Case 5:16-cm-00010-SP Document 177-19 Filed 03/15/16 Page 1 of 3 Page ID #:2998

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Gibson, DLl'ln &

Crutcher LLP

THEODORE J. BOUTROUS JR., SBN 132099
tboutrous@gibsondunn.com
NICOLA T:-tl'ANNA, SBN 130694
nhanna@gibsondunn.com
ERIC D. \1ANDEVELDE, SBN 240699
evandevelde(@gibsondunn.com
GIBSON,, DUNN & CRUTCHER LLP
333 Soutn Grand Avenue
Los Angeles, CA 90071-3197
Telephone: 213.229.7000
Facsimile: 213 .229.7520
THEODORE B. OLSON, SBN 38137
tolson@gibsondunn.com
1050 Connecticut Avenue~ N.W.
Washington, DC 20036-5J06
Telephone: 202.955.8500
Facsimile: 202.467.0539
MARC J. ZWILLINGER*
marc@zwillgen.com
JEFFREY G. LANDIS*
jeff@zwillg_en.com
ZWIC(GEN PLLC
1900 M Street N.W., Suite 250
Washington, D.C. 20036
Telephone: 202. 706.5202
Facsimile: 202.706.5298
*Admitted Pro Hae Vice
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
EASTERN DIVISION
IN THE MATTER OF THE SEARCH
OF AN APPLE !PHONE SEIZED
DURING THE EXECUTION OF A
SEARCH WARRANT ON A BLACK
LEXUS IS300 CALIFORNIA
LICENSE PLATE 35KGD203

ED No. CM 16-10 (SP)
DECLARATION OF CRAIG
FEDERIGHI IN SUPPORT OF APPLE
INC.'S REPLY IN SUPPORT OF
MOTION TO VACATE ORDER
COMPELLING APPLE INC. TO
ASSIST AGENTS IN SEARCH

Hearing:
March 22, 2016
Date:
1:00 p.m.
Time:
Courtroom 3 or 4
Place:
Hon. Sheri Pym
Judge:

 Case 5:16-cm-00010-SP Document 177-19 Filed 03/15/16 Page 2 of 3 Page ID #:2999

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I, Craig F ederighi, declare:

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I am over the age of eighteen years and am competent and authorized to

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make this declaration. I have personal knowledge of the facts set forth below. If

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called as a witness, I would and could testify to the statements and facts contained

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herein, all of which are true and accurate to the best of my knowledge and belief.

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2.

I have worked at Apple Inc. ("Apple") for almost ten years in total, since

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2009 and previously between 1996 and 1999. I have been Senior Vice President of

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Software Engineering for nearly four years. In that role, I oversee the development of

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Apple's iOS operating system for mobile devices as well as its OS X operating system

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for laptop and desktop computers, and also supervise Apple's common operating

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system engineering teams. Through my experience in that role, I am familiar with the

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security features of iOS.

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3.

I received a Master of Science degree in Computer Science and a

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Bachelor of Science in Electrical Engineering and Computer Science from the

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University of California, Berkeley.

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4.

Apple designed the iPhone with users' security in mind. Our customers

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rely on Apple to protect the incredibly personal information on their iPhones, which is

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under siege by criminals and other malicious actors. We have tried to make the iPhone

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as difficult as possible for third parties to hack, so that if the device falls into the wrong

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hands, the data of our customers, including individuals, businesses and governments,

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remains safe.

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5.

Apple uses the same security protocols everywhere in the world.

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6.

Apple has never made user data, whether stored on the iPhone or in

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iCloud, more technologically accessible to any country's government. We believe any

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such access is too dangerous to allow. Apple has also not provided any government

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with its proprietary iOS source code. While governmental agencies in various

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countries, including the United States, perform regulatory reviews of new iPhone

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Gibson, D1.11n &
Cru1cher LLP

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 Case 5:16-cm-00010-SP Document 177-19 Filed 03/15/16 Page 3 of 3 Page ID #:3000

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releases, all that Apple provides in those circumstances is an unmodified iPhone

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device.

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7.

It is my understanding that Apple has never worked with any government

agency from any country to create a "backdoor" in any of our products or services.

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I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed this 15th day of March 2016 in Cupertino, California.

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