Mr. Warner acknowledged that Apple has responded to the problem of iPod nano screens cracking easily but has yet to rectify the issue with easily-scratched displays. The cracked screens were the result of a manufacturing problem affecting a small number of users, according to Apple, but this one "seems too widespread to be a defective batch," Mr. Warner said. "We haven't ruled that out, however."
Apple will soon have to answer the complaint. Possible reactions include a motion for dismissal. Currently, the company will not respond to a request for comment.