All individuals and business entities in Québec who owned or leased an iPhone SE, 5, 6, 7 and their sub-series (hereinafter collectively referred to as the “Subject iPhones”) and have updated their iPhones to iOS 10 and iOS 11 or later versions of iOS, or any other group to be determined by the Court.

The nature of the class action brought by the plaintiff on behalf of the class members is a class action against Apple inc. and Apple Canada inc, for price reduction, and for pecuniary and punitive damages.

Mr. St-Onge is asking the Court to determine notably whether the Subject iPhones slowed down significantly, began to shut down abruptly, or froze after updating to iOS 10 and iOS 11 or later versions of iOS, and whether Apple knew (or should have known) and failed to warn class members that the functionality and/or the performance of the Subject iPhones would be negatively affected by the update. The Court will have to determine whether Apple is liable to pay damages to class members and, if so, in what amounts.

The main relief sought by the representative against the defendants can be summarized as follows:

• The payment of a sum to be determined, to cover the following reimbursements :

1. 1. The cost of replacing the iPhone SE, and the iPhone 5, 6, 7 and their sub-series and/or
   2. The cost of the protection plans and/or
   3. The cost of the replacement batteries and/or
   4. Other economic damages.

• The payment of punitive damages in a sum to be determined;
• An order from the Court to cease the wrongful conduct.