Vtech electronics na llc

Vtech electronics na llc DEFAULT

V.Smile Cyber Pocket - VTech

Dear Parent,

Parent letter

VTech®, with the introduction of our V.SMILE CyberPocket, offers parents a fun, healthy alternative

to the world of hand-held video games. We know that children enjoy the “big kid” feeling that comes

with owning one’s very own hand-held system, and we also understand parents’ reluctance to put

these toys into their children’s hands. Children want more independent play as they get older, and

parents want to feel comfortable that this play is providing healthy, fun and educational benefits to

their children.

With V.SMILE CyberPocket – an educational hand-held video game system designed for kids over

5-years-old – VTech ® continues its tradition of providing unique and fun alternatives to the existing

video game systems. The V.SMILE CyberPocket combines age-appropriate educational content with

high-tech graphics and fun game play to provide a state-of-the-art experience that kids and parents will both

love. Also, V.SMILE CyberPocket can be played both on-the-go as a hand-held unit, or plugged directly into

your TV for a shared, at-home game play experience.

Both the V.SMILE CyberPocket and the V.SMILE TV Learning System work with the full library

of VTech ® Smartridges , each based on popular children’s characters that engage and encourage your

child to play while learning. The library continues to grow, as VTech ® seeks to provide parents with

an almost endless selection of wholesome video games that meet the individual needs and likes of

their children.

At VTech ® we are proud to provide you with a much-needed solution to the video game dilemma, as

well as another innovative way for your child to learn while having fun. We thank you for trusting

VTech ® , with the important job of helping your child explore a new world of learning!

Sincerely,

Julia Fitzgerald

Vice President, Marketing

Vtech Electronics, NA

Your Friends at VTech ®

To learn more about the V.SMILE CyberPocket and other VTech ® toys, visit www.vtechkids.com


table of contents

Introduction............................................................................. 1

• Included in this package.............................................................. 1

Product Features ................................................................... 2

• V.SMILE CyberPocket Features ................................................ 2

• Direction and enter button left / right reverse switch................... 3

Wearing the Wrist Strap...................................................... 4

Getting Started........................................................................ 4

• Battery installation....................................................................... 4

• Battery notice.............................................................................. 4

• AC Adaptor.................................................................................. 5

• Standard guidelines for adaptor toys .......................................... 6

To Begin Play .......................................................................... 6

• Connecting to a TV ..................................................................... 6

Care & Maintenance ............................................................. 7

Troubleshooting .................................................................... 8

Technical support .................................................................. 9

Other info.................................................................................. 10

• Disclaimer and limitation of liability............................................. 10


Thank you for purchasing the VTech ® V.SMILE CyberPocket!

This unique handheld video game device was created especially for young

players. With the VTech ® V.SMILE CyberPocket, children can play

exciting, educational games on the go, or plug the V.SMILE CyberPocket

directly into a TV for great at-home play. They can also use the included

V.Link to upload their scores to a secure web site and unlock additional

fun bonus games online!

User’s Manual

IntroductIon

V.SMILE CyberPocket

V.LINK

Included in this package

V.LINK Manual

Wrist Strap

Smartridge

AV Cable

4AA batteries

Smartridge Manual

• One VTech ® V.SMILE CyberPocket

• One V.LINK

• One Smartridge and Smartridge Manual

• One AV Cable

• One Wrist Strap

• One V.SMILE CyberPocket and one V.Link User’s Manual.

• 4 “AA” heavy duty batteries included. Alkaline batteries are recommended

for longer life and optimum performance.

WARNING: All packing materials such as tape, plastic sheets, wire ties,

vacuum form and tags are not part of this toy and should be

discarded for your child’s safety.


Product features

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24


The V.SMILE CyberPocket accommodates both right and left-handed players.

To switch the ENTER and DIRECTION buttons from one side to the other:

• Slide up the switch on the back of the unit as shown in the diagram.

• Roll the DIRECTION and ENTER buttons from up to down until you hear

and feel a locking sound. The DIRECTION and ENTER buttons will now

appear on opposite sides from where you started.

• To return the buttons to their original positions, perform this same

maneuver again.

back of the unit


WearIng the WrIst straP

Attach the wrist strap to the V.SMILE CyberPocket and then use the strap

to secure the V.SMILE CyberPocket to your wrist when playing.

gettIng started

battery Installation

• Make sure the unit is turned OFF.

• Locate the battery cover on the back of the

unit.

• Locate and remove the battery cover on the

back of the unit as indicated in the diagram.

• Insert 4 X1.5v SIZE AA UM-3 OR LR6 batteries

as indicated in the diagram.

• Make sure to replace the battery cover.

battery notice

• Install batteries correctly observing the polarity (+, -) signs to avoid

leakage.

• Do not mix old and new batteries.

• Do not mix batteries of different types: alkaline, standard (carbon-zinc)

or rechargeable (nickel-cadmium).


• Remove the batteries from the equipment when the unit will not be

used for an extended period of time.

• Always remove exhausted batteries from the equipment.

• Do not dispose of batteries in fire.

• Do not attempt to recharge ordinary batteries.

• The supply terminals are not to be short-circuited.

• Only batteries of the same and equivalent type as recommended are

to be used.

WE DO NOT RECOMMEND THE USE OF RECHARGEABLE BATTERIES.

NOTE: When the V.SMILE CyberPocket is

running on batteries, you may see this

icon appear on the screen . This

indicates that battery power is low,

and you should replace the batteries

soon. Battery time remaining once

the icon first appears is approximately

10-30 minutes, depending on the type

of batteries in use. After that, the

handheld will show the screen on the

right for 5 seconds, and then will turn

OFF automatically.

ac adaptor

• Use a standard 9V 300mA AC/DC adaptor. We recommend the

use of a VTech ® 9V AC/DC adaptor.

• Make sure the unit is turned OFF.

• Plug the power jack into the 9V socket at the lower part of the

handheld.

• Plug the AC adaptor into a wall socket.

NOTE: The use of an adaptor will override the batteries. When the toy is

not going to be in use for an extended period of time, unplug the

adaptor.


standard guidelines for adaptor toys

• The toy is not intended for use by children under 3 years old.

• Only use the recommended adaptor with the toy.

• The transformer is not a toy.

• Never clean a plugged-in toy with liquid.

• Never use more than one adaptor.

• Do not leave the toy plugged-in for extended periods of time.

to begIn PlaY

• Make sure the V.SMILE CyberPocket is turned

OFF and TV cable is disconnected.

• Insert the Smartridge with the label side facing

front, to assure that it is inserted correctly as

shown in the diagram.

• Press the ON button to begin.

connecting to a tV

• Make sure the handheld and TV are turned OFF.

• Insert the Smartridge with the label side facing front.

• Connect the AV cable plug to the TV jack on the handheld.

- Connect the yellow plug on the V.SMILE CyberPocket cable

to the yellow video input terminal on your TV.

- Connect the white plug on the V.SMILE CyberPocket cable

to the white audio input terminal on your TV.

yellow white

• Turn on the TV.

• Set your TV mode to accept input from the port in which your V.SMILE

CyberPocket is connected. In some cases this will involve setting the

TV to “video” mode. However, since all TVs vary, please refer to your TV

manual for further details.

• Turn the V.SMILE CyberPocket on by pressing the ON button.

• When the handheld is properly connected, the TV indicator light will come on.


1. Keep your V.SMILE CyberPocket clean by wiping it with a slightly damp

cloth. Never use solvents or abrasives.

2. Keep it out of direct sunlight and away from direct sources of heat.

3. Remove the batteries when not using it for an extended period of time.

4. Avoid dropping it. Never try to dismantle it.

5. Always keep the V.SMILE CyberPocket away from water.

6. Please examine the toy transformer periodically for conditions that

may result in the risk of fire, electric shock, or injury to persons(such as

damage to the output cord, blades, housing, or other parts) and that, in

an event of such conditions, the transformer should not be used until

properly repaired.

WarnIng

care & MaIntenance

A very small percentage of the public, due to an existing condition, may experience

epileptic seizures or momentary loss of consciousness when viewing certain types

of flashing colors or patterns, especially on television. While the V.SMILE Cyber

Pocket does not contribute to any additional risks, we do recommend that parents

supervise their children while they play video games. If your child experiences

dizziness, altered vision, disorientation, or convulsions, discontinue use immediately

and consult your physician.

Please note that focusing on a television and LCD screen at close range and handling

joystick controls for a prolonged period of time may cause fatigue or discomfort. We

recommend that children take a 15 minute break for every hour of play.


troubleshootIng


technIcal suPPort

• If you have a problem that cannot be solved by using this manual, we

encourage you to visit us online or contact our Consumer Services

Department with any problems and/or suggestions that you might have.

A support representative will be happy to assist you. Before requesting

support, please be ready to provide or include the information below:

• The name of your product or model number (the model number is typically

located on the back or bottom of your product).

• The actual problem you are experiencing.

• The actions you took right before the problem occurred.

Internet : www.vtechkids.com

Phone : 1-800-521-2010 in the U.S. or 1-877-352-8697 in Canada


other Info

disclaimer and limitation of liability

VTech® Electronics North America, L.L.C. and its suppliers assume no

responsibility for any damage or loss resulting from the use of this handbook.

VTech® Electronics North America, L.L.C. and its suppliers assume no

responsibility for any loss or claims by third parties that may arise through

the use of this software. VTech® Electronics North America, L.L.C. and

its suppliers assume no responsibility for any damage or loss caused by

deletion of data as a result of malfunction, dead battery, or repairs. Be

sure to make backup copies of important data on other media to protect

against data loss.

Company: VTech® Electronics North America, L.L.C.

Address: 1155 West Dundee Rd., Suite 130, Arlington Heights, IL 60004 USA

Phone : 1-800-521-2010 in the U.S. or 1-877-352-8697 in Canada

Notice: This equipment has been tested and found to comply with the

limits for a Class B digital device, pursuant to Part 15 of the FCC Rules.

These limits are designed to provide reasonable protection against harmful

interference in a residential installation. This equipment generates, uses

and can radiate radio frequency energy and, if not installed and used in

accordance with the instructions, may cause harmful interference to radio

communications. However , there is no guarantee that interference will

not occur in a particular installation. If this equipment does cause harmful

interference to radio or television reception, which can be determined by

turning the equipment off and on, the user is encouraged to try to correct

the interference by one or more of the following measures:

• Reorient or relocate the receiving antenna.

• Increase the separation between the equipment and receiver.

• Connect the equipment into an outlet on a circuit different from that

to which the receiver is connected.

• Consult the dealer or an experienced radio/TV technician for help.

Caution : Changes or modifications not expressly approved by the party

responsible for compliance could void the user’s authority to

operate the equipment.

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Magazine: V.Smile Cyber Pocket - VTech

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IN RE VTECH DATA BREACH LITIGATION

MEMORANDUM OPINION AND ORDER

MANISH S. SHAH, District Judge.

Defendant VTech Electronics North America, LLC manufactures and markets digital learning toys for children. Plaintiffs purchased some of those toys, which came with access to certain online services. Use of the online services required plaintiffs to provide VTech with personally identifiable information about them and their children. VTech's inadequate data-protection measures allowed a hacker to access and download plaintiffs' personal information. As a result, VTech suspended its online services. Plaintiffs seek to represent a class of consumers and bring suit under theories of breach of contract, breach of the implied warranty of merchantability, violation of the Illinois Consumer Fraud and Deception Act, and unjust enrichment. VTech moves to dismiss the second consolidated amended complaint. For the following reasons, the motion is granted.

I. Legal Standards

A complaint must contain factual allegations that plausibly suggest a right to relief. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). I must accept as true all of the facts alleged in the complaint and draw reasonable inferences from those facts in plaintiffs' favor, but I am not required to accept as true the complaint's legal conclusions. Id. at 678-79. In considering a motion to dismiss under Rule 12(b)(6), I review the complaint, exhibits attached to the complaint, and, if they are central to the claims, documents referenced by the complaint. Otis v. Demarasse, ___F.3d____, 2018 WL 1571916, at *5 n.33 (7th Cir. Apr. 2, 2018).

II. Facts

VTech makes and distributes digital learning toys for young children, including tablets, smartwatches, and other handheld learning systems. [94] ¶ 2. Plaintiffs are eight adults who purchased VTech toys for their children. [94] ¶¶ 74-131. Some VTech toys have access to the Learning Lodge, which is an online application store where toy-users can purchase and download software for their toys. [94] ¶¶ 3, 34. Learning Lodge is also where users install updates to the operating system software and previously installed applications. [94] ¶ 35. Some VTech toys also support Kid Connect, an online communications platform that allows children to use their Kid Connect-enabled toys to communicate with their parents' cell phones. [94] ¶¶ 3, 40. Toys that are able to access these online services—Learning Lodge and Kid Connect—are priced at a premium over toys that are not able to access the online services. [94] ¶¶ 30, 32, 41. Each plaintiff purchased toys that were able to access online services—either Learning Lodge, Kid Connect, or both. [94] ¶¶ 74-131.

If a customer buys an online services-enabled toy, access to the online services is not automatic. Users have to register for an online account with VTech, which requires providing personally identifiable information like name, home address, email address, password, and credit or debit card information. [94] ¶ 42. After an adult registers for an online account, children create profiles with their names, passwords, birthdates, genders, and photographs. [94] ¶ 43. In addition to account creation, users must also affirmatively agree to VTech's terms and conditions (there are separate terms for Learning Lodge and Kid Connect) before using the online services. [94] ¶ 48. The online services terms incorporate VTech's Privacy Policy. [94] ¶ 48. In the Privacy Policy, VTech promised to keep their customers' personally identifiable information secure, including by transmitting data in an encrypted format and storing the data where it would not be accessible by the internet. [94] ¶¶ 48-49.

But in 2015, a hacker penetrated VTech's systems, obtaining the data of millions of VTech's customers. [94] ¶ 51. The hacker acquired parents' names, email addresses, and account password information as well as children's names, genders, birthdates, and photos. [94] ¶ 52. The hacker also obtained the messages that children and their parents exchanged in Kid Connect and on Kid Connect's family bulletin board feature. [94] ¶ 52. The hacker's breach was made possible by VTech's inadequate data-protection measures. [94] ¶ 56. He was able to gain access to the VTech database through its website. [94] ¶ 57. It also turned out that VTech did not use encryption to transmit its customers' data. [94] ¶ 58. As VTech itself stated, the databases were "not as secure as [they] should have been." [94] ¶ 55. VTech found out about the cybersecurity breach from a news organization. [94] ¶ 62. Four days later, VTech issued a press release informing the public of the breach. [94] ¶ 63. VTech also suspended access to the online services. [94] ¶ 6.

Plaintiffs brought several suits against VTech, which have been consolidated into this action. [43]. I dismissed the first consolidated amended complaint for the failure to state a claim. [87]. VTech now moves to dismiss the second consolidated amended complaint, arguing that plaintiffs have failed to state a claim for the second time.

III. Analysis

A. Breach of Contract (Counts I-II)

Plaintiffs allege that they entered into contracts with VTech when they purchased their toys. And, as part of that exchange, VTech promised plaintiffs two things—(1) that plaintiffs would have access to the online services "without meaningful interruptions" and (2) that VTech would use "effective and industry-standard security measures" to protect plaintiffs' data. [94] ¶¶ 150, 163. Plaintiffs have not been clear about what contracts are the source of the promises they allege, but their claims appear to involve three groups of contracts: (1) purchase contracts, created at the time each plaintiff bought her VTech toy; (2) the Terms and Conditions of Learning Lodge and Kid Connect, agreed to when plaintiffs registered for the online services; and (3) VTech's Privacy Policy, incorporated by reference into the online services terms and deemed accepted by use of the online services. Plaintiffs appear to rest their breach of contract claims on the purchase contracts. See [94] ¶¶ 149-50, 162-63.

Plaintiffs have not labeled the purchase contracts as express or implied, but the allegations show that they must be implied. Illinois recognizes contracts that are implied in fact, meaning contracts in which there is no express written or oral contract, but the facts and circumstances show that the promisor meant to be bound by a promise. Marcatante v. City of Chicago, Ill., 657 F.3d 433, 440 (7th Cir. 2011). Or more simply, the promisor did not expressly promise anything, but the promise was implied. An implied-in-fact contract is "a true contract, containing all necessary elements of a binding agreement; it differs from other contracts only in that it has not been committed to writing or stated orally in express terms, but rather is inferred from the conduct of the parties in the milieu in which they dealt." Id. (citation omitted). The complaint makes no allegations that the terms of the purchase contracts were written, nor does it allege that VTech and plaintiffs made an oral contract. Rather, plaintiffs describe VTech's actions—offering products for sale (with particular statements on the packaging)—and plaintiffs' actions— "purchasing and using the VTech Products and the Online Services," [94] ¶¶ 149, 162—and infer that a contract arose from those actions. That would be an implied contract, not an express one.

VTech's lead argument for dismissing both the online services and data-security theories of breach is that plaintiffs did not plead "facts sufficient to demonstrate that the initial purchase transaction included both the hardware device and the Online Services." [101] at 18 (emphasis omitted). This argument is based on my opinion on the first motion to dismiss. On the first go-round, I dismissed plaintiffs' breach of contract claims because the claims hinged on the initial purchase transaction including both the toy and the online services, and I found that the complaint did not allege sufficient facts to show that the initial purchase encompassed a contract for online services. [87] at 18-22. Plaintiffs are right that they have fixed that issue, particularly by including photos of the toys' packaging in the new complaint. See [94] ¶¶ 25-28, 32. The photos show that the toys' packaging included references to Learning Lodge and Kid Connect that suggested access to the online services was part of the deal upon purchase, not just an addition available later. But there are other problems with the complaint.

1. Access to Online Services

Plaintiffs allege that as part of the purchase contracts, VTech promised to provide "access to and use of the Online Services without meaningful interruptions," [94] ¶¶ 150, 163, and that it broke this promise by suspending access to the online services. [94] ¶¶ 155, 168. But this alleged promise is not governed by the terms of the implied purchase contracts, it is governed by the express online services terms. "As in physics, two solid bodies cannot occupy the same space at the same time, so in law and common sense, there cannot be an express and implied contract for the same thing, existing at the same time." Gadsby v. Health Ins. Admin., Inc., 168 Ill.App.3d 460, 470 (1988) (citation omitted). Where an express contract exists on the same subject-matter as an implied contract, the implied contract cannot exist. Marcatante, 657 F.3d at 440. The online services terms cover the same subject-matter as the alleged implied contracts—the provision of online services. So the online services terms are the contracts that control, not any implied contract formed at the time of purchase. And plaintiffs have not alleged a breach of the express online services terms.

Even if plaintiffs had alleged a breach of the online services terms, both the Learning Lodge terms and Kid Connect terms contain provisions that allow VTech to terminate the services at any time and without providing prior notice. [94-2] § 7.3; [94-3] § 2.7. Plaintiffs argue that these provisions are procedurally and substantively unconscionable, mostly because the online services terms added those provisions after plaintiffs had already bought their toys. As they put it, "[t]o hold these terms are enforceable would simply enable VTech to continue making promises to customers at the time of purchase, get them to pay for that promise, and then retract those promises once the consumer gets home and opens the product they purchased, while keeping the premium the customers paid for itself." [104] at 23 (citations omitted) (emphasis in original). Plaintiffs' characterization of the contract—an initial purchase contract later supplemented or amended by the online services terms—is incorrect. The express online services terms negate the existence of any implied purchase contract terms about the provision of online services. See Maness v. Santa Fe Park Enterprises, Inc., 298 Ill.App.3d 1014, 1023 (1998) ("[E]xpress contracts negate the existence of any implied in fact contract."). So VTech did not contractually promise to provide online services and then take back the promise after plaintiffs had already purchased their toys—rather, the parties mutually vacated their implied agreement by entering into an express one. There is no indication that plaintiffs did not have a full and fair opportunity to review the online terms before they agreed to them. So the provisions that allowed VTech to terminate the online services at any time are not unconscionable, and VTech was within its rights to suspend plaintiffs' access to the online services.

Plaintiffs also argue that VTech's interpretation of the online services terms as allowing VTech "unilateral, unfettered discretion to decide whether to provide the Online Services at all" would render the contracts illusory and unenforceable. [104] at 21. But instead of asking for a finding that the contracts are unenforceable, plaintiffs interpret the provisions at issue to mean "that VTech cannot be held liable for occasional outages (e.g., for software updates) or for discontinuing the Online Services many years after purchase." [104] at 21. Plaintiffs' interpretation of the terms of service is not consistent with its language, but even if I adopted plaintiffs' interpretation, there is no allegation that VTech breached the contract: the suspension of Learning Lodge and Kid Connect very well may qualify as an "occasional outage."

VTech also argues that the limitations of liability contained in the online services terms preclude plaintiffs' claims. Although I need not reach this argument, it remains true that the limitation of liability provisions in the online services terms disclaim liability for damages relating to the use of Learning Lodge and Kid Connect. See [87] at 21-22.

2. Data-Protection Measures

Plaintiffs claim that at the time of purchase, VTech promised plaintiffs "the implementation of effective and industry-standard security measures for the PII submitted through the Online Services," [94] ¶¶ 150, 163, and that VTech broke that promise. Once again, this breach is based on an implied purchase contract. See [94] ¶¶ 149-50, 162-63. And, once again, express contracts exist on the same subject-matter—the Privacy Policy and the online services terms. [94-2] § 6.1; [94-3] § 11; [94-4]. So plaintiffs' breach of contract based on the implied contract cannot exist. Plaintiffs have not alleged a breach of the express Privacy Policy or online services terms. VTech's motion to dismiss Counts I and II is granted.

B. Breach of Implied Warranty of Merchantability (Counts III-IV)

Plaintiffs allege that VTech breached the implied warranty of the merchantability of its toys. To succeed on such a claim in Illinois, plaintiffs must allege "(1) a sale of goods (2) by a merchant of those goods, and (3) [that] the goods were not of merchantable quality." Brandt v. Boston Sci. Corp., 204 Ill.2d 640, 645 (2003).

VTech argues that plaintiffs' claims involve services, not goods. Everyone agrees that the toys alone are goods and the online services alone are not. So the question is whether the toys and online services were completely separate or mixed and, if mixed, whether the mix of the two is more of a good or a service. Plaintiffs have sufficiently alleged that the purchase of the toys came with access to online services. This is apparent from the packaging, which emphasizes the access to online services. See [94] ¶¶ 25-28, 32. Because plaintiffs' claim involves a mix of goods and services, it may proceed under the UCC only if the transaction was "predominantly for goods and incidentally for services." Brandt, 204 Ill.2d at 645. As plaintiffs convincingly point out, one could apparently purchase the toy without the online services, but one could not purchase the online services without the toy. [94] ¶ 38; [104] at 25-26. Indeed, the online services would be useless without the toy. This establishes that the sale predominately involved goods.

VTech also argues that plaintiffs have not established that anything is wrong with the toys themselves. Illinois law provides several requirements for a good to be merchantable, three of which plaintiffs rely on—the goods must "pass without objection in the trade under the contract description," be "fit for the ordinary purposes for which such goods are used," and "conform to the promises or affirmations of fact made on the container or label if any." 810 ILCS 5/2-314(2). Plaintiffs did not adequately plead a breach of any of the three. As to whether the toys "pass without objection in the trade under the contract description," plaintiffs have not alleged what the contract description is or why the toys would be objectionable in the trade. Nor does the complaint contain any allegations of what the "ordinary purposes" of the toys were or how the toys were not fit for those ordinary purposes. The complaint's descriptions of the products—like the tablets that "provide an array of uses including interaction learning and video gaming" and the smartwatches that have "cameras, educational software and motion sensors", [94] ¶ 37—actually seem to accurately describe what plaintiffs got. If the ordinary purposes of the toys were somehow more than that, plaintiffs needed to plead that.

Nor does the complaint suggest that the toys did not meet the promises made on their packaging. The photos of the packaging show that VTech represented that the tablet would have access to Learning Lodge, be capable of communication via Kid Connect, include a one-year subscription to Kid Connect, and come with two free downloadable apps from the Learning Lodge store. But the complaint does not adequately allege that those promises were not kept. VTech suspended access to Learning Lodge and Kid Connect, but the complaint does not allege that those services were never restored. Plaintiffs do not claim that any of them could never get their two free apps from Learning Lodge or subscription to Kid Connect, or that their toys could never access the online services. Instead, plaintiffs claim that VTech broke a promise by interrupting their access to the online services, but that reads in an extra promise onto the packaging—that the online services would be provided without any interruption. The packaging does not say that.

Finally, plaintiffs have not sufficiently alleged privity, which is required for an implied warranty claim. See Mekertichian v. Mercedes-Benz U.S.A., L.L.C., 347 Ill.App.3d 828, 832 (2004) ("[T]he UCC article II implied warranties give a buyer of goods a potential cause of action only against his immediate seller." (citation omitted)). Plaintiffs argue that the "direct relationship" exception to the privity requirement applies, because VTech directly marketed its toys to them and plaintiffs relied on the advertisements. Illinois has recognized an exception to the privity requirement "where there is a direct relationship between the manufacturer and the seller." Frank's Maint. & Eng'g, Inc. v. C. A. Roberts Co., 86 Ill.App.3d 980, 992 (1980). Plaintiffs point to recent federal cases that have interpreted the "direct relationship" exception as applying to circumstances in which manufacturers advertise directly to consumers. See Elward v. Electrolux Home Prod., Inc., 214 F.Supp.3d 701, 705 (N.D. Ill. 2016); In re Rust-Oleum Restore Mktg., Sales Practices & Prod. Liab. Litig., 155 F.Supp.3d 772, 807 (N.D. Ill. 2016). I am not persuaded that the Illinois Supreme Court would conclude that advertising alone creates a direct relationship between a manufacturer and a customer (and no such binding authority has been cited), especially where, as here, there is no allegation that a plaintiff viewed a particular representation in an ad and relied on the representation in making the purchase.

In any event, as VTech asserts, the pleaded marketing is not sufficient because the advertisements did not contain an express warranty of data security. That is to say, in In re Rust-Oleum, plaintiffs' merchantability claims arose from their reliance on the representations in the advertisements and marketing that supported application of the direct relationship exception. 155 F.Supp.3d at 807. But here, plaintiffs could not have reasonably relied on the "kid safe" representations as a promise of cybersecurity, because those representations were not related to the kind of cybersecurity at issue in the complaint. And though plaintiffs alleged that they relied on VTech's representations about the safety of their products, [94] ¶¶ 217, 249, plaintiffs did not allege that they relied on marketing representations that the toys would come with access to the online services. The direct marketing did not put the parties in privity for the implied warranty of merchantability.

VTech's motion to dismiss Counts III and IV is granted. Because plaintiffs have already had an opportunity to amend their complaint and further amendment of the claims in Counts I through IV would be futile, the claims are dismissed with prejudice.

C. Violation of the Illinois Consumer Fraud and Deceptive Business Practices Act (Counts V-VI)

As its name implies, the ICFA prohibits, among other things, "[u]nfair or deceptive acts or practices . . . in the conduct of any trade or commerce." 815 ILCS 505/2. The elements of a claim under the statute are: "(1) a deceptive act or practice by the defendant; (2) the defendant intended that the plaintiff rely on the deception; (3) the deceptive act occurred in a course of conduct involving trade or commerce; and (4) actual damage to the plaintiff; (5) proximately caused by the deceptive act." Philadelphia Indem. Ins. Co. v. Chicago Title Ins. Co., 771 F.3d 391, 402 (7th Cir. 2014) (citing De Bouse v. Bayer AG, 235 Ill.2d 544, 550 (2009)). Although these elements refer to deceptive conduct, they also apply to unfair conduct. Id.

VTech argues that plaintiffs have only alleged deceptive conduct in the complaint, but plaintiffs argue that they have alleged both deceptive and unfair conduct. Allegations of deceptive and unfair conduct are subject to different pleading standards. Federal Rule of Civil Procedure 9(b) requires a heightened pleading standard for allegations of fraud, and deceptive acts often sound in fraud. See Camasta v. Jos. A. Bank Clothiers, Inc., 761 F.3d 732, 737 (7th Cir. 2014); Pirelli Armstrong Tire Corp. Retiree Med. Benefits Tr. v. Walgreen Co., 631 F.3d 436, 446-47 (7th Cir. 2011). If Rule 9(b) applies, the "who, what, when, where, and how" of the fraud must be alleged with particularity. U.S. ex rel. Lusby v. Rolls-Royce Corp., 570 F.3d 849, 853 (7th Cir. 2009). On the other hand, a claim alleging unfair practices is governed by the more relaxed pleading standards of Rule 8. Pirelli, 631 F.3d at 446.

Plaintiffs allege only deceptive conduct. The ICFA claims are primarily based on VTech's alleged misrepresentations that its toys were safe and secure, and the corresponding failure to disclose that the toys were not safe—a course of conduct that is deceptive. Plaintiffs do not allege any separate conduct that is unfair. The complaint's attempt to explain how VTech's actions were also unfair just contains more allegations about VTech's promotion of its products as "safe" despite not implementing basic data protections. See [94] ¶¶ 226, 258. "Simply adding language of `unfairness' instead of `misrepresentation' does not alter the fact that [plaintiffs'] allegations are entirely grounded in fraud under the ICFA." Camasta, 761 F.3d at 737. Plaintiffs also argue that they have alleged unfair conduct by pleading that VTech disregarded its ethical duty (and statutory duty, under the Children's Online Privacy Protection Act) to protect its customers' information and by pleading that VTech harmed its customers in a way that the customers could not avoid and without any countervailing benefit to the customers. But this misses the issue. It is not that the alleged conduct is not unfair; it is that the alleged unfair conduct completely overlaps with the deceptive conduct. For example, plaintiffs allege that VTech's violation of COPPA constituted "unlawful, unfair, and deceptive acts." [94] ¶¶ 229, 261. Illinois law allows plaintiffs to predicate ICFA unfairness claims on violations of other statutes (even if the violated statutes do not allow for private enforcement), Gainer Bank, N.A. v. Jenkins, 284 Ill.App.3d 500, 503 (1996), but plaintiffs cannot rely on the same conduct to establish separate unfair and deceptive theories under the ICFA. See Camasta, 761 F.3d at 737; Halperin v. Int'l Web Servs., LLC, 123 F.Supp.3d 999, 1007 (N.D. Ill. 2015). Even if a violation of COPPA did constitute separate conduct from the alleged misrepresentations and omissions, plaintiffs have not sufficiently pleaded that VTech violated COPPA. The allegation that "VTech's retention and collection policies did not comply with COPPA," [94] ¶¶ 229, 261, is a legal conclusion. Plaintiffs have not alleged any unfair conduct separate from the deceptive conduct, and so Rule 9(b)'s heightened pleading requirement applies.

To meet the standard for a claim of misrepresentation, the complaint must state "the identity of the person making the misrepresentation, the time, place and content of the misrepresentation, and the method by which the misrepresentation was communicated to the plaintiff[s]." U.S. ex rel. Grenadyor v. Ukrainian Vill. Pharmacy, Inc., 772 F.3d 1102, 1106 (7th Cir. 2014). But plaintiffs instead allege their claims generally. Although plaintiffs' focus on "on-box misrepresentations" in their briefing, [104] ¶ 30, it is not clear what specific misrepresentations plaintiffs rely on. The complaint suggests that the misrepresentations may come from three places—the Privacy Policy, the toys' packaging, and VTech's advertisements and marketing—but it does not connect the alleged misrepresentations to the plaintiffs. Not only does the complaint not allege when plaintiffs saw the Privacy Policy, packaging, or advertisements, it does not allege that plaintiffs ever saw them. See De Bouse, 235 Ill.2d at 555 ("[W]e have repeatedly emphasized that in a consumer fraud action, the plaintiff must actually be deceived by a statement or omission. If there has been no communication with the plaintiff, there have been no statements and no omissions."). See also In re Sears, Roebuck & Co. Tools Mktg. & Sales Practices Litig., No. 05 C 2623, 2009 WL 937256, at *6 (N.D. Ill. Apr. 6, 2009) (dismissing consumer fraud claim where plaintiffs did not allege that they saw the alleged misrepresentations or when they saw the misrepresentations). Instead, the complaint generally alleges that "[b]ecause of VTech's express and implied representations, [plaintiffs] reasonably believed that [their] PII and [their children's] PII would be secure," [94] ¶¶ 75, 81, 88, 96, 103, 109, 117, 125, without alleging what specific representations each plaintiff saw and when and where they saw them. That does not meet Rule 9(b)'s pleading requirements.

This lack of particularity is also fatal to plaintiffs' omissions theory of fraud. Plaintiffs allege that VTech failed to disclose a number of its data-protection practices, including its practices of storing passwords as simple "unsalted hashes," storing account-recovery secret questions as plain text, failing to use encryption when it transmitted data, failing to encrypt stored data, and others. [94] ¶¶ 219, 251. But plaintiffs did not plead where these facts should have been disclosed, which is insufficient to meet the bar set by Rule 9(b). See Carroll v. Fort James Corp., 470 F.3d 1171, 1174 (5th Cir. 2006) (Misrepresentation by omission "typically requires the claimant to plead the type of facts omitted, the place in which the omissions should have appeared, and the way in which the omitted facts made the representations misleading." (citation omitted)); Rowe v. Bankers Life & Cas. Co., No. 09-CV-00491, 2010 WL 3699928, at *6 (N.D. Ill. Sept. 13, 2010); FujisawaPharm. Co. v. Kapoor, 814 F.Supp. 720, 727 (N.D. Ill. 1993). Even if I assume that plaintiffs imply that the data security details were omitted from the Privacy Policy (or the toys' boxes or advertisements), plaintiffs still did not plead if or when they saw it and so the omissions alone would still be insufficient to adequately plead fraud.

To the extent plaintiffs' consumers fraud claims are based on VTech's representations that its toys are "kid safe," they fail for another reason—plaintiffs have not adequately pleaded falsity. VTech argues that plaintiffs misconstrue the phrases "kid safe" and "kid friendly" to refer to data security, when in fact they refer to parental controls that allow parents to restrict their children's access to inappropriate content on the internet. VTech points to the complaint itself as evidence that its interpretation is the correct one:

[101] at 22. Plaintiffs argue that VTech's interpretation of the phrases is too narrow. For example, the complaint includes a photo of a toy's package that says, "Kid-Safe Wi-Fi Connection," [94] ¶ 27, and plaintiffs argue that parents could reasonably interpret that phrase to mean VTech would provide basic data protection.

Plaintiffs have not sufficiently alleged deception with respect to the "kid safe" misrepresentations, because they have not alleged that the products were not "kid safe." I am mindful that, as plaintiffs note, reasonable inferences are to be drawn in plaintiffs' favor when resolving this motion. But plaintiffs' interpretation of the "kid safe" representations is not a reasonable one. Most of the "kid safe" references clearly speak to child-appropriate content. The phrase "Kid-Safe Wi-Fi Connection" is not deceptive either. There are no allegations that the children's Wi-Fi connections were not safe or secure. Plaintiffs allege issues with VTech's data-storage and encryption practices, but that is separate from the safety of the children's Wi-Fi connections. The hacker breached VTech's databases, not the children's Wi-Fi connections. Plaintiffs have not pleaded allegations to show that VTech's toys were not "kid safe."

VTech's motion to dismiss Counts V and VI is granted. The claims are dismissed without prejudice.

D. Unjust Enrichment

Plaintiffs base their unjust enrichment claim on a familiar argument—that VTech represented that its products were "safe" for children, but the toys were not safe because VTech did not implement basic cybersecurity measures. VTech argues that plaintiffs have not identified the law on which they are basing the unjust enrichment claim, instead improperly asserting it on behalf of a nationwide class. Because each state handles unjust enrichment claims differently, they argue, plaintiffs' generic pleading is inappropriate and grounds for dismissal. Plaintiffs' only response is to say that "any argument that a national unjust enrichment class cannot be certified is premature and not a basis for dismissing a claim at this stage of the litigation." [104] at 36. For this proposition, plaintiffs cite to my opinion in Rysewyk v. Sears Holdings Corp., No. 15 CV 4519, 2015 WL 9259886 (N.D. Ill. Dec. 18, 2015). In that case, I did find that a motion to strike class allegations was premature, id. at *7-8, but this is not a motion to strike class allegations. VTech is not arguing against certification of the class in this motion, but rather appears to be pointing out that plaintiffs' failure to identify what law they are proceeding under does not provide them with adequate notice as required by Federal Rule of Civil Procedure 8. I agree that because VTech failed to identify the states' laws on which they base their unjust enrichment claim, they failed to state a cause of action. See Avenarius v. Eaton Corp., 898 F.Supp.2d 729, 740 (D. Del. 2012) ("Generic pleading and generic responsive briefing is inappropriate given that states analyze unjust enrichment claims differently."). See also In re Opana ER Antritrust Litig., 162 F.Supp.3d 704, 726 (N.D. Ill. 2016); In re Flonase Antitrust Litig., 610 F.Supp.2d 409, 419 (E.D. Pa. 2009); In re Wellbutrin XL Antitrust Litig., 260 F.R.D. 143, 167 (E.D. Pa. 2009).

VTech also argues that the unjust enrichment claim is duplicative of the breach of contract claims and, since plaintiffs did not plead it in the alternative, it must be dismissed. Plaintiffs counter that their unjust enrichment claim not only was pleaded in the alternative to the breach of contract and warranty claims, but that the claim is also based on principles of tort law—specifically, fraud. In Illinois, "if an unjust enrichment claim rests on the same improper conduct alleged in another claim, then the unjust enrichment claim will be tied to this related claim— and, of course, unjust enrichment will stand or fall with the related claim." Cleary v. Philip Morris Inc., 656 F.3d 511, 517 (7th Cir. 2011). Whether it is contract or tort law, plaintiffs' unjust enrichment claims are tied to either its breach of contract, implied warranty, or ICFA claims. And since those claims have fallen, so must the unjust enrichment claim.

VTech's motion to dismiss the unjust enrichment claim is granted. The claim is dismissed without prejudice.

IV. Conclusion

VTech's motion to dismiss, [100], is granted. The consumer fraud claims (Counts V and VI) and the unjust enrichment claim are dismissed without prejudice. The other claims are dismissed with prejudice.

Sours: https://www.leagle.com/decision/infdco20180419b11
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Chicago – VTech Electronics North America, L.L.C., a wholly owned subsidiary of VTech Holdings Limited (HKSE: 303), today announced Andrew (Andy) S. Keimach has been named President, effective immediately. The appointment follows the retirement of the current President, William To.

In this role, Keimach leads the Electronic Learning Products (ELPs) business of both the VTech and LeapFrog® brands in the U.S. He and his team are charged with delivering growth through executing the dual brand strategy, effectively engaging consumers and business partners, as well as contributing to product innovation. Keimach reports to Gilles Sautier, International President of ELPs.

Prior to the appointment, Keimach was most recently President at Munchkin, Inc. He focused on building a strong international sales team and expanding the business geographically, which made Munchkin one of the leading U.S. infant products manufacturers. Before joining Munchkin in 1999, Keimach started his career at Procter & Gamble in 1983 and became Vice President of Sales in 1996. He has more than 30 years of experience in global consumer products, with a strong cross-functional, market and customer business development track record.

"Under William's leadership, VTech became the number one supplier of electronic learning toys from infancy through toddler and preschool in the U.S., a position we retain today. We thank William for his decades of service and contribution," said Dr. King Pang, Group President of VTech Holdings Limited. "Andy is a talented executive with strong leadership skills in driving business growth and product development. We look forward to further success under him."

"VTech has been a pioneer in the electronic learning toy category for more than three decades, and both VTech and LeapFrog are great names in children's learning and entertainment. I look forward to building on the tremendous platform VTech's ELPs business has in the U.S. as we continue to develop the innovative products that make us the market leader," said Keimach.

About VTech

VTech is a world leader in age-appropriate and developmental stage-based electronic learning products for children. As a pioneer in the learning toy category, VTech develops high-quality, innovative educational products that enrich children's development and make learning fun. With a rich 40 year history, VTech has not only established itself as a learning authority but also consistently remains at the forefront of innovation with multiple award-winning products, including prestigious Toy of the Year (TOTY) Award winners. The company also has a broad range of award-winning infant, toddler and preschool products available in 31 different languages worldwide, with more than 100 new products introduced every year. In order to further strengthen VTech's position as a learning authority, new products are developed with critical insights from a dedicated team of in-house learning experts.

VTech Electronics North America, L.L.C. is based in Arlington Heights, Illinois. VTech Electronics Limited is headquartered in Hong Kong with distribution globally.

For more information about VTech's electronic learning products, visit www.VTechKids.com, www.facebook.com/VTechtoys on Facebook or follow @VTechToys on Twitter.

Sours: https://www.vtech.com/en/press_release/2018/vtech-electronics-north-america-appoints-new-president/

VTech Electronics 9148 V.smile motion User Manual

User’sManual

Thank you for purchasing the VTech®V.Smile

V-Motion

tm

Active Learning

System!

The V.Smile

V-Motion

tm

Active Learning Systemis a unique video gaming system

created especially for younger players. With V.Smile

V-Motion

tm

, children can take off

on wonderful journeys to a variety of places such as an amusement park, a cartoon world,

or even a magical fairy tale land. As they explore these worlds, children absorb learning

concepts through creative gaming and adventure play. Each game universe features

child-directed play and hidden surprises, so that the adventure is never the same twice!

The package contentsThe package contents

• V.Smile®

V-Motion

tm

Active Learning System consoleand User’s Manual

• One Wireless Controller

• One Wrist Strap

• One V.LINK™and V.LINK™ Manual

• One Smartridge™ and Smartridge™ Manual

WARNING: All packing materials such as tape, plastic sheets, wire ties and tags are

not part of this toy and should be discarded for your child’s safety.

User’sManual

V.Smile®

V-Motiontm

Console

• Make sure the unit is turned OFF.

• Locate the battery cover on the back of the unit.

• Remove the battery cover and insert 4 X 1.5V AA LR6/AM-3

batteries as indicated in the diagram.

• Make sure battery cover is securely.

Notice: When the V.Smile®

V-Motion

tm

is running on batteries,

you may see this icon appear on right upper corner

of screen. This indicates that battery power is low, and you

should replace the batteries soon. Battery time remaining

once the icon first appears is approximately 10-30 minutes,

depending on the type of batteries in use. After that, the

console will show the low battery icon for 5 seconds as

indicated in the diagram, for 5 seconds, and then will turn

OFF automatically.

V.Smile®

V-Motiontm

Wireless Controller

• Make sure the Wireless Controller is turned OFF.

• Locate the battery cover on the back of the unit.

• Remove the screw of the battery cover with a screwdriver or acoin,

and insert 3 x 1.5V AAA AM4/LR03 batteriesas indicated in the

diagram.

• Make sure battery cover is securely attached with screws.

Notice: When the V.Smile

V-Motion

tm

Wireless Controller is low

battery life and 4 direction LED on the controller will blink

around 10-30 mintues then will turn OFF automatically.

VTech®recommends high quality alkaline batteries for best

performance and longevity of battery.

Battery NoticeBattery Notice

• Install batteries correctly observing the polarity (+, -) signs to avoid leakage.

• Do not mix old and new batteries.

• Do not mix batteries of different types: alkaline, standard (carbon-zinc) or rechargeable

(Ni-Cd or Ni-MH).

• Remove the batteriesfrom the equipment whenthe unit will not be usedfor an extended

period of time.

• Always remove exhausted batteries from the equipment.

• Do not dispose of batteries in fire.

l

• Do not attempt to recharge ordinary batteries.

• The supply terminals are not to be short-circuited.

• Only batteries of the same and equivalent type as recommended are to be used.

WE DO NOT RECOMMEND THE USE OF RECHARGEABLE BATTERIES.

AC AdaptorAC Adaptor

• Use a

VTech®

9V 300mA AC/DC adaptor or a standard AC/DC adaptor

with equivalent specification.

• Make sure the unit is turned OFF.

• Plug the power jack into the 9V DC socket at the back of the unit.

• Plug the AC adaptor into a wall socket.

NOTE: The use of an adaptor will override the batteries. When the toy is not going to

be in use for an extended period of time, unplug the adaptor.

Standard Guidelines for Adaptor ToysStandard Guidelines for Adaptor Toys

• The toy is not intended for use by children under 3 years old.

• Only use the recommended adaptor with the toy.

• The transformer is not a toy.

• Never clean a plugged-in toy with liquid.

• Never use more than one adaptor.

• Do not leave the toy plugged-in for extended periods of time.

NOTE: Before you connect the V.Smile®

V-Motion

tm

Active Learning System to

a TV, check to make sure that the unit is working. Once you have turned the

unit ON, the power indicator light (ON/RESTART Button) should glow. If the

ON/RESTART Buttondoesnot glow,check to see thatthe adaptor is connected

correctly, or that the batteries are installed correctly. If the batteries are not

installed correctly, the V.Smile®

V-Motion

tm

Active Learning System will

not function and damage to the unit could result. Make sure that your TV and

the unit are turned OFF before you begin making connections.

Connect the V.Smile®

V-Motion

tm

Active Learning Systemto your TV or monitor

by plugging the colored cables on the unit into the matching color video and audio input

jacks on your TV set.

For TVs with stereo audio inputs:

- Connect theyellowplug onthe V.Smile®

V-Motion

tm

cableto

the yellow video input terminal on your TV.

- Connect thewhiteand redplugson the V.Smile®

V-Motion

tm

cable to the white and red audio input terminals on your TV.

Yellow WhiteRed

User’s Manual

GETTING STARTED

PARENT’S TV TIPS

A Healthy, Balanced “TV Diet”

By Dr. Helen Boehm

Television was long considered the “uninvited” guest in American households. However,

today many realistic and caring parents are partnering with television to create electronic

classrooms -- right in their own living rooms. They are no longer asking if children should

watch TV but, rather, which programs and on-screen activities should be part of their

children’s TV intake.

The samebalanced andstructured approach to developing healthy eating habits translates

to watching less, different and better television! This “TV diet” gives families a menu for

regulating children’sviewing, choosing “healthy” program contentand reducing the quantity

and potency of television consumed.

So, what does a healthy, balanced “TV diet” look like?

A well-balanced diet is best…

Consider a healthy mixture of age-appropriate programming and activities that educate,

engage and entertain! A variety of viewing and interactive experiences can turn a TV

screen into an electronic classroom for learning and fun.

Trim the fat…

It is important to reduce children’s sedentary behavior and eliminate unhealthy programs

that contain violent, aggressive or disrespectful behaviors.

Move out of the candy store…

Parents are children’s first teachers and their most powerful role models. It is difficult

to improve children’s viewing when parents are modeling other TV viewing behaviors.

Consider adapting your own TV habits as a healthy example for your child.

Plan menus and season to taste…

Whenever possible, eliminate channel surfing and encourage the viewing of specific,

pre-selected shows. The PG-TV ratings help parents make more informed selections

that take into account the content and age-appropriateness of programs. For example,

Y-7 shows are designed for children 7 and older who can distinguish between fact and

fantasy. A TV-Y7-FV rating indicates that “fantasy violence” is present in an episode of

an animated program.

Control couch potatoes…

CONTENTS

• PARENT’S TV TIPS ......................................................................... 1

•INTRODUCTION ............................................................................... 3

The Package contents .............................................................................. 3

• PRODUCT FEATURES................................................................... 4

V.Smile

V-Motion

tm

Console

V.Smile

V-Motion

tm

Wireless Controller

• GETTING STARTED ....................................................................... 5

Battery Installation ..................................................................................... 5

Battery Notice ............................................................................................ 6

AC Adaptor ................................................................................................ 6

Standard Guidelines for Adaptor Toys ..................................................... 6

Connecting to a TV ................................................................................... 6

Connecting to a VCR ................................................................................ 7

To Begin Play ............................................................................................ 7

V.Smile®

V-Motiontm

Console .............................................................. 8

Using V.Smile®

V-Motiontm

Wireless Controller .......................................... 8

How to attach wrist strap to Controller?

1 Player mode

2 Player mode

Connect V.SMILE accessories or V.SMILE cable controller

• V.Smile®

V-Motion

tm

PLAY GUIDELINES........................... 9

Best results when playing the game ......................................................... 9

Using the V.Smile®

V-Motion

tm

Wireless Controller ........................... 10

• CARE & MAINTENANCE ............................................................. 12

• TROUBLESHOOTING ................................................................... 12

• TECHNICAL SUPPORT ................................................................ 14

• OTHER INFO ...................................................................................... 15

Disclaimer and Limitation of liabilty

12356

Children benefit from participation in movement, fitness activities and sports. These

bodily actions are not only important for a child’s physical growth and development but

also to monitor their emotional stability, social skills and obesity. Limit sedentary screen

time and blend physical and mental pursuits, like active on-screen games and video

activities, into the TV mix.

Starvation diets don’t work…

Many parents have found that restricting all TV time is an impractical long-term strategy.

It is possible, however, to set realistic limits that are welcomed by both parent and child!

Make viewing a choice and not a habit. Eliminate some TV timeby setting a few basic rules,

such as restricting television during meals or before the day’s homework is completed.

News fast…

The realism of TV news can be overwhelming and scary for young children and reinforces

their profound safety concerns. Exposureto TV news images, particularly without a context

for scenes of terrible suffering, can cause vivid and long lasting fears.

Food for thought…

Whenever possible, connect viewing with learning. Many programs and characters are

based on books and many on-screen subjects -- from geography to sports -- can inspire

a lifelong interest in reading. Choose age-appropriate video activities that encourage

interaction and challenge critical thinking.

Dr. Helen Boehm is the author of The Right Toys, Fearless Parenting and many magazine

articles on parenting and responsible children’s media. A distinguished psychologist

and nationally known authority on children’s development, play, and media, Dr. Boehm

headed Public Responsibility and Network Standards at MTV/Nickelodeon and was Vice

President of the Fox Children’s Network.

V.Smile

V-Motion

tm

Active Learning

System Console

Smartridge™

4

Wireless Controller

Wrist Strap

V.LINK

TM

The V.Smile®

V-Motion

tm

Wireless Controlleraccommodates

both right-andleft-handed players.

Release thelock andturn thefunc-

tion button panel ( center part ofthe

joystick) around to the other side

until you hear a locking sound.

Parent letter

V.LINK

TM

Manual

Der Pr,

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ag-rit nr?

Or wr t ts qui s V-Mi Acv Lerng Syt! A ig retru r ir

gmrs, V-Mi tk eucin id gng t  l  lv t  i-acte

gng t th ngag b acv ns n oi.

V-Mi us rely t t TV t rvid is t  ig-t gng pinc ng

tng, ag-rit lerng gm n  i-acte, v rl crlr.

 V-Mi Acv Lerng Syt ngag clr t w od  lay: t Lerng

Avr -  cng lrtry rn  c lerng cncpts r elly tegrte,

n t Lerng Zn -  i  gm digne t cs  pfi s   , ngagng

ay. Eac Smrid™ gm ncrag acv gng l gvng is’ ns  r, t,

s t ler b t, eang, scinc, png n r.

I adi t t aci-ackeSmrid™ gm lay, t V-Mi ncud tV.L™ (USB v)

th cnes istVT®’s r nt t lc sgm n rac trscr ag

r gmrs.

A VT®,  rru t rvid rtst  uc-ede i t t id gm lm,

s  s nr nv ay r clr t ler l hvng . W th  r ng

VT® t t prt b  ng r cl lr   rl  lerng!

Sncrly,

Ji Fzgrl

Vc Prid, Mrkng

Vt Elers, NA

To learn more about the V-Motion Active Learning System™ and other VTech® toys, visit www.vtechkids.com

INTRODUCTION PRODUCT FEATURES

User’s Manual

User’s Manual

• Storage compartment

You can store up to nine Smartridges™

inside here when they are not in use.

• Smartridge™ slot

For inserting a Smartridge™ and make

sure it should lock into place. (can play

both V.Smile®

V-Motion

tm

Smart-

ridge™ & V.Smile® Smartridge™).

• Wireless Contoller signal

Lights turn on when receive the data from

Wireless Controller.

• Joystick Port

Open the rubber door and plug the cable

joystick into this port ( Cable joystick is

sold separated ).

• Battery compartment

See page 6.

• AV cable

Connects to TV or VCR. See page 6 & 7.

• Power jack

See page 6.

• Off button

Press this button to turn the unit OFF .

Always do this before removing a Smartridge™.

• ON / RESTART button

Press this button to turn the unit on ON/RE-

START Button while playing a game, the game

will start over from the beginning.

• Microphone Port

Connects to the Microphone ( sold separated ).

• V.Link™ Port

For inserting a V.Link.

• 4 Direction signal

Light turns on and indicate up, left, down

& right direction.

• HELP Button

Press this button to hear helpful hints in

certain games.

• Joystick

• 4 Color Button

Use these buttons to choose

answers in certain activities, or to

preform certain game actions.

• Wireless Controller OFF/ON-Player

1/Player 2 Button

Switch this button choose Off / ON

- Player 1 / Player 2. Details operation

please refer to page 8-11.

• Wrist Band Attachment

See page 8.

• Wrist Band

• Motion sensor signal

Light turns on when connected with

Console.

• Enter Button

Press this button to make a choice,

or to perform certain game actions.

Resume power when unit auto

power off.

• Battery Compartment

See page 5.

• LEARNING ZONE Button

Press this button to enter the Learning

Zone play mode.

• EXIT Button

Press this button to exit or pause a game.

Smartridge™ Manual

V-Motion Wireless ControllerV-Motion Wireless Controller

Sours: https://usermanual.wiki/VTech-Electronics/9148/html

Na vtech llc electronics

I won't say it was fun. Just a stupid booze. Then he took her home to her sister and stayed overnight. And suddenly an unexpected surprise. Her cousin also came there.

Paw Patrol Game - VTech Toys UK

And now the women got off him. You satisfied us well, but then you didnt understand it right away, you will be punished, Sveta said, and left. Katya pulled him out of bed and knelt in front of her.

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The work is done, I will go. Oh, sweets. There were candy in a vase in the room. She took one.



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