UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA,

Plaintiff,

v.

VERSATILE MARKETING SOLUTIONS, 

INC., a Massachusetts corporation, also doing 

business as VMS Alarms, VMS, Alliance 

Security, and Alliance Home Protection,

and

JASJIT GOTRA, individually and as an 

officer of Versatile Marketing Solutions, Inc.,

Defendants. 

Case No. 1:14-cv-10612

STIPULATED FINAL ORDER

FOR PERMANENT INJUNCTION 

AND CIVIL PENALTY JUDGMENT

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“Commission” or “FTC”), filed its 

Complaint for Civil Penalties, Permanent Injunction, and Other Relief (“Complaint”) in this 

matter, pursuant to Sections 5(a), 5(m)(1)(A), 13(b), 16(a)(1), and 19 of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), 56(a)(1), and 57b, and 

Section 6 of the Telemarketing and Consumer Fraud and Abuse Prevention Act (the 

“Telemarketing Act”), 15 U.S.C. § 6105. Defendants have waived service of the summons and

the Complaint. Plaintiff and Defendants stipulate to the entry of this Stipulated Final Order for 

Permanent Injunction and Civil Penalty Judgment (“Order”) to resolve all matters in dispute in 

this action between them.

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THEREFORE, IT IS ORDERED as follows:

FINDINGS

1. This Court has jurisdiction over this matter.

2. The Complaint charges that Defendants engaged in deceptive acts or practices in 

violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the FTC’s Telemarketing Sales 

Rule (the “TSR” or “Rule”), as amended, 16 C.F.R. Part 310, in the Telemarketing of their 

products and services.

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 to Justice 

Act, 28 U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, 

and agree to bear their own costs and attorneys’ fees. Defendants waive and release any claims 

that they may have against Plaintiff, the Commission, and their agents that relate to this action.

5. Defendants and Plaintiff waive all rights to appeal or otherwise challenge or 

contest the validity of this Order.

DEFINITIONS

For the purpose of this Order, the following definitions apply:

A. “Caller Identification Service” means a service that allows a telephone 

subscriber to have the telephone number, and, where available, name of the calling party 

transmitted contemporaneously with the telephone call, and displayed on a device in or 

connected to the subscriber’s telephone.

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B. “Defendants” means the Individual Defendant and the Corporate Defendant, 

individually, collectively, or in any combination.

1. “Corporate Defendant” means Versatile Marketing Solutions, Inc., also 

doing business as VMS Alarms, VMS, Alliance Security, or Alliance 

Home Protection, and its successors and assigns.

2. “Individual Defendant” means Jasjit Gotra.

C. “Entity-Specific Do Not Call List” means a list of telephone numbers 

maintained by a Seller or Telemarketer of persons who have previously stated that they do not 

wish to receive Outbound Telephone Calls made by or on behalf of the Seller or Telemarketer.

D. “Established Business Relationship” means a relationship between a Seller and 

a person based on: (a) the person’s purchase, rental, or lease of the Seller’s goods or services or 

a financial transaction between the Seller and person, within the eighteen months immediately 

preceding the date of the Telemarketing call; or (b) the person’s inquiry or application regarding 

a product or service offered by the Seller, within the three months immediately preceding the 

date of a Telemarketing call.

E. “Lead Generator” means any person that provides, in exchange for 

consideration, consumer information to a Seller or Telemarketer for use in the marketing of any 

goods or services.

F. “National Do Not Call Registry” means the “do-not-call” registry of telephone 

numbers maintained by the Commission pursuant to 16 C.F.R. § 310.4(b)(1)(iii)(B).

G. “Outbound Telephone Call” means a telephone call initiated by a Telemarketer

to induce the purchase of goods or services or to solicit a charitable contribution.

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H. “Representatives” means Defendant’s officers, agents, servants, employees and 

those persons in active concert or participation with them who receive actual notice of this Order 

by personal service or otherwise.

I. “Seller” means any person who, in connection with a Telemarketing transaction, 

provides, offers to provide, or arranges for others to provide goods or services to the customer in 

exchange for consideration, whether or not such person is under the jurisdiction of the 

Commission.

J. “Telemarketer” means any person who, in connection with Telemarketing, 

initiates or receives telephone calls to or from a customer or donor, whether or not such person is 

under the jurisdiction of the Commission.

K. “Telemarketing” means a plan, program, or campaign which is conducted to 

induce the purchase of goods or services or a charitable contribution, by use of one or more 

telephones and which involves more than one interstate telephone call.

ORDER

I. Prohibition Against

Abusive Telemarketing Practices

IT IS ORDERED that, in connection with Telemarketing, Defendants and their 

Representatives are permanently restrained and enjoined from engaging in, causing others to 

engage in, or assisting others engaging in, any of the following practices:

A. Initiating any Outbound Telephone Call to any person at a telephone number on 

the National Do Not Call Registry, unless Defendants prove that:

1. Defendants have obtained the express agreement, in writing, of such 

person to place calls to that person. Such written agreement shall clearly 

evidence such person’s authorization that calls made by or on behalf of 

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Defendants may be placed to that person, and shall include the telephone 

number to which the calls may be placed and the signature of that person;

or

2. Defendants have an Established Business Relationship with such person,

and that person has not previously stated that he or she does not wish to 

receive Outbound Telephone Calls made by or on behalf of Defendants;

B. Initiating any Outbound Telephone Call to a person when that person has 

previously stated that he or she does not wish to receive an Outbound Telephone Call made by or 

on behalf of Defendants; 

C. Initiating any Outbound Telephone Call to a telephone number within a given 

area code when the annual fee for access to the telephone numbers within that area code that are 

on the National Do Not Call Registry has not been paid by or on behalf of Defendants, unless the 

telephone call is:

1. a solicitation to induce charitable contributions;

2. to a business; 

3. to persons who have given the Seller their express agreement, in writing 

and signed, to receive calls from Defendants; or

4. to persons who have an Established Business Relationship with 

Defendants;

D. Abandoning, or causing others to abandon, any Outbound Telephone Call to a 

person by failing to connect the call to a live operator within two seconds of the person’s 

completed greeting, unless Defendants or their Representatives prove that the following four 

conditions are met:

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1. Defendants and their Representatives employ technology that ensures 

abandonment of no more than three percent of all calls answered by a 

person, measured over the duration of a single calling campaign, if less 

than thirty days, or separately over each successive 30-day period or 

portion thereof that the campaign continues; 

2. Defendants and their Representatives, for each Telemarketing call placed, 

allow the telephone to ring for at least fifteen seconds or four rings before 

disconnecting an unanswered call;

3. Whenever a live operator is not available to speak with the person 

answering the call within two seconds after the person’s completed 

greeting, Defendants or their Representatives promptly play a recorded 

message that states Defendants’ name and telephone number; and

4. Defendants or their Representatives retain records establishing compliance 

with the preceding three conditions;

E. Initiating any Outbound Telephone Call in which Defendants or their 

Representatives fail to disclose truthfully, promptly, and in a clear and conspicuous manner the 

Defendants’ identity, that the purpose of the call is to sell goods or services, and the nature of the 

goods or services;

F. Initiating any Outbound Telephone Call in which Defendants or their 

Representatives fail to transmit or cause to be transmitted to any Caller Identification Service in 

use by a recipient of a Telemarketing call either: (i) the telephone number and name of the 

Telemarketer making the call; or (ii) Defendants’ name and customer service telephone number;

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G. Initiating any Outbound Telephone Call that delivers a prerecorded message, 

other than a prerecorded message permitted for compliance with Section I.D.3 of this Order, 

unless Defendants prove that:

1. Prior to making any such call to induce the purchase of any good or 

service, Defendants have obtained from the recipient of the call an express 

agreement, in writing, that:

a. Defendants obtained only after a clear and conspicuous disclosure 

that the purpose of the agreement is to authorize Defendants to 

place prerecorded calls to such person;

b. Defendants obtained without requiring, directly or indirectly, that 

the agreement be executed as a condition of purchasing any good 

or service;

c. evidences the willingness of the recipient of the call to receive 

calls that deliver prerecorded messages by or on behalf of 

Defendants; and

d. includes such person’s telephone number and signature; and

2. In any such call to induce the purchase of any good or service, 

Defendants:

a. allow the telephone to ring for at least fifteen (15) seconds or four 

(4) rings before disconnecting an unanswered call; and

b. within two (2) seconds after the completed greeting of the person 

called, plays a prerecorded message that promptly discloses 

Defendants’ identity, that the purpose of the call is to sell goods or 

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services, and the nature of the goods or services, followed 

immediately by a disclosure of one or both of the following:

i. in the case of a call that could be answered in person by a 

consumer, that the person called can use an automated 

interactive voice and/or keypress-activated opt-out 

mechanism to assert a do-not-call request at any time 

during the message. The mechanism must:

(a) automatically add the number called to Defendants’ 

Entity-Specific Do Not Call List;

(b) once invoked, immediately disconnect the call; and

(c) be available for use at any time during the message; 

and

ii. in the case of a call that could be answered by an answering 

machine or voicemail service, that the person called can use 

a toll free-number to assert a do-not-call request. The 

number provided must connect directly to an automated 

interactive voice or keypress-activated opt-out mechanism 

that:

(a) automatically adds the number called to 

Defendants’ Entity-Specific Do Not Call List;

(b) immediately thereafter disconnects the call; and

(c) is accessible at any time throughout the duration of

the Telemarketing campaign. 

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II. Lead Generator Review, Notice, and Termination

IT IS FURTHER ORDERED that:

A. Defendant or its Representatives shall, within ninety (90) days of the date of entry 

of this Order: 

1. Review and determine the methods used by Defendants’ existing Lead 

Generators to obtain the leads sold or offered for sale to Defendants and, if 

those leads were obtained by means that do not comply with this Order, 

Defendants shall immediately cease purchasing such leads from the Lead 

Generator;

2. Provide, electronically or otherwise, all of Defendants’ existing Lead 

Generators with: (i) a copy of this Order; and (ii) a written notice stating 

that, if the Lead Generator sells any leads to Defendants that do not 

comply with this Order, Defendants will immediately cease purchasing 

such leads from the Lead Generator; and

3. Obtain from all of Defendants’ existing Lead Generators an electronic 

acknowledgment or other signed and dated statement acknowledging 

receipt of this Order and the written notice set forth in the preceding 

subparagraph.

B. Prior to purchasing leads from any new Lead Generator, Defendants shall:

1. Review and determine the methods used by the Lead Generator to obtain 

leads offered for sale to Defendants and, if those leads were obtained by 

means that do not comply with this Order, Defendants are prohibited from 

purchasing such leads;

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2. Provide, electronically or otherwise, each new Lead Generator with: (i) a 

copy of this Order; and (ii) a written notice stating that, if the Lead 

Generator sells any leads to Defendants that do not comply with this 

Order, Defendants will immediately cease purchasing leads from the Lead 

Generator; and

3. Obtain from each new Lead Generator an electronic acknowledgment or 

other signed and dated statement acknowledging receipt of this Order and 

the written notice set forth in the preceding subparagraph.

III. Monetary Judgment for

Civil Penalty and Partial Suspension

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Three Million, Four Hundred Thousand Dollars 

($3,400,000) is entered in favor of Plaintiff against Defendants, jointly and severally, as a civil 

penalty.

B. Defendants are ordered to pay to Plaintiff, by making payment to the Treasurer of 

the United States, a total of Three Hundred Twenty Thousand, Seven Hundred Dollars 

($320,700) pursuant to the schedule, terms, and conditions set forth below:

1. Defendants stipulate that, at the time of Defendants’ signing of this Order, 

their undersigned counsel holds in escrow Fifty-Two Thousand Dollars 

($52,000) (“Escrow Amount”) for no purpose other than payment to 

Plaintiff. Within seven (7) days of entry of this Order, the Escrow 

Amount shall be transferred to Plaintiff by electronic fund transfer in 

accordance with instructions provided by a representative of Plaintiff.

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2. Payment of the remaining Two Hundred Sixty-Eight Thousand, Seven 

Hundred Dollars ($268,700) must be made within thirty (30) days of entry 

of this Order, or by March 1, 2014, whichever is later, by electronic fund 

transfer in accordance with instructions provided by a representative of 

Plaintiff.

3. Upon completion of both such payments, the remainder of the judgment is 

suspended, subject to the Subsections below.

C. The Commission’s and Plaintiff’s agreement to the suspension of part of the 

judgment is expressly premised upon:

1. The truthfulness, accuracy, and completeness of Defendants’ sworn 

financial statements and related documents (collectively, “financial 

representations”) at the time submitted to the Commission, namely: 

a. The Financial Statement of Individual Defendant Jasjit Gotra

signed on October 23, 2013 and bearing Bates stamps FIN0100992 to 0101007;

b. The Financial Statement of Corporate Defendant VMS signed by 

Jasjit Gotra on October 23, 2013 and bearing Bates stamps FIN0101008 to 0101022; and

c. The additional documentation submitted on Defendants’ behalf by 

Defendants’ counsel to Commission counsel Bikram Bandy 

bearing Bates stamps FIN-0100001 to 0100991 and FIN-0101023 

to 0101030; and

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2. Defendants’ payment of Three Hundred Twenty Thousand, Seven 

Hundred Dollars ($320,700) in accordance with the schedule and all terms 

and conditions set forth in Subsection B, above.

D. The suspension of the judgment will be lifted as to any Defendant if, upon motion 

by the Commission or Plaintiff, the Court finds that Defendant failed to disclose any material 

asset, materially misstated the value of any asset, or made any other material misstatement or 

omission in the financial representations identified above.

E. If the suspension of the judgment is lifted, the judgment becomes immediately 

due as to one or both Defendants, as appropriate, in the amount specified in Subsection A above 

(which the parties stipulate only for purposes of this Section represents the amount of the civil 

penalty for the violations alleged in the Complaint), less any payment previously made pursuant 

to this Section, plus interest computed from the date of entry of this Order.

F. Defendants relinquish dominion and all legal and equitable right, title, and interest 

in all assets transferred pursuant to this Order and may not seek the return of any assets.

G. The facts alleged in the Complaint will be taken as true, without further proof, in 

any subsequent civil litigation brought solely by or on behalf of the Commission, including in a 

proceeding to enforce its rights to any payment or monetary judgment pursuant to this Order.

H. Defendants agree that the judgment represents a civil penalty owed to the 

government of the United States, is not compensation for actual pecuniary loss, and, therefore, as 

to the Individual Defendant, it is not subject to discharge under the Bankruptcy Code pursuant to 

11 U.S.C. § 523(a)(7).

I. Defendants acknowledge that their Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), may be used for collecting and 

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reporting on any delinquent amount arising out of this Order, in accordance with 31 U.S.C. §

7701.

IV. COOPERATION

IT IS FURTHER ORDERED that Defendants must fully cooperate with representatives 

of Plaintiff and the Commission in this case and in any investigation related to or associated with 

the transactions or the occurrences that are the subject of the Complaint. Defendants must 

provide truthful and complete information, evidence, and testimony. Individual Defendant must 

appear and Corporate Defendant must cause its officers, employees, Representatives, or agents to 

appear for interviews, discovery, hearings, trials, and any other proceedings that a Plaintiff or 

Commission representative may reasonably request upon five days written notice, or other 

reasonable notice, at such places and times as a Plaintiff or Commission representative may 

designate, without the service of a subpoena.

V. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of this 

Order:

A. Each Defendant, within seven days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury.

B. For five years after entry of this Order, Individual Defendant for any business that 

he, individually or collectively with any other Defendants, is the majority owner or controls 

directly or indirectly, and Corporate Defendant, must deliver a copy of this Order to: (1) all 

principals, officers, directors, and LLC managers and members; (2) all employees, agents, and 

other Representatives who participate in conduct related to the subject matter of the Order; and 

(3) any business entity resulting from any change in structure as set forth in the Section titled 

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Compliance Reporting. Delivery must occur within seven 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 this 

Order, that Defendant must obtain, within 30 days, a signed and dated acknowledgment of 

receipt of this Order.

VI. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission:

A. One year after entry of this Order, each Defendant must submit a compliance 

report, sworn under penalty of perjury:

1. Each Defendant must: (a) identify the primary physical, postal, and email 

address and telephone number, as designated points of contact, which 

representatives of the Commission and Plaintiff 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 each business, including the goods 

and services offered, the means of advertising, marketing, and sales, and 

the involvement of any other Defendant (which Individual Defendant must 

describe if he knows or should know due to his own involvement); 

(d) describe in detail whether and how that Defendant is in compliance 

with each Section of this Order; and (e) provide a copy of each Order 

Acknowledgment obtained pursuant to this Order, unless previously 

submitted to the Commission. 

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2. Additionally, Individual Defendant must: (a) identify all telephone 

numbers and all physical, postal, email and Internet addresses, including 

all residences; (b) identify all business activities, including any business 

for which he performs services whether as an employee or otherwise and 

any entity in which he has any ownership interest; and (c) describe in 

detail his involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership.

B. For ten years after entry of this Order, each Defendant must submit a compliance 

notice, sworn under penalty of perjury, within fourteen days of any change in the following:

1. Each Defendant must report any change in: (a) any designated point of 

contact; or (b) the structure of Corporate Defendant or any entity that 

Defendant has any ownership interest in or controls directly or indirectly 

that may affect compliance obligations arising under this Order, including:

creation, merger, sale, or dissolution of the entity or any subsidiary, 

parent, or affiliate that engages in any acts or practices subject to this 

Order.

2. Additionally, Individual Defendant must report any change in: (a) name, 

including aliases or fictitious name, or residence address; or (b) title or 

role in any business activity, including any business for which he performs 

services whether as an employee or otherwise and any entity in which he 

has any ownership interest, and identify the name, physical address, and 

any Internet address of the business or entity.

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C. Each Defendant must submit to the Commission notice of the filing of any 

bankruptcy petition, insolvency proceeding, or similar proceeding by or against such Defendant 

within fourteen days of its filing.

D. Any submission to the Commission required by this Order to be sworn under 

penalty 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 the United States of America 

that the foregoing is true and correct. Executed on: _____” and supplying the date, signatory’s 

full name, title (if applicable), and signature.

E. Unless otherwise directed by a Commission representative in writing, all submissions 

to the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by overnight 

courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of 

Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin: FTC v. Versatile Marketing Solutions, Inc., 

Matter Number 1223162. 

VII. RECORDKEEPING

IT IS FURTHER ORDERED that Defendants must create certain records for ten years 

after entry of the Order, and retain each such record for five years. Specifically, Corporate 

Defendant, in connection with Telemarketing, and Individual Defendant for any business that he, 

individually or collectively with any other Defendants, is a majority owner or controls directly or 

indirectly, must create and retain the following records:

A. accounting records showing the revenues from all goods or services sold;

B. personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person’s: name; addresses; telephone numbers; job title or position; 

dates of service; and (if applicable) the reason for termination;

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C. records of all consumer complaints concerning the subject matter of the Order, 

whether received directly or indirectly, such as through a third party, and any response;

D. all records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and

E. all records relating to Lead Generators from whom Defendants purchase leads for 

Telemarketing, including contracts with such Lead Generators.

VIII. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’ compliance 

with this Order, including the financial representations upon which part of the judgment was 

suspended and any failure to transfer any assets as required by this Order:

A. Within fourteen days of receipt of a written request from a representative of the 

Commission or Plaintiff, each Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for depositions; 

and produce documents for inspection and copying. The Commission and Plaintiff are also 

authorized to obtain discovery, without further leave of court, using any of the procedures 

prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 31, 33, 

34, 36, 45, and 69.

B. For matters concerning this Order, the Commission and Plaintiff are authorized to 

communicate directly with each Defendant. Defendant must permit representatives of the 

Commission and Plaintiff to interview any employee or other person affiliated with any 

Defendant who has agreed to such an interview. The person interviewed may have counsel 

present.

C. The Commission and Plaintiff may use all other lawful means, including posing, 

through its representatives as consumers, suppliers, or other individuals or entities, to Defendants 

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or any individual or entity affiliated with Defendants, without the necessity of identification or 

prior notice. Nothing in this Order limits the Commission’s lawful use of compulsory process, 

pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1.

IX. RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order.

SO ORDERED, this _____ day of __________, 2013.

United States District Judge

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SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FOR THE UNITED STATES OF AMERICA: 

STUARTF.DELERY 

Assistant Attorney General, Civil Division 

U.S. DEPARTMENT OF JUSTICE 

MAAME EWUSl-MENSAH FRIMPONG 

Deputy Assistant Attorney General 

Civil Division 

MICHAELS. BLUME 

Director 

Consumer Protection Branch 

ANDY CLARK 

Assistant Director 

Consumer Protection Branch 

U.S. Department of Justice 

P.0.Box386 

Washington, D.C. 20044 

PHONE: 202-307-0067 

FAx::202-514-8742 

Andrew.Clark@usdoj.gov 

~ENTWISTLE L~-

Trial Attorney 

Consumer Protection Branch 

U.S. Department ofJustice 

P.0.Box386 

Washington, D.C. 20044 

PHONE: 202-305-3630 

FAx:: 202-514-8742 

Ann.Entwistle@usdoj.gov 

19 

Case 1:14-cv-10612-PBS Document 2-1 Filed 03/10/14 Page 19 of 20
bbandy@ftc.gov, jevansl@ftc.gov 

FOR DEFENDANTS: .• .. • • ··-·-·-- ·--- :'> 

... __ _ 

mdividually and as an officer of Date 

keting Solutions, Inc. 

/' 

'I'' ~·- - ./ <'-

-

Gerard M. Stegmaier, Esq. (VSB #45893) 

Wilson Sonsini Goodrich & Rosati, P.C. 

1700 K Street, NW, 5th Floor 

Washington, DC 20006 

(202) 973-8809 (direct) 

(202) 973-8899 (facsimile) 

gstegmaier@wsgr.com 

Attorney for Defendants 

12:'13/13 

Date 

20 

) 3 . 

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