As Google's Android smartphone operating system was coming under attack in fall 2012 from malware with the colorful names of "Loozfon" and "FinFisher," the FBI's Internet Crime Complaint Center issued an alert against the threat.

"Depending on the type of phone," the FBI said, "the operating system may have encryption available. This can be used to protect the user's personal data."

Last fall, when Apple and Google announced they were cleaning up their operating systems to ensure that their users' information was encrypted to prevent hacking and potential data loss, FBI Director James Comey attacked both companies. He claimed the encryption would cause the users to "place themselves above the law."