1. Through its Amazon Photos service, Amazon unlawfully  collects, stores, and uses the biometric identifiers and  information of Amazon Prime members residing in  Illinois. ................................................................................................. 13  1. The rise of facial recognition through “deep learning.” ...........................8  1. The rise of facial recognition through “deep learning.”   18. In general, “facial recognition” refers to the scanning of a person’s face and  matching it against a library of facial images. Facial recognition is a type of “image  recognition”—a term that refers more broadly to computer technologies that can recognize  people, animals, objects, or other targeted subjects using algorithms and machine learning.   19. Many of the recent advances in image-recognition technologies rely “on deep  learning technology, an advanced type of machine learning and artificial intelligence.”17 Deep  learning “works by building deep neural networks that simulate the mechanism of the human  brain and then interpreting and analyzing data, such as image, video and text.”18  2. Amazon unlawfully collects, stores, and uses the biometric  information of Illinois residents who are not Prime  members but are given free Amazon Photos accounts  through the Family Vault feature. ......................................................... 17  2. Tech behemoths race to perfect image-recognition  technology via deep learning. .................................................................9  20. Unlike other machine-learning algorithms, “[d]eep learning networks do not  require human intervention because the nested algorithms run the data through different  concepts which eventually learn from their own mistakes.”19 Thus, “[d]eep learning is suitable  for instances where there are boatloads of data to analyze or complex problems to solve.”20  3. Amazon unlawfully collects, stores, and uses the biometric  identifiers and information of Illinois residents who have  never used Amazon Photos, most of whom are unaware  that Amazon has their biometric data. ................................................... 18 C. Amazon Rekognition has raised civil-liberty and privacy concerns  among civil-rights groups, members of Congress, and Amazon’s  own employees and shareholders. .................................................................... 21 D. Amazon unlawfully collected, stored, and used Plaintiff’s  biometric identifiers and information through Amazon Photos. ........................ 23 V. 3. Amazon makes facial-recognition technology available to  consumers through Amazon Photos and to businesses and  governmental entities through Rekognition. .......................................... 10 B. Amazon Photos ................................................................................................ 13  A. Deep learning, big tech, and the road to Rekognition.   A. Deep learning, big tech, and the road to Rekognition..........................................8  ANGELA HOGAN, individually and on behalf  of all others similarly situated,  Plaintiff,  v. 