13. Apple tracks users locations on its own, separate, apart and in addition to the information it collects in conjunction with other businesses that develop applications for Apple's devices. This action is not about the applications' collection of information on users; rather, it is specifically in objection to Apple's own collection of user location information.
14. Apple's iPhones and iPad 3Gs are carried with users to essentially every location they travel to, making the information collected by Apple highly personal; indeed, in many instances it may be information to which employers and spouses are not privy.
"The Class is so numerous that joinder of all members of the Class is impracticable."
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