
SIF
will
accomplish
the
three
functions
specified
in
paragraph
2.
The
SIF
will
be
loaded
on
the
SUBJECT DEVICE
at
either
a
government
facility,
or
alternatively,
at
an
Apple
facility;
if
the
latter,
Apple
shall
provide
the
government
with
remote
access
to
the
SUBJECT
2
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'
~
DEVICE
through
a
computer
allowing
the
government
to
conduct
passcode
recovery
analysis.
4.
If
Apple
determines
that
it
can
achieve
the
three
functions
stated
above
in
paragraph
2,
as
well
as
the
functionality
set
forth
in
paragraph
3,
using
an
alternate
technological
means
from
that
recommended
by
the
government,
and
the
government
concurs,
Apple
may
comply
with
this
Order
in
that
way.
5.
Apple
shall
advise
the
government
of
the
reasonable
cost
of
providing
this
service.
6.
Although
Apple
shall
make
reasonable
efforts
to
maintain
the
integrity
of
data
on
the
SUBJECT DEVICE,
Apple
shall
not
be
required
to
maintain
copies
of
any
user
data
as
a
result
of
the
assistance
ordered
herein.
All
evidence
preservation
shall
remain
the
responsibility
of
law
enforcement
agents.
7.
To
the
extent
that
Apple
believes
that
compliance
with
this
Order
would
be
unreasonably
burdensome,
it
may
make
an
application
to
this
Court
for
relief
within
five
business
days
of
receipt
of
the
Order.
SHERI
PYM
DATED:
FEB
1 6
2016
UNITED STATES MAGISTRATE JUDGE
3