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182-3084

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Joseph J. Simons, Chairman

Noah Joshua Phillips 

Rohit Chopra

Rebecca Kelly Slaughter

Christine S. Wilson

In the Matter of

STAFFORDSHIRE PROPERTY MANAGEMENT, 

LLC, a limited liability company, and

AARON FISCHER, individually and as manager of 

STAFFORDSHIRE PROPERTY MANAGEMENT, 

LLC.

DOCKET NO. C-4682

COMPLAINT

The Federal Trade Commission, having reason to believe that Staffordshire Property 

Management, LLC and Aaron Fischer, individually and as owner and manager of Staffordshire 

Property Management, LLC (collectively, “Respondents”) have violated the Consumer Review 

Fairness Act of 2016, and it appearing to the Commission that this proceeding is in the public 

interest, alleges:

1. Respondent Staffordshire Property Management, LLC (“Staffordshire”) is a Maryland 

limited liability company with its principal office or place of business at 108 East Preston Street, 

Apt. 1, Baltimore, Maryland 21202. Staffordshire operates a residential property management 

service and processes consumer applications to rent properties that it manages. 

2. Respondent Aaron Fischer is owner and manager of Staffordshire. Individually or in 

concert with others, he controlled or participated in the acts and practices of Staffordshire, 

including the acts and practices alleged in this complaint. His principal office or place of 

business is the same as that of Staffordshire.

3. The acts and practices of Respondents alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act, 15 

U.S.C. § 44.
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Course of Conduct

4. Between approximately February 2016 and October 2018, Respondents used, in their 

form contracts offered to hundreds of prospective renters in the course of processing their 

applications to rent properties that Respondents manage, the following provision:

The Applicant consents, whether approved or not approved, to hold and maintain 

the terms, conditions, and communications related to Staffordshire Property 

Management, this application, and application process in strict confidence, and

specifically agrees not to disparage Staffordshire Property Management, and any 

of its employees, managers, or agents in any way, and also agrees not to 

communicate, publish, characterize, publicize or disseminate, in any manner, any 

terms, conditions, opinions and communications related to Staffordshire Property 

Management, this application, or the application process. . . . Any breach of such 

confidentiality will support a cause of action and will entitle Staffordshire 

Property Management to recover any and all damages from such a breach.

A copy of the Staffordshire “Authorization, Agreement & Release Consent Form” that includes

this language is attached as Exhibit A hereto. Respondents’ form contracts were in effect on or 

after December 14, 2017.

VIOLATION OF THE CONSUMER REVIEW FAIRNESS ACT 

5. The Consumer Review Fairness Act of 2016 (“CRFA”), P.L. 114-258, 15 U.S.C. § 45b, 

was enacted on December 14, 2016. As of March 14, 2017, Section 2(b) of the CRFA renders 

void, and Section 2(c) of the CRFA prohibits the offering of, provisions in form contracts that:

prohibit or restrict individual consumers’ ability to communicate reviews, performance 

assessments, and similar analyses about a seller’s goods, services, or conduct; or that impose a 

penalty or fee against individual consumers who engage in such communications. 15 U.S.C. 

§§ 45b(a)(2), 45b(b)(1), and 45b(c).

6. The Commission is authorized to enforce Section 2(c) of the CRFA in the same manner, 

by the same means, and with the same jurisdiction, powers, and duties as though all applicable 

terms and provisions of the Federal Trade Commission Act, 15 U.S.C. §§ 41-58, were 

incorporated into and made a part of the CRFA. 15 U.S.C. § 45b(d)(2)(A). The Commission’s 

enforcement authority under the CRFA applies to contracts in effect on or after December 14, 

2017. 15 U.S.C. § 45b(i)(2).

7. Pursuant to 15 U.S.C. § 45b(d)(1), a violation of 15 U.S.C. § 45b(c) shall be treated as a 

violation of a rule defining an unfair or deceptive act or practice prescribed under Section 

18(a)(1)(B) of the FTC Act, 15 U.S.C. § 57a(a)(1)(B). 

Count I

8. As described in Paragraph 4 of this Complaint, Respondents have offered, in the course 

of selling their services, form contracts, as that term is defined in 15 U.S.C. § 45b(a)(3), that 

contained a provision made void by 15 U.S.C. § 45b(b)(1). 
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Therefore, the acts and practices set forth in Paragraph 4 of this Complaint occurring on or after 

March 14, 2017 violated Section 2(c) of the CRFA, 15 U.S.C. § 45b(c).

THEREFORE, the Federal Trade Commission this twenty-fifth day of July, 2019, has 

issued this Complaint against Respondent.

By the Commission.

April Tabor

Acting Secretary

SEAL: