Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 1 of 13

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA 

) 

) 

) 

Plaintiff, ) 

v. 

HIRERIGHT SOLUTIONS, INC. 

Defendant. 

) Civil Action No. 

) 

) 

) 

) 

) 

) 

) 

) 

STIPULATED FINAL JUDGMENT AND ORDER FOR 

CIVIL PENALTIES, PERMANENT INJUNCTION, AND OTHER EQUITABLE 

RELIEF 

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

Attorney General by the Federal Trade Commission ("FTC" or "Commission"), is concurrently 

filing its Complaint herein, which alleges that Defendant HireRight Solutions, Inc. has engaged 

in violations of the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681-1681x, and in unfair 

or deceptive acts or practices in violation of section 5 of the Federal Trade Commission Act 

("FTC Act"), 15 U.S.C. § 45(a), Defendant has been represented by the attorney whose name 

appears hereafter. The parties have agreed to entry of this Stipulated Final Judgment and Order 

for Civil Penalties, Permanent Injunction, and Other Equitable Relief ("Order") to resolve all 

matters in dispute in this action without trial or adjudication of any issue of law or fact herein. 

Defendant has waived service of the Summons and Complaint. 

Page 1 of 13 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA 

) 

) 

) 

Plaintiff, ) 

v. 

HIRERIGHT SOLUTIONS, INC. 

Defendant. 

) Civil Action No. 

) 

) 

) 

) 

) 

) 

) 

) 

STIPULATED FINAL JUDGMENT AND ORDER FOR 

CIVIL PENALTIES, PERMANENT INJUNCTION, AND OTHER EQUITABLE 

RELIEF 

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

Attorney General by the Federal Trade Commission ("FTC" or "Commission"), is concurrently 

filing its Complaint herein, which alleges that Defendant HireRight Solutions, Inc. has engaged 

in violations of the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681-1681x, and in unfair 

or deceptive acts or practices in violation of section 5 of the Federal Trade Commission Act 

("FTC Act"), 15 U.S.C. § 45(a), Defendant has been represented by the attorney whose name 

appears hereafter. The parties have agreed to entry of this Stipulated Final Judgment and Order 

for Civil Penalties, Permanent Injunction, and Other Equitable Relief ("Order") to resolve all 

matters in dispute in this action without trial or adjudication of any issue of law or fact herein. 

Defendant has waived service of the Summons and Complaint. 

Page 1 of 13 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 2 of 13

THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as 

follows: 

FINDINGS 

1. This Court has jurisdiction over the subj ect matter of this case and over the 

Parties. 

2. Venue in this district is proper under 28 U.S.C. §§ 1391(b) - (c) and 1395(a), and 

15 U.S.C. § 53(b). 

3. The Complaint states claims upon which relief may be granted against 

Defendant under sections 5(a), 13(b), and 16(a) ofthe Federal Trade Commission Act, 15 U.S.C. 

§§ 45(a), 53(b), and 56(a); and under sections 607(b), 609(a), 611(a)(1)(A), 611(a)(6), 613(a)(1), 

and 621 of the Fair Credit Reporting Act, 15 U.S.C. §§ 1681e(b), 1681g(a), 168li(a)(1)(A), 

168li(a)(6), 1681k(a)(1), and 1681s. 

4. Defendant makes no admissions to the allegations in the Complaint, 

other than the jurisdictional facts. 

5. Defendant waives: (a) all rights to seek appellate review or otherwise challenge 

or contest the validity of this Order; (b) any claims it may have against the Commission, its 

employees, representatives, or agents that relate to the matter stated herein; (c) all claims under 

the Equal Access to Justice Act, 28 U.S.C. § 2412, as amended by Pub. L. 104-121, 110 Stat. 

847,863-64 (1996); and (d) any rights to attorneys' fees that may arise under said provision of 

law. 

6. This action and the relief awarded herein are in addition to, and not in lieu of, 

other remedies as may be provided by law, including both civil and criminal remedies. 

Page 2 of 13 

THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED as 

follows: 

FINDINGS 

1. This Court has jurisdiction over the subj ect matter of this case and over the 

Parties. 

2. Venue in this district is proper under 28 U.S.C. §§ 1391(b) - (c) and 1395(a), and 

15 U.S.C. § 53(b). 

3. The Complaint states claims upon which relief may be granted against 

Defendant under sections 5(a), 13(b), and 16(a) ofthe Federal Trade Commission Act, 15 U.S.C. 

§§ 45(a), 53(b), and 56(a); and under sections 607(b), 609(a), 611(a)(1)(A), 611(a)(6), 613(a)(1), 

and 621 of the Fair Credit Reporting Act, 15 U.S.C. §§ 1681e(b), 1681g(a), 168li(a)(1)(A), 

168li(a)(6), 1681k(a)(1), and 1681s. 

4. Defendant makes no admissions to the allegations in the Complaint, 

other than the jurisdictional facts. 

5. Defendant waives: (a) all rights to seek appellate review or otherwise challenge 

or contest the validity of this Order; (b) any claims it may have against the Commission, its 

employees, representatives, or agents that relate to the matter stated herein; (c) all claims under 

the Equal Access to Justice Act, 28 U.S.C. § 2412, as amended by Pub. L. 104-121, 110 Stat. 

847,863-64 (1996); and (d) any rights to attorneys' fees that may arise under said provision of 

law. 

6. This action and the relief awarded herein are in addition to, and not in lieu of, 

other remedies as may be provided by law, including both civil and criminal remedies. 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 3 of 13

7. Entry of this Order is in the public interest. 

8. F or the purpose of this Order: 

a. "Defendant" shall mean HireRight Solutions and its successors and 

assIgns. 

b. The definitions set forth in the FCRA, 15 U.S.c. § 1681a, et seq., shall 

apply. 

ORDER 

I. CIVIL PENALTY 

IT IS ORDERED that: 

A. Judgment in the amount of2.6 million dollars ($2,600,000) is hereby entered 

against Defendant as a civil penalty for violations of the FCRA pursuant to section 621(a) of the 

Fair Credit Reporting Act, 15 U.S.C. § 1681s(a). 

B. Defendant shall make this payment within seven (7) business days ofthe date of 

service of this Order to the Treasurer of the United States by electronic fund transfer in 

accordance with instructions provided by the Consumer Protection Branch, Civil Division, U.S. 

Department of Justice, Washington, D.C. 20530, for appropriate disposition. 

C. In the event of any default in payment, which default continues for ten (10) days 

beyond the due date of payment, the entire unpaid penalty, together with interest, as computed 

pursuant to 28 U.S.C. § 1961, from the date of default to the date of payment, shall immediately 

become due and payable. 

D. Defendant relinquishes all dominion, control, and title to the funds paid to the 

fullest extent permitted by law. Defendant shall make no claim to or demand return of the funds, 

Page 3 of 13 

7. Entry of this Order is in the public interest. 

8. F or the purpose of this Order: 

a. "Defendant" shall mean HireRight Solutions and its successors and 

assIgns. 

b. The definitions set forth in the FCRA, 15 U.S.c. § 1681a, et seq., shall 

apply. 

ORDER 

I. CIVIL PENALTY 

IT IS ORDERED that: 

A. Judgment in the amount of2.6 million dollars ($2,600,000) is hereby entered 

against Defendant as a civil penalty for violations of the FCRA pursuant to section 621(a) of the 

Fair Credit Reporting Act, 15 U.S.C. § 1681s(a). 

B. Defendant shall make this payment within seven (7) business days ofthe date of 

service of this Order to the Treasurer of the United States by electronic fund transfer in 

accordance with instructions provided by the Consumer Protection Branch, Civil Division, U.S. 

Department of Justice, Washington, D.C. 20530, for appropriate disposition. 

C. In the event of any default in payment, which default continues for ten (10) days 

beyond the due date of payment, the entire unpaid penalty, together with interest, as computed 

pursuant to 28 U.S.C. § 1961, from the date of default to the date of payment, shall immediately 

become due and payable. 

D. Defendant relinquishes all dominion, control, and title to the funds paid to the 

fullest extent permitted by law. Defendant shall make no claim to or demand return of the funds, 

Page 3 of 13 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 4 of 13

directly or indirectly, through counselor otherwise. 

E. Defendant agrees that the facts as alleged in the Complaint filed in this action 

shall be taken as true, without further proof, in any subsequent civil litigation filed by or on 

behalf of the Commission to enforce its rights to any payment or money judgment pursuant to 

this Order. 

II. PROHIBITED BUSINESS ACTIVITIES 

IT IS FURTHER ORDERED that Defendant, and all other persons or entities within 

the scope of Fed. R. Civ. P. 65, whether acting directly or through any sole proprietorship, 

partnership, limited liability company, corporation, subsidiary, branch, division, device, or other 

business entity who receive actual notice of this Order by personal service or otherwise, are 

hereby permanently restrained and enjoined from: 

A. Failing to maintain reasonable procedures to assure the maximum possible 

accuracy of the information concerning the individual about whom a consumer report relates, as 

required by section 607(b) of the FCRA, 15 U.S.C. § 1681e(b), including but not limited to: 

1. failing to follow reasonable procedures to assure that the information 

contained in consumer reports it furnishes reflects the current public 

record status of consumers' information, such as expungement of a 

criminal record; 

2. failing to follow reasonable procedures to prevent the inclusion of multiple 

entries for the same criminal offense in a single report in a manner that 

would render the report inaccurate in violation of section 607 (b) of the 

FCRA, 15 U.S.C. § 1681e(b); and 

Page 4 of 13 

directly or indirectly, through counselor otherwise. 

E. Defendant agrees that the facts as alleged in the Complaint filed in this action 

shall be taken as true, without further proof, in any subsequent civil litigation filed by or on 

behalf of the Commission to enforce its rights to any payment or money judgment pursuant to 

this Order. 

II. PROHIBITED BUSINESS ACTIVITIES 

IT IS FURTHER ORDERED that Defendant, and all other persons or entities within 

the scope of Fed. R. Civ. P. 65, whether acting directly or through any sole proprietorship, 

partnership, limited liability company, corporation, subsidiary, branch, division, device, or other 

business entity who receive actual notice of this Order by personal service or otherwise, are 

hereby permanently restrained and enjoined from: 

A. Failing to maintain reasonable procedures to assure the maximum possible 

accuracy of the information concerning the individual about whom a consumer report relates, as 

required by section 607(b) of the FCRA, 15 U.S.C. § 1681e(b), including but not limited to: 

1. failing to follow reasonable procedures to assure that the information 

contained in consumer reports it furnishes reflects the current public 

record status of consumers' information, such as expungement of a 

criminal record; 

2. failing to follow reasonable procedures to prevent the inclusion of multiple 

entries for the same criminal offense in a single report in a manner that 

would render the report inaccurate in violation of section 607 (b) of the 

FCRA, 15 U.S.C. § 1681e(b); and 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 5 of 13

3. failing to follow reasonable procedures to prevent the provision of 

obviously erroneous consumer report information to employers, such as 

purported information on a single consumer that includes records of other 

consumers with different names, dates of birth, or other identifiers that are 

available in the public record. 

B. Failing to, upon request, clearly and accurately disclose to a consumer all 

information in the consumer's file at the time ofthe request, as required by section 609(a)(I) of 

the FCRA, 15 U.S.C. § 1681g(a)(1). 

C. Requiring that a consumer who disputes the completeness or accuracy of 

information in his or her file obtain a copy of his or her consumer report before Defendant will 

conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate 

and record the current status of the disputed information, or delete the information from the file 

before the end of the 30-day period beginning on the date on which Defendant receives the notice 

of dispute from the consumer, in violation of section 611(a)(1)(A) of the FCRA, 15 U.S.c. § 

168li(a)(1 )(A). 

D. Failing to provide written notice to the consumer of the results of a 

reinvestigation not later than five business days after its completion, as required by section 

611(a)(6) of the FCRA, 15 U.S.C. § 168li(a)(6). 

E. Failing to notify the consumer, at the time such information is reported to the user 

of the information, of the fact that public record information is being reported by the consumer 

reporting agency, together with the name and address of the person to whom such information is 

reported; or, in the alternative, failing to maintain strict procedures to insure that whenever public 

Page 5 of 13 

3. failing to follow reasonable procedures to prevent the provision of 

obviously erroneous consumer report information to employers, such as 

purported information on a single consumer that includes records of other 

consumers with different names, dates of birth, or other identifiers that are 

available in the public record. 

B. Failing to, upon request, clearly and accurately disclose to a consumer all 

information in the consumer's file at the time ofthe request, as required by section 609(a)(I) of 

the FCRA, 15 U.S.C. § 1681g(a)(1). 

C. Requiring that a consumer who disputes the completeness or accuracy of 

information in his or her file obtain a copy of his or her consumer report before Defendant will 

conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate 

and record the current status of the disputed information, or delete the information from the file 

before the end of the 30-day period beginning on the date on which Defendant receives the notice 

of dispute from the consumer, in violation of section 611(a)(1)(A) of the FCRA, 15 U.S.c. § 

168li(a)(1 )(A). 

D. Failing to provide written notice to the consumer of the results of a 

reinvestigation not later than five business days after its completion, as required by section 

611(a)(6) of the FCRA, 15 U.S.C. § 168li(a)(6). 

E. Failing to notify the consumer, at the time such information is reported to the user 

of the information, of the fact that public record information is being reported by the consumer 

reporting agency, together with the name and address of the person to whom such information is 

reported; or, in the alternative, failing to maintain strict procedures to insure that whenever public 

Page 5 of 13 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 6 of 13

record information which is likely to have an adverse effect on a consumer's ability to obtain 

employment is reported it is complete and up to date, as required by section 613(a)(1)-(2) of the 

FCRA, 15 U.S.C. § 1681k(a)(1)-(2). 

III. ORDER ACKNOWLEDGMENTS 

IT IS.FURTHER ORDERED that Defendant obtain acknowledgments of receipt of this 

Order: 

A. Defendant, within 7 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 3 years after entry of this Order, Defendant must deliver a copy of this Order 

to: (1) all of its officers, vice presidents, directors, and managers; (2) all of its employees, agents, 

and 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 

Compliance Reporting. Delivery must occur within 7 days of entry of this Order for current 

personnel. To all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which Defendant delivered a copy of this Order, 

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this 

Order. 

IV. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

Commission: 

A. One hundred eighty days after entry ofthis Order, Defendant must submit a 

compliance report, sworn under penalty of perjury. 

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record information which is likely to have an adverse effect on a consumer's ability to obtain 

employment is reported it is complete and up to date, as required by section 613(a)(1)-(2) of the 

FCRA, 15 U.S.C. § 1681k(a)(1)-(2). 

III. ORDER ACKNOWLEDGMENTS 

IT IS.FURTHER ORDERED that Defendant obtain acknowledgments of receipt of this 

Order: 

A. Defendant, within 7 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 3 years after entry of this Order, Defendant must deliver a copy of this Order 

to: (1) all of its officers, vice presidents, directors, and managers; (2) all of its employees, agents, 

and 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 

Compliance Reporting. Delivery must occur within 7 days of entry of this Order for current 

personnel. To all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which Defendant delivered a copy of this Order, 

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this 

Order. 

IV. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

Commission: 

A. One hundred eighty days after entry ofthis Order, Defendant must submit a 

compliance report, sworn under penalty of perjury. 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 7 of 13

1. Defendant must: (a) designate at least one telephone number and an 

email, physical, and postal address as points of contact, which 

representatives of the Commission and Plaintiff may use to communicate 

with Defendant; (b) identify all of 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 

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

and sales;· (d) describe in detail whether and how 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. 

B. For 5 years following entry of this Order, Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the following: 

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

or (b) the structure of Defendant or any entity that Defendant has any 

ownership interest in or directly or indirectly controls 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. 

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

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

within 14 days of its filing. 

Page 7 of 13 

1. Defendant must: (a) designate at least one telephone number and an 

email, physical, and postal address as points of contact, which 

representatives of the Commission and Plaintiff may use to communicate 

with Defendant; (b) identify all of 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 

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

and sales;· (d) describe in detail whether and how 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. 

B. For 5 years following entry of this Order, Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the following: 

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

or (b) the structure of Defendant or any entity that Defendant has any 

ownership interest in or directly or indirectly controls 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. 

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

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

within 14 days of its filing. 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 8 of 13

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. HireRight Solutions, Inc. 

V. RECORDKEEPING PROVISIONS 

IT IS FURTHER ORDERED that Defendant must create certain records for 5 years after 

entry of the Order, and retain each such record for 5 years. Specifically, Defendant must 

maintain the following records: 

A. Accounting records showing the revenues from all goods or services sold, all costs 

incurred in generating those revenues, and the resulting net profit or loss; 

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

employee or otherwise, that person's: name, addresses, and telephone numbers; job title or 

position; dates of service; and, if applicable, the reason for termination; 

C. Customer files showing the names, addresses, telephone numbers, dollar amounts 

paid, and the quantity and description of goods or services purchased, to the extent such 

information is obtained in the ordinary course of business; 

Page 8 of 13 

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. HireRight Solutions, Inc. 

V. RECORDKEEPING PROVISIONS 

IT IS FURTHER ORDERED that Defendant must create certain records for 5 years after 

entry of the Order, and retain each such record for 5 years. Specifically, Defendant must 

maintain the following records: 

A. Accounting records showing the revenues from all goods or services sold, all costs 

incurred in generating those revenues, and the resulting net profit or loss; 

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

employee or otherwise, that person's: name, addresses, and telephone numbers; job title or 

position; dates of service; and, if applicable, the reason for termination; 

C. Customer files showing the names, addresses, telephone numbers, dollar amounts 

paid, and the quantity and description of goods or services purchased, to the extent such 

information is obtained in the ordinary course of business; 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 9 of 13

D. Complaints and refund requests, whether received directly or indirectly, such as 

through a third party, and any response; 

E. Copies of all training materials and written policies and procedures that relate to 

Defendant's activities as alleged in the Complaint or Defendant's compliance with the provisions 

of this Order; and 

F. All records and documents necessary to demonstrate full compliance with each 

provision of this Order, including all submissions to the Commission. 

VI. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant's 

compliance with this Order, including any failure to transfer any assets as required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission or Plaintiff, 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, provided that, Defendant, after attempting to resolve a dispute without court 

action and for good cause shown, may file a motion with this Court seeking an order including 

one or more of the protections set forth in Rule 26 (c). 

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

communicate directly with Defendant. Defendant must permit representatives of the 

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

Page 9 of 13 

D. Complaints and refund requests, whether received directly or indirectly, such as 

through a third party, and any response; 

E. Copies of all training materials and written policies and procedures that relate to 

Defendant's activities as alleged in the Complaint or Defendant's compliance with the provisions 

of this Order; and 

F. All records and documents necessary to demonstrate full compliance with each 

provision of this Order, including all submissions to the Commission. 

VI. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant's 

compliance with this Order, including any failure to transfer any assets as required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission or Plaintiff, 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, provided that, Defendant, after attempting to resolve a dispute without court 

action and for good cause shown, may file a motion with this Court seeking an order including 

one or more of the protections set forth in Rule 26 (c). 

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

communicate directly with Defendant. Defendant must permit representatives of the 

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

Page 9 of 13 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 10 of 13

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 Defendant 

or any individual or entity affiliated with Defendant, 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. 

VII. 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. 

VIII. COSTS AND ATTORNEYS' FEES 

IT IS FURTHER ORDERED that each party shall bear its own costs and attorneys' fees 

incurred in connection with this action. 

The parties hereby stipulate to the entry of the foregoing Order, which shall constitute a 

final Order in this action. 

IT IS SO ORDERED: 

Dated this ___ day of ________ " 2012 

UNITED STATES DISTRICT JUDGE 

Page 10 of 13 

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 Defendant 

or any individual or entity affiliated with Defendant, 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. 

VII. 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. 

VIII. COSTS AND ATTORNEYS' FEES 

IT IS FURTHER ORDERED that each party shall bear its own costs and attorneys' fees 

incurred in connection with this action. 

The parties hereby stipulate to the entry of the foregoing Order, which shall constitute a 

final Order in this action. 

IT IS SO ORDERED: 

Dated this ___ day of ________ , 2012 

UNITED STATES DISTRICT JUDGE 

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Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 11 of 13

FOR THE UNITED STATES 

OF AMERICA: 

STUART F. DELERY 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

MAAME EWUSI-MENSAH FRIMPONG 

Acting Deputy Assistant Attorney General 

Civil Division 

MICHAEL S. BLUME 

Director 

Consumer Protection Branch 

Trial i\ttorney 

Consumer Protection Branch 

U.S. Department of Justice 

PO Box 386 

Washington, D.C. 20044 

Phone: 202-307-6154 

alan.phelps@usdoj.gov 

FOR THE FEDERAL TRADE 

COMMISSION: 

MANEESHA MITHAL 

Associate Director 

Division of Privacy and Identity Protection 

ROBERT SCHOSHINSKI 

Assistant Director 

Division of Privacy and Identity Protection 

ANTHONY RODRIGUEZ 

Attomey 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Ave. NW 

Mail Stop NJ-8100 

Washington, D. C. 

Phone: 202-326-2757 

Facsimile: 202-326-3062 

TIFF ANY GEORGE 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Ave. NW 

Mail Stop NJ-8100 

Washington, D.C. 

Phone: 202-326-3040 

Facsimile: 202-326-3062 

Page 11 of 11 

FOR THE UNITED STATES 

OF AMERICA: 

STUART F. DELERY 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

MAAME EWUSI-MENSAH FRIMPONG 

Acting Deputy Assistant Attorney General 

Civil Division 

MICHAEL S. BLUME 

Director 

Consumer Protection Branch 

Trial i\ttorney 

Consumer Protection Branch 

U.S. Department of Justice 

PO Box 386 

Washington, D.C. 20044 

Phone: 202-307-6154 

alan.phelps@usdoj.gov 

FOR THE FEDERAL TRADE 

COMMISSION: 

MANEESHA MITHAL 

Associate Director 

Division of Privacy and Identity Protection 

ROBERT SCHOSHINSKI 

Assistant Director 

Division of Privacy and Identity Protection 

ANTHONY RODRIGUEZ 

Attomey 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Ave. NW 

Mail Stop NJ-8100 

Washington, D. C. 

Phone: 202-326-2757 

Facsimile: 202-326-3062 

TIFF ANY GEORGE 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Ave. NW 

Mail Stop NJ-8100 

Washington, D.C. 

Phone: 202-326-3040 

Facsimile: 202-326-3062 

Page 11 of 11 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 12 of 13

FOR THE FEDERAL TRADE COMMISSION: 

MANEESHA MITHAL 

Associate Director 

~ 

Division of Privacy and Identity Protection 

7~RT SCHOSHINSKI 

Assistant Director 

Division of Privacy and Identity Protection 

~~ Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-2757 

Fax: (202) 326-3062 

TIF s~~t~ Y OR E 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-3040 

Fax: (202) 326-3062 

Page 12 of 13 

FOR THE FEDERAL TRADE COMMISSION: 

MANEESHA MITHAL 

Associate Director 

~ 

Division of Privacy and Identity Protection 

7~RT SCHOSHINSKI 

Assistant Director 

Division of Privacy and Identity Protection 

~~ Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-2757 

Fax: (202) 326-3062 

TIF s~~t~ Y OR E 

Attorney 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, NW 

Mail Stop NJ-8100 

Washington D.C. 20001 

Tel: (202) 326-3040 

Fax: (202) 326-3062 

Page 12 of 13 
Case 1:12-cv-01313 Document 2-1 Filed 08/08/12 Page 13 of 13

FOR THE DEFENDANT: 

~-- President and Chief Executive Officer 

HireRight Solutions, Inc. 

~ee Attorney 

L~DIAPARNES ~ Wilson Sonsini Goodrich & Rosati 

1700 K Street, NW, Fifth Floor 

Washington, DC 20006 

Counsel for Defendant 

Page 13 of 13 

FOR THE DEFENDANT: 

~-- President and Chief Executive Officer 

HireRight Solutions, Inc. 

~ee Attorney 

L~DIAPARNES ~ Wilson Sonsini Goodrich & Rosati 

1700 K Street, NW, Fifth Floor 

Washington, DC 20006 

Counsel for Defendant 

Page 13 of 13