Revolv Inc.'s actions, and that unilaterally rendering the devices inoperable would cause unjustified, substantial consumer injury that consumers themselves could not reasonably avoid.”).3 US v. Verkada Inc., Case No.: 3:24-cv-06153 (N.D. Cal. Sept. 4, 2024) (Stipulated Order for Permanent Injunction, Civil Penalty Judgment, And Other Equitable Relief).4 In the Matter of The Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things, Docket No. 160331306-6306-01 (Comments of the Staff of the Federal Trade Commission’s Bureau of Consumer Protection and Office of Policy Planning, Jul. 2, 2016).5 This Alert does not address any state or federal laws or certification programs generally relating to the cybersecurity of IoT devices. See, e.g., California Internet of Things Cybersecurity Improvement Act of 2017, Cal. Civ. Code § 1798.91.04 (Jan. 1, 2023); O. R. S. § 646A.813 (Nov. 15, 2019); FCC US Cyber Trust Mark Labelling Program, 88 Fed. Reg. 58211-01 (Aug. 25, 2023) and related rules adopted by Report and Order, FCC 24-26 (Mar. 15, 2024).