1 ALDEN F. ABBOTT
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 1 of 10 Page ID ALDEN F. ABBOTTGeneral CounselKATHERINE WHITEVA Bar No. 68779; kwhite@ftc.govTel: (202) 326-2878ELISA JILLSONDC Bar No. 989763; ejillson@ftc.govTel: (202) 326-3001Federal Trade Commission600 Pennsylvania Ave. NW, CC-8232Washington, DC 20580Fax: (202) 326-3062Local CounselKENNETH ABBECA Bar No. 172416; kabbe@ftc.govFederal Trade Commission10990 Wilshire Boulevard, Suite 400Los Angeles, CA 90024Tel: (310) 824-4313 / Fax: (310) 824-4380Attorneys for PlaintiffFederal Trade CommissionUNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIAFEDERAL TRADE COMMISSION, ))Case No.Plaintiff,))COMPLAINT FORv.)PERMANENT INJUNCTION)AND OTHER EQUITABLEKATRINA MOORE,)RELIEFindividually and also d/b/a)Innovative Paycheck Solutions )and FakePayStubOnline.com, ))Defendant.))COMPLAINTPAGE 1
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 2 of 10 Page ID #:21Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges:21.345The FTC brings this action under Section 13(b) of the Federal TradeCommission Act (“FTC Act”), 15 U.S.C. § 53(b), to obtain permanent injunctiverelief, disgorgement of ill-gotten monies, and other equitable relief for Defendant’s6acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), in7connection with Defendant’s marketing and sale of fake pay stubs, fake bank8statements, fake tax forms, and a service for falsifying real bank statements.91011121314JURISDICTION AND VENUE2.This Court has subject matter jurisdiction pursuant to 28 U.S.C.§§ 1331, 1337(a), and 1345, and 15 U.S.C. §§ 45(a) and 53(b).3.Venue in the Central District of California is proper under 28 U.S.C.§ 1391(b)(1), (b)(2), and (c)(1) and 15 U.S.C. § 53(b).15161718192021PLAINTIFF4.The FTC is an independent agency of the United States Governmentcreated by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTCAct, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in oraffecting commerce.5.The FTC is authorized to initiate federal district court proceedings, by22its own attorneys, to enjoin violations of the FTC Act and to secure such other23equitable relief as may be appropriate in each case, including rescission or242526reformation of contracts, restitution, the refund of monies paid, and thedisgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b) and 56(a)(2)(A).2728COMPLAINTPAGE 2
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 3 of 10 Page ID #:312345DEFENDANT6.Defendant Katrina Moore (“Moore”) is the operator of InnovativePaycheck Solutions (“IPS”), an unincorporated entity that runs the websitewww.fakepaystubonline.com (“Fake Pay Stub Website” or “Website”). At all6times material to this Complaint, acting alone or in concert with others, she has7formulated, directed, controlled, had the authority to control, or participated in the8acts and practices of IPS and the Fake Pay Stub Website, including the acts and9practices set forth in this Complaint. Defendant Moore resides in this district and,101112in connection with the matters alleged herein, transacts or has transacted businessin this district and throughout the United States.COMMERCE13147.At all times material to this Complaint, Defendant has maintained a15substantial course of trade in or affecting commerce, as “commerce” is defined in16Section 4 of the FTC Act, 15 U.S.C. § 44.17DEFENDANT’S BUSINESS PRACTICES18198.Since at least 2013, Defendant has operated IPS and the Fake Pay20Stub Website, which sells customers a variety of financial documents, including21pay stubs, income tax forms and returns, bank statements, and profit and loss22statements. The company advertises these documents as fake, but makes clear in23its ads that they look authentic. Defendant knows or should know that these fake242526documents will be presented as genuine when provided to recipients (such aslenders and landlords).2728COMPLAINTPAGE 3
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 4 of 10 Page ID #:41234569.Through the Fake Pay Stub Website, Defendant sells fake pay stubsfor 40 to 80, fake income tax forms (W-2 and 1099 forms) for 75, fake taxreturns starting at 150, fake bank statements for 125, and fake profit and lossstatements starting at 100. See Exhs. A-I.10.Pay stubs, also called paycheck stubs or check stubs, can be used to7prove identity, residency, income, and/or employment to government agencies,8landlords, and lenders. They typically identify the employer and employee by9name and address, and state the employee’s full or partial Social Security number,101112gross and net wages earned, hours worked, pay rate or salary, pay period dates, anddeductions. Tax forms W-2 and 1099 and tax returns can be used to prove identity,13residency, income, and/or taxes paid to government agencies, landlords, and14lenders. Bank statements, which show incoming and outgoing payments to and15from a bank account, can be used to prove identity, residency, and/or financial16assets to government agencies, landlords, and lenders. Profit and loss statements,17181920which show a company’s revenues and expenses, can be used to prove acompany’s assets and creditworthiness to lenders.11.Purchasers of fake pay stubs can choose among three styles of pay21stubs: “DIY” [do-it-youself] pay stubs apparently generated by payroll company22ADP (Exh. B), “standard” pay stubs printed on white paper in one of four different23formats (Exh. C), and “premier” pay stubs printed on blue business check stock2425262728paper (Exh. D). Purchasers of fake bank statements can choose among statementsapparently associated with real banks such as Citibank, Chase, Bank of America,Wells Fargo, and Best Bank. Exh. H.COMPLAINTPAGE 4
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 5 of 10 Page ID #:51234512.Customers can populate IPS’s fake pay stubs, fake income tax formsand returns, fake bank statements, and fake profit and loss statements with anyidentification and financial information they choose. In addition, for certainproducts, Defendant offers personalized data-editing to maximize the apparent6authenticity of the products. For example, the blog post introducing IPS’s fake tax7return explains that sometimes Defendant asks “detailed questions” for customized8data-editing that require the customer to respond to email promptly. Exh. J.910111213.Unless the customer selects a “DIY” [do-it-yourself] option (Exh. B),IPS uses the information the customer supplies to “custom calculate[]” taxes,withholdings, and/or interest appropriate to generate an authentic-looking pay stub13or tax form (Exh. A). Once the customer approves the draft populated template,14IPS finalizes the document and sends it to the customer by email, download and/or15postal mail. Exh. A.1617181914.IPS also sells a service, editing real bank statements provided by thecustomer, for 150. Exh. K. The Website instructs customers to download realfinancial statements from their bank and submit them to IPS in PDF format for20modification. Id. Customers who purchase the bank statement editing service can21make any modifications they choose, with any information they choose, to those22real bank statements. Id.23242526272815.To use the bank statement editing service, purchasers must supply realcontact information for service-related correspondence. Exh. K. The Websiteassures the purchaser, however, that “[t]his information will NOT be used on yourdocument.” Id. Defendant makes no attempt to cross-check the identificationCOMPLAINTPAGE 5
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 6 of 10 Page ID #:61information supplied for the bank statement editing with the contact information2supplied for service-related correspondence.34516.In addition to the bank statement editing service, Defendant offers paystub and other document editing services. Defendant explains in an “FAQ” (“If I6send you my pay stubs or W2 can you change make changes [sic]?): “In some7cases we can edit pay stubs or other documents you provide us.” Exh. L.8Defendant requires customers to submit a digital copy of a document “downloaded9from the company website that issued the document.” Id.10111217.Defendant consistently emphasizes that its products are “fake” butlook “authentic” and contain “accurate” calculations. For example, the Website’s13URL, www.fakepaystubonline.com, prominently describes the site’s products as14“fake.” The home page and product pages for pay stubs, tax forms, and bank15statements use the all-capitalized, bold-faced heading “FAKE.” See Exhs. A-1, -2;16C-1, E-1; G-1; H. Other product pages similarly describe the pay stubs and tax171819forms as “fake.” See Exhs. C-1; D; F-1. Metatags in the Website’s source code(which drive Internet search traffic) describe: “Custom Fake Pay Stubs” and20“Inexpensive & Authentic Fake Pay Stubs!” Exh. M. Metatags also identify the21site as: “Fake Pay Stubs Online Quick, Easy, Accurate Pay Stubs.” Id. The22Website describes itself as: “Your one stop shop for authentic looking fake page23stubs and other income verification documents . . . Whether you want fake pay2425262728stubs, fake W2’s or fake pay statements, we can help!” Exh. N. The Websitefurther states: “We make our check stubs with accurate tax withholding’s [sic],and without a watermarks [sic].” Id. at N-2.COMPLAINTPAGE 6
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 7 of 10 Page ID #:7123456718.The Website’s Terms and Conditions state: “All items sold on thissite are for novelty and entertainment purposes.” Exh. O. The Terms andConditions further state: “The term “fake” as used in this website’s text, title, metatags, keywords, and images equate with the word ‘novelty’ and are used for thesole purpose of search engine optimization.” Id.19.Despite claiming that the financial documents sold on this site are for8“novelty and entertainment purposes,” Defendant does not clearly and prominently9mark these documents as being appropriate only for such purposes and does not101112otherwise clearly and prominently convey to the ultimate recipients that thesedocuments are fake. For example, Defendant does not use a watermark or13permanent label to indicate that the pay stub, income tax form, or bank statement is14fake. To the contrary, as described in Paragraph 17, Defendant advertises that IPS15does not use a watermark and that its products, although “fake,” appear “authentic”16and “accurate.” In addition, Defendant uses its “FAQs” to give advice on how to17181920avoid making pay stubs “look fake.” Exh. P (advising customers to avoidchanging pay stub dates without updating “YTD earnings & taxes”).20.Fake pay stubs, tax forms and returns, bank statements, and profit and21loss statements are used to commit identity theft, tax fraud, and loan fraud.22Identity thieves use fake pay stubs, along with other fake or fraudulently obtained23documents, to apply for credit cards using stolen personal information. When the2425262728identity thief fails to pay credit card bills, it is the victim’s credit that suffers.Identity thieves also use fake IRS W-2 and 1099 forms with stolen personalinformation to obtain tax refunds fraudulently. As a result, victims of the identityCOMPLAINTPAGE 7
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 8 of 10 Page ID #:81theft often experience long delays before receiving needed tax refunds. Bad actors2use fake pay stubs, fake tax forms and returns, fake bank statements, and fake345profit and loss statements to misrepresent income, employment, assets, andcreditworthiness in order to obtain mortgages, auto loans, housing leases, and6credit fraudulently. When bad actors default on loans or leases, the lender and any7downstream investors suffer a loss, which is often passed onto consumers with8higher lending costs.910111213VIOLATIONS OF THE FTC ACT21.Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair ordeceptive acts or practices in or affecting commerce.”22.Acts or practices are unfair under Section 5 of the FTC Act if they14cause or are likely to cause substantial injury to consumers that consumers cannot15reasonably avoid themselves and that is not outweighed by countervailing benefits16to consumers or competition. 15 U.S.C. § 45(n).17181923.Misrepresentations or deceptive omissions of material fact constitutedeceptive acts or practices prohibited by Section 5(a) of the FTC Act.COUNT I202124.In numerous instances, Defendant has advertised and sold fake pay22stubs, fake income tax documents, fake bank statements, fake profit and loss23statements, and services for falsifying real bank statements and other real financial2425262728documents.25.Fake financial documents, such as those sold on Defendant’s website,are used to facilitate fraudulent activity, including identity theft and loan fraud.COMPLAINTPAGE 8
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 9 of 10 Page ID #:91234526.Defendant’s actions cause or are likely to cause substantial injury toconsumers that consumers cannot reasonably avoid themselves and that is notoutweighed by countervailing benefits to consumers or competition.27.Therefore, Defendant’s practices as described in Paragraph 24 above6constitute unfair acts or practices in violation of Section 5 of the FTC Act, 157U.S.C. §§ 45(a) and 45(n).89101112CONSUMER INJURY28.Consumers have suffered and will continue to suffer substantial injuryas a result of Defendant’s violations of the FTC Act. In addition, Defendant hasbeen unjustly enriched as a result of the unlawful acts or practices. Absent13injunctive relief by this Court, Defendant is likely to injure consumers and harm14the public interest.1516171819THIS COURT’S POWER TO GRANT RELIEF29.Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Courtto grant injunctive and such other relief as the Court may deem appropriate to halt20and redress violations of any provision of law enforced by the FTC. The Court, in21the exercise of its equitable jurisdiction, may award ancillary relief, including22rescission or reformation of contracts, restitution, the refund of monies paid, and23the disgorgement of ill-gotten monies, to prevent and remedy any violation of any2425provision of law enforced by the FTC.262728COMPLAINTPAGE 9
Case 5:18-cv-01960 Document 1 Filed 09/13/18 Page 10 of 10 Page ID #:10l23PRAYER FOR RELIEFWherefore, Plaintiff FTC, pursuant to Section 13{b) of the FTC Act, 15U.S.C. § 53(b), and the Court's own equitable powers, requests that the Court:45678910A.Enter a permanent injunction to prevent future violations of the FTCAct by Defendant; andB.Award such relief as the Court finds necessary to redress injury toconsumers resulting from Defendant's violations of the FTC Act, including but 1;1otlimited to, rescission or reformation of contracts, restitution, the refund of moniespaid, and the disgorgement of ill-gotten monies;111213C.Award Plaintiff the costs of bringing this action, as well as such otherand additional relief as the Court may determine to be just and proper.1415Respectfully submitted,16ALDEN F. ABBOTTGeneral Counsel171819Dated: C, // / 18KATHERINE WHITEELISA JILLSONKENNETH ABBE2021Attorneys for PlaintiffFEDERAL TRADE COMMISSION22232425262728COMPLAINTPAGE 10
9. Through the Fake Pay Stub Website, Defendant sells fake pay stubs for 40 to 80, fake income tax forms (W-2 and 1099 forms) for 75, fake tax returns starting at 150, fake bank statements for 125, and fake profit and loss statements starting at 100. See Exhs. A-I. 10. Pay stubs,
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