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182-3088

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

SHORE TO PLEASE VACATIONS LLC, a limited 

liability company, and

ROBERT AARON STEPHENS, individually and as

manager of SHORE TO PLEASE VACATIONS LLC.

DOCKET NO.

COMPLAINT

The Federal Trade Commission, having reason to believe that Shore to Please Vacations

LLC and Robert Aaron Stephens, individually and as owner and manager of Shore to Please 

Vacations 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 Shore to Please Vacations LLC (“STP”) is a Nevada limited liability 

company, registered to do business in Florida, with its principal office or place of business at 

8033 West Sunset Boulevard, #1079, West Hollywood, California 90046. STP has advertised

and rented to the public, via VRBO.com (a/k/a “Vacation Rental by Owner”), Rosemary Beach, 

Florida vacation properties owned by Respondent Robert Aaron Stephens. 

2. Respondent Robert Aaron Stephens is the owner and manager of STP. Individually or in 

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

acts and practices alleged in this complaint. His principal office or place of business is the same 

as that of STP.

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. From June 2017 through at least August 2017, Respondents used, in their form contracts 

offered to prospective customers in the course of renting vacation properties, the following 

provision in the “Disclaimers” paragraph:

By signing below, you agree not to defame or leave negative reviews (includes 

any review or comment deemed to be negative by a Shore to Please Vacations

LLC officer or member, as well as any review less than a “5 star” or “absolute 

best” rating) about this property and/or business in any print form or on any 

website (including but not limited to www.VRBO.com). Due to the difficulty in 

ascertaining an actual amount of damages in situations like this, breaching this 

clause (leaving any negative review or negative comment about this property or 

business) will immediately result in minimum liquidated damages of $25,000 paid 

by you to Shore to Please Vacations LLC. By signing below, you agree to all 

charges mentioned above, if you or your party incurs them, in relation to violating 

any rules/policies/clauses within this contract. . . . By signing below, you agree to 

be held liable for any legal fees incurred by Shore To Please Vacations LLC, 

arising from any legal actions, including but not limited to litigation and 

collections, filed against you or others in your party.

Copies of STP rental agreements (with renters’ personal information redacted) that include this 

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

after December 14, 2017.

5. From October 2017 through at least August 2018, Respondents have continued to assert 

that the contract provision quoted in Paragraph 4 of this Complaint remains in effect in their 

communications with renters who posted reviews that Respondents deemed to be negative, and 

in lawsuits STP filed against those renters in the Circuit Court of the First Judicial Circuit, 

Walton County, Florida in November and December 2017. These lawsuits were pending on or 

after December 14, 2017.

6. In the lawsuits described in Paragraph 5 of this Complaint, STP alleged among other 

causes of action, that the renters breached the provision quoted in Paragraph 4 of this Complaint 

by posting negative reviews in August and September 2017 about their experiences renting 

Respondents’ vacation properties. Respondents have claimed, in demand letters to those renters,

that by breaching the provision each renter is liable to Respondents for $25,000 for “liquidated 

damages” under the contract, plus attorney’s fees.

VIOLATION OF THE CONSUMER REVIEW FAIRNESS ACT 

7. The Consumer Review Fairness Act of 2016 (“CRFA”), Pub. L. No. 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 
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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).

8. 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).

9. 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

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

of selling or leasing their goods or 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).

11. Therefore, the acts and practices set forth in Paragraph 4 of this Complaint violated 

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

THEREFORE, the Federal Trade Commission this ____ day of _______, 2019, has 

issued this Complaint against Respondents.

By the Commission.

April J. Tabor

Acting Secretary

SEAL: