UNITED STATES DISTRICT COURT - Federal Trade Commission
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 1 of 36UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MASSACHUSETTSWESTERN DIVISIONFEDERAL TRADE COMMISSION,Case No. 3:22-cv-30048STIPULATED ORDER FORPERMANENT INJUNCTION,MONETARY JUDGMENT,AND OTHER RELIEFPlaintiff,v.WARRIOR TRADING, INC., acorporation,WARRIOR OPERATING INC., acorporation, also d/b/a Warrior Trading,andROSS CAMERON, individually and as anofficer of WARRIOR TRADING, INC.,and WARRIOR OPERATING INC.,Defendants.Plaintiff, the Federal Trade Commission (“Commission” or “FTC”), filed itsComplaint for Permanent Injunction, Monetary Relief, and Other Relief(“Complaint”), for a permanent injunction, and other relief in this matter, pursuantto Sections 13(b) and 19 of the Federal Trade Commission Act (“FTC Act”), 15U.S.C. §§ 53(b) and 57b and the Telemarketing and Consumer Fraud and AbusePrevention Act (“Telemarketing Act”), 15 U.S.C. §§ 6101-6108. The CommissionPage 1 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 2 of 36and Defendants stipulate to the entry of this Stipulated Order for PermanentInjunction, Monetary Judgment, and Other Relief (“Order”) to resolve all matters indispute in this action between them including a potential administrative actionpursuant to 16 C.F.R. Part 3, followed by a potential federal court action subject to19(a)(2) of the FTC Act, 15 U.S.C. §57b(a)(2).THEREFORE, IT IS ORDERED as follows:FINDINGS1.This Court has jurisdiction over this matter.2.The Complaint charges that Defendants participated in deceptive and unfairacts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45 and theTelemarketing and Consumer Fraud and Abuse Prevention Act (“TelemarketingAct”), 15 U.S.C. §§ 6101-6108, in connection with the advertising, marketing,distribution, and selling of a Day-Trading strategy and related goods and services toconsumers throughout the United States.3.Defendants neither admit nor deny any of the allegations in the Complaint,except as specifically stated in this Order. Only for purposes of this action,Defendants admit the facts necessary to establish jurisdiction.4.Defendants waive any claim that they may have under the Equal Access toJustice Act, 28 U.S.C. § 2412, concerning the prosecution of this action through thePage 2 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 3 of 36date of this Order, and agree to bear their own costs and attorney fees.5.Defendants and the Commission waive all rights to appeal or otherwisechallenge or contest the validity of this Order.DEFINITIONSFor the purpose of this Order, the following definitions apply:A.“Billing Information” means any data that enables any person to access acustomer’s account, such as a credit card, checking, savings, share or similaraccount, utility bill, mortgage loan account, or debit card.B.“Charge,” “Charged,” or “Charging” means any attempt to collect moneyor other consideration from a consumer, including causing Billing Information to besubmitted for payment, including against the consumer’s credit card, debit card,bank account, telephone bill, or other account.C.“Clear(ly) and conspicuous(ly)” means that a required disclosure is difficultto miss (i.e., easily noticeable) and easily understandable by ordinary consumers,including in all of the following ways:1.In any communication that is solely visual or solely audible, thedisclosure must be made through the same means through which thecommunication is presented. In any communication made through bothvisual and audible means, such as a television advertisement, the disclosurePage 3 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 4 of 36must be presented simultaneously in both the visual and audible portions ofthe communication even if the representation requiring the disclosure is madein only one means.2.A visual disclosure, by its size, contrast, location, the length of time itappears, and other characteristics, must stand out from any accompanyingtext or other visual elements so that it is easily noticed, read, and understood.3.An audible disclosure, including by telephone or streaming video, mustbe delivered in a volume, speed, and cadence sufficient for ordinaryconsumers to easily hear and understand it.4.In any communication using an interactive electronic medium, such asthe Internet or software, the disclosure must be unavoidable.5.The disclosure must use diction and syntax understandable to ordinaryconsumers and must appear in each language in which the representation thatrequires the disclosure appears.6.The disclosure must comply with these requirements in each mediumthrough which it is received, including all electronic devices and face-to-facecommunications.7.The disclosure must not be contradicted or mitigated by, orinconsistent with, anything else in the communication.Page 4 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 5 of 368.When the representation or sales practice targets a specific audience,such as children, the elderly, or the terminally ill, “ordinary consumers”includes reasonable members of that group.D.“Day-Trading” means buying then selling or selling short then buying thesame security on the same day. This definition encompasses any security,including options.E.“Defendants” means all of the Individual Defendants and the CorporateDefendants, individually, collectively, or in any combination.1.“Corporate Defendants” means Warrior Trading, Inc., WarriorOperating, Inc., also d/b/a Warrior Trading, and their successors and assigns.2.F.“Individual Defendant” means Ross P. Cameron.“Earnings Claim(s)” means any representation to a consumer, specific orgeneral, about income, financial gains, percentage gains, profit, net profit, grossprofit, or return on investment. Earnings Claims include: (1) any chart, table, ormathematical calculation that demonstrates possible results based upon acombination of variables; (2) any statements from which a prospective purchasercan reasonably infer that he or she will earn a minimum level of income (e.g., “earnenough to buy a Porsche,” “earn a six-figure income,” or “earn your investmentback within one year”); and (3) any statements, claims, success stories,Page 5 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 6 of 36endorsements, or testimonials about the performance or profitability ofrepresentatives, endorsers, instructors or customers.G.“Investment Opportunity” includes anything, tangible or intangible, that isoffered, offered for sale, sold, or traded based wholly or in part on representations,either express or implied, about past, present, or future income, profit, orappreciation.H.“Telemarketer” means any Person who, in connection with Telemarketing,initiates or receives telephone calls to or from a customer or donor.I.“Telemarketing” means any plan, program, or campaign which is conductedto induce the purchase of goods or services by use of one or more telephones, andwhich involves a telephone call, whether or not covered by the Telemarketing SalesRule.ORDERI. PROHIBITION CONCERNING EARNINGS CLAIMSIT IS ORDERED that Defendants, Defendants’ officers, agents, employees,and attorneys, and all other persons in active concert or participation with any ofthem, who receive actual notice of this Order, whether acting directly or indirectly,in connection with promoting or offering for sale any good or service arepermanently restrained and enjoined from making any Earnings Claims or assistingPage 6 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 7 of 36others in making any Earnings Claims, expressly or by implication, unless theEarnings Claim is non-misleading, and, at the time such claim is made, Defendants:(1) have a reasonable basis for the claim; (2) have in their possession writtenmaterials that substantiate the claim; and (3) make the written substantiationavailable upon request to the consumer, potential purchaser, or the FTC.II. PROHIBITION AGAINST MISREPRESENTATIONSIT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents,employees, and attorneys, and all other persons in active concert or participationwith any of them, who receive actual notice of this Order, whether acting directly orindirectly, in connection with promoting or offering for sale any good or service,are permanently restrained and enjoined from:A.Misrepresenting or assisting others in misrepresenting, expressly or byimplication, that:1.A consumer can attain proficiency in using Defendants’ tradingstrategy, regardless of education, background, skills or other inherentaptitudes;2.A consumer can attain enough trading experience through Defendants’trading simulator to achieve consistent profitability throughday-trading;Page 7 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 8 of 363.A consumer can effectively use Defendants’ trading strategy to achieveconsistent profitability without the need to possess or deploysignificant amounts of investable capital; or4.A consumer can effectively use Defendants’ trading strategy to makemoney without spending significant time trading.B.Misrepresenting or assisting others in misrepresenting, expressly or byimplication, any fact material to consumers concerning any good or service, suchas: the total costs; any material restrictions, limitations, or conditions; or anymaterial aspect of its performance, efficacy, nature, or central characteristics.III. PROHIBITIONS REGARDING TELEMARKETINGIT IS FURTHER ORDERED that Defendants, Defendants’ officers,agents, and employees, and all other persons in active concert or participation withthem, who receive actual notice of this Order, whether acting directly or indirectly,in connection with Telemarketing of any goods or services are permanentlyrestrained and enjoined from:A.misrepresenting risk, liquidity, earnings potential, or profitability of goods orservices that are the subject of a sales offer;B.misrepresenting material aspects of an Investment Opportunity;C.misrepresenting any material aspect of the performance, efficacy, nature, orPage 8 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 9 of 36central characteristics of goods or services that are the subject of a sales offer;D.making a false or misleading statement to induce any person to pay for goodsor services; andE.violating any provision of the TSR, 16 C.F.R. Part 310, a copy of which isattached as Attachment A.IV. MONETARY JUDGMENTIT IS FURTHER ORDERED that:A.Judgment in the amount of 3,000,000.00 is entered in favor of theCommission against Individual Defendant and Corporate Defendants, jointly andseverally as monetary relief.B.Defendants are ordered to pay to the Commission Three Million Dollars( 3,000,000.00). Such payment must be made within 30 days of entry of thisOrder by electronic fund transfer in accordance with instructions previouslyprovided by a representative of the Commission.C.Defendants relinquish dominion and all legal and equitable right, title, andinterest in all assets transferred pursuant to this Order and may not seek the returnof any assets.D.The facts alleged in the Complaint will be taken as true, without furtherproof, in any subsequent civil litigation by or on behalf of the Commission,Page 9 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 10 of 36including in a proceeding to enforce its rights to any payment or monetary judgmentpursuant to this Order, such as a nondischargeability complaint in any bankruptcycase.E.The facts alleged in the Complaint establish all elements necessary to sustainan action by the Commission pursuant to Section 523(a)(2)(A) of the BankruptcyCode, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effectfor such purposes.F.Defendants acknowledge that their Taxpayer Identification Numbers (SocialSecurity Numbers or Employer Identification Numbers), which Defendantspreviously submitted to the Commission, may be used for collecting and reportingon any delinquent amount arising out of this Order, in accordance with 31 U.S.C.§7701.G.All money paid to the Commission pursuant to this Order may be depositedinto a fund administered by the Commission or its designee to be used for consumerrelief, such as redress and any attendant expenses for the administration of anyredress fund. If a representative of the Commission decides that direct redress toconsumers is wholly or partially impracticable or money remains after redress iscompleted, the Commission may apply any remaining money for such other relief(including consumer information remedies) as it determines to be reasonably relatedPage 10 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 11 of 36to Defendants’ practices alleged in the Complaint. Any money not used for suchrelief is to be deposited to the U.S. Treasury. Defendants have no right tochallenge any actions the Commission or its representatives may take pursuant tothis Subsection.V. CUSTOMER INFORMATIONIT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents,employees, attorneys, and all other persons in active concert or participation withany of them, who receive actual notice of this Order, are permanently restrained andenjoined from directly or indirectly failing to provide sufficient customerinformation to enable the Commission to efficiently administer consumer redress.Defendants represent that they have provided this redress information to theCommission. If a representative of the Commission requests in writing anyinformation related to redress, Defendants must provide it, in the form prescribedby the Commission, within 14 days.VI. ORDER ACKNOWLEDGMENTSIT IS FURTHER ORDERED that Defendants obtain acknowledgments ofreceipt of this Order:A.Each Defendant, within 7 days of entry of this Order, must submit to theCommission an acknowledgment of receipt of this Order sworn under penalty ofPage 11 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 12 of 36perjury.B.For 5 years after entry of this Order, each Individual Defendant for anybusiness that such Defendant, individually or collectively with any otherDefendants, is the majority owner or controls directly or indirectly, and eachCorporate Defendant, must deliver a copy of this Order to: (1) all principals,officers, directors, and LLC managers and members; (2) all employees havingmanagerial responsibilities for conduct related to the subject matter of the Orderand all agents and representatives who participate in conduct related to the subjectmatter of the Order; and (3) any business entity resulting from any change instructure as set forth in the Section titled Compliance Reporting. Delivery mustoccur within 7 days of entry of this Order for current personnel. For all others,delivery must occur before they assume their responsibilities.C.From each individual or entity to which a Defendant delivered a copy of thisOrder, that Defendant must obtain, within 30 days, a signed and datedacknowledgment of receipt of this Order.VII. COMPLIANCE REPORTINGIT IS FURTHER ORDERED that Defendants make timely submissions tothe Commission:A.One year after entry of this Order, each Defendant must submit a compliancePage 12 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 13 of 36report, sworn under penalty of perjury:1.Each Defendant must: (a) identify the primary physical, postal, and emailaddress and telephone number, as designated points of contact, whichrepresentatives of the Commission may use to communicate with Defendant; (b)identify all of that Defendant’s businesses by all of their names, telephone numbers,and physical, postal, email, and Internet addresses; (c) describe the activities of eachbusiness, including the goods and services offered, the means of advertising,marketing, and sales, and the involvement of any other Defendant (which IndividualDefendants must describe if they know or should know due to their owninvolvement); (d) describe in detail whether and how that Defendant is incompliance with each Section of this Order; and (e) provide a copy of each OrderAcknowledgment obtained pursuant to this Order, unless previously submitted tothe Commission.2.Additionally, each Individual Defendant must: (a) identify all telephonenumbers and all physical, postal, email and Internet addresses, including allresidences; (b) identify all business activities, including any business for whichsuch Defendant performs services whether as an employee or otherwise and anyentity in which such Defendant has any ownership interest; and (c) describe indetail such Defendant’s involvement in each such business, including title, role,Page 13 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 14 of 36responsibilities, participation, authority, control, and any ownership.B.For 10 years after entry of this Order, each Defendant must submit acompliance notice, sworn under penalty of perjury, within 14 days of any change inthe following:1.Each Defendant must report any change in: (a) any designated point ofcontact; or (b) the structure of any Corporate Defendant or any entity thatDefendant has any ownership interest in or controls directly or indirectly that mayaffect compliance obligations arising under this Order, including: creation,merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate thatengages in any acts or practices subject to this Order.2.Additionally, each Individual Defendant must report any change in: (a)name, including aliases or fictitious name, or residence address; or (b) title or rolein any business activity, including any business for which such Defendant performsservices whether as an employee or otherwise and any entity in which suchDefendant has any ownership interest, and identify the name, physical address, andany Internet address of the business or entity.C.Each Defendant must submit to the Commission notice of the filing of anybankruptcy petition, insolvency proceeding, or similar proceeding by or againstsuch Defendant within 14 days of its filing.Page 14 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 15 of 36D.Any submission to the Commission required by this Order to be sworn underpenalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746,such as by concluding: “I declare under penalty of perjury under the laws of theUnited States of America that the foregoing is true and correct. Executed on:” and supplying the date, signatory’s full name, title (if applicable), andsignature.E.Unless otherwise directed by a Commission representative in writing, allsubmissions to the Commission pursuant to this Order must be emailed toDEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to:Associate Director for Enforcement, Bureau of Consumer Protection, Federal TradeCommission, 600 Pennsylvania Avenue NW, Washington, DC 20580. Thesubject line must begin: FTC v. Warrior Trading, Inc., X .VIII. RECORDKEEPINGIT IS FURTHER ORDERED that Defendants must create certain records for10 years after entry of the Order, and retain each such record for 5 years.Specifically, each Corporate Defendant and each Individual Defendant for anyconsumer goods or services businesses that such Defendant, individually orcollectively with any other Defendants, is a majority owner or controls directly orindirectly, must create and retain the following records:Page 15 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 16 of 36A.accounting records showing the revenues from all goods or services sold;B.personnel records showing, for each person providing services, whether as anemployee or otherwise, that person’s: name; addresses; telephone numbers; jobtitle or position; dates of service; and (if applicable) the reason for termination;C.records of all consumer complaints and refund requests, whether receiveddirectly or indirectly, such as through a third party, and any response;D.all records necessary to demonstrate full compliance with each provision ofthis Order, including all submissions to the Commission; andE.a copy of each unique advertisement or other marketing material.IX. COMPLIANCE MONITORINGIT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’compliance with this Order, and any failure to transfer any assets as required by thisOrder:A.Within 14 days of receipt of a written request from a representative of theCommission, each Defendant must: submit additional compliance reports or otherrequested information, which must be sworn under penalty of perjury; appear fordepositions; and produce documents for inspection and copying. The Commissionis also authorized to obtain discovery, without further leave of court, using any ofthe procedures prescribed by Federal Rules of Civil Procedure 29, 30 (includingPage 16 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 17 of 36telephonic depositions), 31, 33, 34, 36, 45, and 69.B.For matters concerning this Order, the Commission is authorized tocommunicate directly with each Defendant. Defendant must permit representativesof the Commission to interview any employee or other person affiliated with anyDefendant who has agreed to such an interview. The person interviewed may havecounsel present.C.The Commission may use all other lawful means, including posing, throughits representatives as consumers, suppliers, or other individuals or entities, toDefendants or any individual or entity affiliated with Defendants, without thenecessity of identification or prior notice. Nothing in this Order limits theCommission’s lawful use of compulsory process, pursuant to Sections 9 and 20 ofthe FTC Act, 15 U.S.C. §§ 49, 57b-1.D.Upon written request from a representative of the Commission, any consumerreporting agency must furnish consumer reports concerning Individual Defendants,pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C.§1681b(a)(1).X. RETENTION OF JURISDICTIONIT IS FURTHER ORDERED that this Court retains jurisdiction of this matterfor purposes of construction, modification, and enforcement of this Order.Page 17 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 18 of 36SO ORDERED thisday of, 2022.UNITED STATES DISTRICT JUDGEPage 18 of 20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 19 of 36SO STIPULATED AND AGREED:FOR PLAINTIFF:FEDERAL TRADE COMMISSIONRoberto Anguizola(202) 326-3284 I ranguizola@ftc.govIL Bar No. 6270874Benjamin R. Davidson(202) 326-3055 I bdavidson@ftc.govDC Bar No. 975509Suzanne Barth(202) 326-3317 I sbarth@ftc.govMABarNo. 706122Federal Trade Commission600 Pennsylvania Ave., NW, CC-8528Washington, DC 20580Attorneys for Plaintiff Federal Trade CommissionPage 19 of20
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 20 of 36FOR DEFENDANTS:Date:3/31/22Nicolas MorganPAUL HASTINGS LLP515 South Flower StreetTwenty-Fifth FloorLos Angeles. CA 90071(213) 683-6181nicolasmorgan@paulhastings.comAttorney for Defendants Warrior Trading. Inc. \Varrior Operating, Inc., and Ross P. CameronDEFENDANTS:LDate:Ross P. Cameron, individually and as anofficer of \Varrior Trading. Inc. andWarrior Operating. Inc.f&\Varrior Trading, Inc.by its President, Ross P'. CameronILV/arriorOpcrating, Inc.,by its President, Ross P. CameronPage 20 of2O,s} ?: t /:2
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 21 of 36Attachment A
Document 6 Filed 05/25/22 Page 22 of 36§310.2Federal Trade CommissionAPPENDIX A TO PART 309---FIGURES FOR PART 309HYDROGENMINIMUMMINIMUM90 /o98 /oHYDROGENMETHANEfigur 1ELECTRICITY9.6 kW240 vac/40 ampsCONDUCTIVE(60 FR 26955, May 19, 1995, as amended at 69 FR 55339, Sept. 14, 2004; 78 FR 23835, Apr. 23 , 2013]PART 310-TELEMARKETING SALESRULE§310.1 Scope of regulations in thispart.Sec.310.1 Scope of regulations in t his part.310.2 Definitions.310.3 Deceptive t elemarketing acts or prac tices.310.4 Abusive telemarketing acts or practices.310.5 Recordkeeplng requirements.310.6 Exemptions.310.7 Ac tions by s tates and privat e persons.310.8 Fee for access to t he National Do NotCall Registry.310.9 Severab1l!t y.AUTHORITY: 15 U.S.C. 6101 108.SOURCE: 75 FR 48516, Aug. 10, 2010, unlessotherwise noted.This part implements the Tele marketing and Consumer Fraud andAbuse Prevent ion Act, 15 U.S.C. 61016108, as amended.§ 310.2Definitions.(a) Acquirer means a business organi zation, financial institution, or anagent of a business organization or fi nancial institution that has authorityfrom an organization that operates orlicenses a credit card system to author ize merchants to accept, transmit, orprocess payment by credit cardthrough the credit card system formoney, goods or services, or anythingelse of value.385
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 23 of 36§ 310.216 CFR Ch. I (1–1–21 Edition)(b) Attorney General means the chieflegal officer of a state.(c) Billing information means any datathat enables any person to access acustomer’s or donor’s account, such asa credit card, checking, savings, shareor similar account, utility bill, mortgage loan account, or debit card.(d) Caller identification service means aservice that allows a telephone subscriber to have the telephone number,and, where available, name of the calling party transmitted contemporaneously with the telephone call, anddisplayed on a device in or connectedto the subscriber’s telephone.(e) Cardholder means a person towhom a credit card is issued or who isauthorized to use a credit card on behalf of or in addition to the person towhom the credit card is issued.(f) Cash-to-cash money transfer meansthe electronic (as defined in section106(2) of the Electronic Signatures inGlobal and National Commerce Act (15U.S.C. 7006(2)) transfer of the value ofcash received from one person to another person in a different locationthat is sent by a money transfer provider and received in the form of cash.For purposes of this definition, moneytransfer provider means any person orfinancial institution that providescash-to-cash money transfers for a person in the normal course of its business, whether or not the person holdsan account with such person or financial institution. The term cash-to-cashmoney transfer includes a remittancetransfer, as defined in section 919(g)(2)of the Electronic Fund Transfer Act(‘‘EFTA’’), 15 U.S.C. 1693a, that is acash-to-cash transaction; however itdoes not include any transaction thatis:(1) An electronic fund transfer as defined in section 903 of the EFTA;(2) Covered by Regulation E, 12 CFR1005.20, pertaining to gift cards; or(3) Subject to the Truth in LendingAct, 15 U.S.C. 1601 et seq.(g) Cash reload mechanism is a device,authorization code, personal identification number, or other security measurethat makes it possible for a person toconvert cash into an electronic (as defined in section 106(2) of the ElectronicSignatures in Global and NationalCommerce Act (15 U.S.C. 7006(2)) formthat can be used to add funds to a general-use prepaid card, as defined inRegulation E, 12 CFR 1005.2, or an account with a payment intermediary.For purposes of this definition, a cashreload mechanism is not itself a general-use prepaid debit card or a swipereload process or similar method inwhich funds are added directly onto aperson’s own general-use prepaid cardor account with a payment intermediary.(h) Charitable contribution means anydonation or gift of money or any otherthing of value.(i) Commission means the FederalTrade Commission.(j) Credit means the right granted bya creditor to a debtor to defer paymentof debt or to incur debt and defer itspayment.(k) Credit card means any card, plate,coupon book, or other credit device existing for the purpose of obtainingmoney, property, labor, or services oncredit.(l) Credit card sales draft means anyrecord or evidence of a credit cardtransaction.(m) Credit card system means anymethod or procedure used to processcredit card transactions involving credit cards issued or licensed by the operator of that system.(n) Customer means any person who isor may be required to pay for goods orservicesofferedthroughtelemarketing.(o) Debt relief service means any program or service represented, directly orby implication, to renegotiate, settle,or in any way alter the terms of payment or other terms of the debt between a person and one or more unsecured creditors or debt collectors, including, but not limited to, a reductionin the balance, interest rate, or feesowed by a person to an unsecured creditor or debt collector.(p) Donor means any person solicitedto make a charitable contribution.(q) Established business relationshipmeans a relationship between a sellerand a consumer based on:(1) the consumer’s purchase, rental,or lease of the seller’s goods or servicesor a financial transaction between the386
Case 3:22-cv-30048-MGM Document 6 Filed 05/25/22 Page 24 of 36Federal Trade Commission§ 310.2consumer and seller, within the eighteen (18) months immediately precedingthe date of a telemarketing call; or(2) the consumer’s inquiry or application regarding a product or service offered by the seller, within the three (3)months immediately preceding thedate of a telemarketing call.(r) Free-to-pay conversion means, in anoffer or agreement to sell or provideany goods or services, a provisionunder which a customer receives aproduct or service for free for an initialperiod and will incur an obligation topay for the product or service if he orshe does not take affirmative action tocancel before the end of that period.(s) Investment opportunity means anything, tangible or intangible, that is offered, offered for sale, sold, or tradedbased wholly or in part on representations, either express or implied, aboutpast, present, or future income, profit,or appreciation.(t) Material means likely to affect aperson’s choice of, or conduct regarding, goods or services or a charitablecontribution.(u) Merchant means a person who isauthorized under a written contractwith an acquirer to honor or acceptcred
" means Warrior Trading, Inc., Warrior Operating, Inc., also d/b/a Warrior Trading, and their successors and assigns. 2. " Individual Defendant " means Ross P. Cameron. F. " Earnings Claim(s) " means any representation to a consumer, specific or general, about income, financial gains, percentage gains, profit, net profit, gross
United States District Court District of Utah Pro Hac Vice Registration STEP 2 Enter your PACER Username and Password.Click Login. STEP 3 Click the Maintenance tab. STEP 4 Click the Attorney Admissions / E‐File Registration link. STEP 5 From the Court Type list, select U.S. District Courts.From the Court list, select Utah District Court - NextGen.
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO [Return to Table of Contents] I.SCOPE, PURPOSE, AND CONSTRUCTION D.C.COLO.LCivR 1.1 SCOPE OF THE LOCAL CIVIL RULES (a) Title and Citation. These rules shall be known as the Local Rules of Practice of the United States District Court for the District of Colorado - Civil. These rules
courts of the Federal Government. This book is written for jurors selected to serve in the trial court of the Federal Government, the United States District Court. The types of cases that can be brought in this court have been fixed by the United States Congress according to our Federal Constitution. Cases in the United States District Courts
Table of Contents a. District 1 pg. 6 b. District 2 pg. 7 c. District 3 pg. 9 d. District 4 pg. 10 e. District 5 pg. 11 f. District 6 pg. 12 g. District 7 pg. 13 h. District 8 pg. 14 i. District 9 pg. 15 j. District 10 pg. 16 k. District 11 pg. 17 l. District 12 pg. 18 m. District 13 pg. 19 n. District 14 pg. 20
UNITED STATES OF AMERICA )) v. ) Criminal No. CR-05-86-P-H) CORDELL LOCHIN ) GOVERNMENT'S SUPPLEMENTAL SENTENCING MEMORANDUM NOW COMES the United States of America, by and through Paula D. Silsby, United States Attorney for the District of Maine, and Daniel J. Perry, Assistant United States Attorney, and
UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF NEW YORK ECF NEWSLETTER . 14 (347) 394 "Go Live Day" January 19, 2021 . United States Bankruptcy Court . Eastern District of New York . Conrad B. Duberstein United States Bankruptcy Courthouse . 271-C Cadman Plaza East, Suite 1595 . Brooklyn, NY 11201-1800 -1700 press 6. United States .
court assignments, pooling, authorization of leave, and efficient service to the Court and litigants. Each official court reporter in this district shall prepare and submit to the Court Operations Supervisor the quarterly report AO 40A, Attendance and Transcripts of U.S. Court Reporters, listing hours and days in court and any transcript backlog.
Nexus Technologies, Inc., Kim Anh Nguyen, and An Quoc Nguyen is DENIED. BY THE COURT: HONORABLE TIMOTHY J. SAVAGE United States District Court Case 2:08-cr-00522-TJS Document 135 Filed 12/11/2009 Page 1 of 16. IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA .
