Case 2:10-cv-00565-RLH-PAL Document 2 Filed 04/20/10 Page 1 of 14

Case No. 2:10-cv-0565-RLH-PAL

Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 1 of 14

UNITED STATES DISTRICT COURT 

DISTRICT OF NEVADA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

CENTRAL CREDIT, LLC, a limited 

liability company, 

Defendant. 

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STIPULATED FINAL JUDGMENT AND ORDER FOR CIVIL PENAL TIES, 

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 Central Credit, LLC, a wholly owned 

subsidiary of Global Cash Access, 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 

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UNITED STATES DISTRICT COURT 

DISTRICT OF NEVADA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

CENTRAL CREDIT, LLC, a limited 

liability company, 

Defendant. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

STIPULATED FINAL JUDGMENT AND ORDER FOR CIVIL PENAL TIES, 

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 Central Credit, LLC, a wholly owned 

subsidiary of Global Cash Access, 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 

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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 and without Defendant admitting the truth of, or 

liability for, any of the matters alleged in the Complaint. Defendant has waived service of the 

Summons and Complaint. 

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

follows: 

FINDINGS 

I. This Court has jurisdiction over the subject matter of this case and over 

Defendant Central Credit, LLC. 

2. Venue in this district is proper under 28 U.S.C. §§ 1391(b)-(c), 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) of the Federal Trade Commission Act, 15 U.S.C. §§ 45(a), 

53(b), and 56(a); and under sections 607(d), 609(c), 612(a)(l)(C) and (a)(2), and 621 of the Fair 

Credit Reporting Act, 15 U.S.C. §§ 1681e, 1681g, and 1681s and the Streamlined Process Rule, 

16 C.F.R. § 610.3, promulgated pursuant to section 612(a)(l)(C) of the FCRA, IS U.S.C. § 

168Ij(a)(l )(C). 

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 claim Defendant 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 

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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 and without Defendant admitting the truth of, or 

liability for, any of the matters alleged in the Complaint. Defendant has waived service of the 

Summons and Complaint. 

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

follows: 

FINDINGS 

I. This Court has jurisdiction over the subject matter of this case and over 

Defendant Central Credit, LLC. 

2. Venue in this district is proper under 28 U.S.C. §§ 1391(b)-(c), 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) of the Federal Trade Commission Act, 15 U.S.C. §§ 45(a), 

53(b), and 56(a); and under sections 607(d), 609(c), 612(a)(l)(C) and (a)(2), and 621 of the Fair 

Credit Reporting Act, 15 U.S.C. §§ 1681e, 1681g, and 1681s and the Streamlined Process Rule, 

16 C.F.R. § 610.3, promulgated pursuant to section 612(a)(l)(C) of the FCRA, IS U.S.C. § 

168Ij(a)(l )(C). 

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 claim Defendant 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 

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

oflaw. 

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

7. For the purpose of this Order: 

a. "Defendant" shall mean Central Credit, LLC, and its successors and 

assigns. 

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

and the Streamlined Process Rule, 16 C.F.R. Part 610, shall apply. 

ORDER 

I. CIVIL PENALTY 

IT IS ORDERED that Defendant shall pay to Plaintiff, pursuant to section 621 (a) of the 

FCRA, 15 U.S.C. § 1681s(a), a civil penalty in the amount of $150,000. 

A. Defendant shall make this payment within seven (7) business days of the date of 

service of this Order by electronic fund transfer in accordance with instructions provided by the 

Office of Consumer Litigation, Civil Division, U.S. Department of Justice, Washington, D.C. 

20530, for appropriate disposition. 

B. 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. 

C. This judgment represents a civil penalty owed to the United States Govemment, 

and is not compensation for actual pecuniary loss, and, therefore, is not subject to discharge 

under the Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7). Defendant agrees that the facts as 

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

oflaw. 

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

7. For the purpose of this Order: 

a. "Defendant" shall mean Central Credit, LLC, and its successors and 

assigns. 

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

and the Streamlined Process Rule, 16 C.F.R. Part 610, shall apply. 

ORDER 

I. CIVIL PENALTY 

IT IS ORDERED that Defendant shall pay to Plaintiff, pursuant to section 621 (a) of the 

FCRA, 15 U.S.C. § 1681s(a), a civil penalty in the amount of $150,000. 

A. Defendant shall make this payment within seven (7) business days of the date of 

service of this Order by electronic fund transfer in accordance with instructions provided by the 

Office of Consumer Litigation, Civil Division, U.S. Department of Justice, Washington, D.C. 

20530, for appropriate disposition. 

B. 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. 

C. This judgment represents a civil penalty owed to the United States Govemment, 

and is not compensation for actual pecuniary loss, and, therefore, is not subject to discharge 

under the Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7). Defendant agrees that the facts as 

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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. 

D. Proceedings initiated under this part are in addition to, and not in lieu of, any 

other civil or criminal penalties that may be provided by law, including any other proceedings 

Plaintiff may initiate to enforce this Order. 

E. 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 for return of the 

funds, directly or indirectly, through counselor otherwise. 

II. PROHIBITED BUSINESS ACTIVITIES 

IT IS FURTHER ORDERED that Defendant, and its officers, agents, servants, 

employees, and all persons or entities in active concert or participation with any of them, who 

receive actual notice of this Order by personal service or otherwise, whether acting directly or 

through any business entity, corporation, subsidiary, division, affiliate, or other device, when 

operating as a consumer reporting agency as defined in section 603(w) of the FCRA, 15 U.S.C. § 

1681a(w), are hereby permanently restrained and enjoined from: 

A. Failing to provide the "User Notice" required by section 607(d) of the FCRA, 15 

U.S.C. § 1681e(d), to all users of Defendant'sconsumer reports. 

B. Failing to provide the "Furnisher Notice" required by section 607(d) of the 

FCRA, 15 U.S.C. § 1681e(d), to all furnishers of consumer report information to Defendant. 

C. Failing to provide the "Summary of Rights" notice required by section 609( c )(2) 

of the FCRA, 15 U.S.C. § 1681g(c)(2), to all consumers who obtain file disclosures from 

Defendant. 

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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. 

D. Proceedings initiated under this part are in addition to, and not in lieu of, any 

other civil or criminal penalties that may be provided by law, including any other proceedings 

Plaintiff may initiate to enforce this Order. 

E. 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 for return of the 

funds, directly or indirectly, through counselor otherwise. 

II. PROHIBITED BUSINESS ACTIVITIES 

IT IS FURTHER ORDERED that Defendant, and its officers, agents, servants, 

employees, and all persons or entities in active concert or participation with any of them, who 

receive actual notice of this Order by personal service or otherwise, whether acting directly or 

through any business entity, corporation, subsidiary, division, affiliate, or other device, when 

operating as a consumer reporting agency as defined in section 603(w) of the FCRA, 15 U.S.C. § 

1681a(w), are hereby permanently restrained and enjoined from: 

A. Failing to provide the "User Notice" required by section 607(d) of the FCRA, 15 

U.S.C. § 1681e(d), to all users of Defendant'sconsumer reports. 

B. Failing to provide the "Furnisher Notice" required by section 607(d) of the 

FCRA, 15 U.S.C. § 1681e(d), to all furnishers of consumer report information to Defendant. 

C. Failing to provide the "Summary of Rights" notice required by section 609( c )(2) 

of the FCRA, 15 U.S.C. § 1681g(c)(2), to all consumers who obtain file disclosures from 

Defendant. 

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D. When operating as a nationwide specialty consumer reporting agency, failing to 

establish and maintain a streamlined process to enable consumers to obtain their free annual file 

disclosures by a toll-free telephone number, as required by sections 612(a)(I)(C) and 6l2(a)(2) 

of the FCRA, 15 U.S.C. §§ l68Ij(a)(l)(C) and l68Ij(a)(2), and section 610.3 of the Streamlined 

Process Rule, 16 C.F.R. § 610.3 

III. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring and investigating 

compliance with any provision of this Order: 

A. Within ten (10) days of receipt of written notice from a representative ofthe 

Commission, Defendant shall submit additional written reports, which are true and accurate and . 

sworn to under penalty of perjury; produce documents for inspection and copying; appear for 

deposition; and provide entry during normal business hours to any business location in 

Defendant's possession or direct or indirect control, to inspect the business operation. 

B. In addition, the Commission is authorized to use all other lawful means, including 

but not limited to: 

I. obtaining discovery from any person, without further leave of 

court, using the procedures prescribed by Fed. R. Civ. P. 30, 31, 

33,34,36,45, and 69; 

2. having its representatives pose as consumers and suppliers to Defendant, 

its employees, or any other entity managed or controlled in whole or in 

part by Defendant, without the necessity of identification or prior notice; 

and 

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D. When operating as a nationwide specialty consumer reporting agency, failing to 

establish and maintain a streamlined process to enable consumers to obtain their free annual file 

disclosures by a toll-free telephone number, as required by sections 612(a)(I)(C) and 6l2(a)(2) 

of the FCRA, 15 U.S.C. §§ l68Ij(a)(l)(C) and l68Ij(a)(2), and section 610.3 of the Streamlined 

Process Rule, 16 C.F.R. § 610.3 

III. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring and investigating 

compliance with any provision of this Order: 

A. Within ten (10) days of receipt of written notice from a representative ofthe 

Commission, Defendant shall submit additional written reports, which are true and accurate and . 

sworn to under penalty of perjury; produce documents for inspection and copying; appear for 

deposition; and provide entry during normal business hours to any business location in 

Defendant's possession or direct or indirect control, to inspect the business operation. 

B. In addition, the Commission is authorized to use all other lawful means, including 

but not limited to: 

I. obtaining discovery from any person, without further leave of 

court, using the procedures prescribed by Fed. R. Civ. P. 30, 31, 

33,34,36,45, and 69; 

2. having its representatives pose as consumers and suppliers to Defendant, 

its employees, or any other entity managed or controlled in whole or in 

part by Defendant, without the necessity of identification or prior notice; 

and 

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C. Defendant shall pennit representatives of the Commission to interview any 

employer, consultant, independent contractor, representative, agent, or employee who has agreed 

to such an interview, relating in any way to any conduct subject to this Order. The person 

interviewed may have counsel present. 

Provided however, that nothing in this Order shall limit the Commission's lawful use of 

compulsory process, pursuant to sections 9 and 20 of the FTC Act, 15 U.S.c. §§ 49 and 57b-l, to 

obtain any documentary material, tangible things, testimony, or infonnation relevant to unfair or 

deceptive acts or practices in or affecting commerce (within the meaning of 15 U.S.C. § 

45(a)(l» or to any violation of the FCRA. 

IV. COMPLIANCE REPORTING BY DEFENDANT 

IT IS FURTHER ORDERED that, in order that compliance with the provisions of this 

Order may be monitored: 

A. For a period of three (3) years from the date of entry of this Order, Defendant 

shall notifY the Commission of any changes in structure of Defendant or any other business 

entity that Defendant directly or indirectly controls, or has an ownership interest in, that may 

affect compliance obligations arising under this Order, including but not limited to incorporation 

or other organization; a dissolution, assignment, sale, merger, or other action; the creation or 

dissolution of a subsidiary, parent, or affiliate that engages in any acts or practices subject to this 

Order; or a change in the business name or address, at least thirty (30) days prior to such change, 

provided that, with respect to any such change in the business entity about which Defendant 

learns less than thirty (30) days prior to the date such action is to take place, Defendant shall 

notifY the Commission as soon as is practicable after obtaining such knowledge. 

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C. Defendant shall pennit representatives of the Commission to interview any 

employer, consultant, independent contractor, representative, agent, or employee who has agreed 

to such an interview, relating in any way to any conduct subject to this Order. The person 

interviewed may have counsel present. 

Provided however, that nothing in this Order shall limit the Commission's lawful use of 

compulsory process, pursuant to sections 9 and 20 of the FTC Act, 15 U.S.c. §§ 49 and 57b-l, to 

obtain any documentary material, tangible things, testimony, or infonnation relevant to unfair or 

deceptive acts or practices in or affecting commerce (within the meaning of 15 U.S.C. § 

45(a)(l» or to any violation of the FCRA. 

IV. COMPLIANCE REPORTING BY DEFENDANT 

IT IS FURTHER ORDERED that, in order that compliance with the provisions of this 

Order may be monitored: 

A. For a period of three (3) years from the date of entry of this Order, Defendant 

shall notifY the Commission of any changes in structure of Defendant or any other business 

entity that Defendant directly or indirectly controls, or has an ownership interest in, that may 

affect compliance obligations arising under this Order, including but not limited to incorporation 

or other organization; a dissolution, assignment, sale, merger, or other action; the creation or 

dissolution of a subsidiary, parent, or affiliate that engages in any acts or practices subject to this 

Order; or a change in the business name or address, at least thirty (30) days prior to such change, 

provided that, with respect to any such change in the business entity about which Defendant 

learns less than thirty (30) days prior to the date such action is to take place, Defendant shall 

notifY the Commission as soon as is practicable after obtaining such knowledge. 

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B. One hundred eighty days after the date of entry of this Order and annually 

thereafter for a period of three (3) years, Defendant shall provide a written report to the 

Commission, which is true and accurate and sworn to under penalty ofperjury, setting forth in 

detail the manner and form in which they have complied and are complying with this Order. 

This report shall include, but not be limited to: 

1. A copy of each acknowledgment of receipt ofthis Order, obtained 

pursuant to the Section titled "Distribution of Order"; and 

2. Any other changes required to be reported under Subsection A of 

this Section. 

C. Defendant shall notify the Commission of the filing of a bankruptcy petition 

within fifteen (15) days of filing. 

D. For purposes of this Order, Defendant shall, unless otherwise directed by the 

Commission's authorized representatives, send by overnight courier all reports and notifications 

required by this Order to the Commission, to the following address: 

Associate Director, Division of Enforcement 

Bureau of Consumer Protection 

Federal Trade Commission 

600 Pennsylvania Avenue, N.W., Room NJ-2l22 

Washington, D.C. 20580 

RE: United States v. Central Credit, LLC 

Provided that, in lieu of overnight courier, Defendant may send such reports or notifications by 

first-class mail, but only if Defendant contemporaneously sends an electronic version of such 

reports or notifications to the Commission at: DEBrief@ftc.gov. 

E. For purposes of the compliance reporting and monitoring required by this Order, 

the Commission is authorized to communicate directly with the Defendant. Provided however, 

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B. One hundred eighty days after the date of entry of this Order and annually 

thereafter for a period of three (3) years, Defendant shall provide a written report to the 

Commission, which is true and accurate and sworn to under penalty ofperjury, setting forth in 

detail the manner and form in which they have complied and are complying with this Order. 

This report shall include, but not be limited to: 

1. A copy of each acknowledgment of receipt ofthis Order, obtained 

pursuant to the Section titled "Distribution of Order"; and 

2. Any other changes required to be reported under Subsection A of 

this Section. 

C. Defendant shall notify the Commission of the filing of a bankruptcy petition 

within fifteen (15) days of filing. 

D. For purposes of this Order, Defendant shall, unless otherwise directed by the 

Commission's authorized representatives, send by overnight courier all reports and notifications 

required by this Order to the Commission, to the following address: 

Associate Director, Division of Enforcement 

Bureau of Consumer Protection 

Federal Trade Commission 

600 Pennsylvania Avenue, N.W., Room NJ-2l22 

Washington, D.C. 20580 

RE: United States v. Central Credit, LLC 

Provided that, in lieu of overnight courier, Defendant may send such reports or notifications by 

first-class mail, but only if Defendant contemporaneously sends an electronic version of such 

reports or notifications to the Commission at: DEBrief@ftc.gov. 

E. For purposes of the compliance reporting and monitoring required by this Order, 

the Commission is authorized to communicate directly with the Defendant. Provided however, 

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nothing in this provision shall limit the Commission's authority to pose as a consumer or 

supplier pursuant to Subsection B.2 of the Section titled "Compliance Monitoring." 

V. RECORD KEEPING PROVISIONS 

IT IS FURTHER ORDERED that, for a period of six (6) years from the date of entry of 

this Order, Defendant is hereby restrained and enjoined from failing to create and retain the 

following records: 

A. Files containing the names, addresses, and telephone numbers of all users and 

furnishers of consumer report information that received the section 607(d) User Notice and 

Furnisher Notice, and all materials considered by Defendant to demonstrate compliance with 

section 607(d) of the FCRA. 

B. 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. 

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

provision of this Order, including but not limited to, copies of acknowledgments of receipt of 

this Order, required by Sections titled "Distribution of Order" and "Acknowledgment of Receipt 

of Order" and all reports submitted to the FTC pursuant to the Section titled "Compliance 

Reporting. " 

D. All records and documents that contradict, qualify, or call into question 

Defendant's compliance with this Order. 

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nothing in this provision shall limit the Commission's authority to pose as a consumer or 

supplier pursuant to Subsection B.2 of the Section titled "Compliance Monitoring." 

V. RECORD KEEPING PROVISIONS 

IT IS FURTHER ORDERED that, for a period of six (6) years from the date of entry of 

this Order, Defendant is hereby restrained and enjoined from failing to create and retain the 

following records: 

A. Files containing the names, addresses, and telephone numbers of all users and 

furnishers of consumer report information that received the section 607(d) User Notice and 

Furnisher Notice, and all materials considered by Defendant to demonstrate compliance with 

section 607(d) of the FCRA. 

B. 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. 

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

provision of this Order, including but not limited to, copies of acknowledgments of receipt of 

this Order, required by Sections titled "Distribution of Order" and "Acknowledgment of Receipt 

of Order" and all reports submitted to the FTC pursuant to the Section titled "Compliance 

Reporting. " 

D. All records and documents that contradict, qualify, or call into question 

Defendant's compliance with this Order. 

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VI. DISTRIBUTION OF ORDER BY DEFENDANT 

IT IS FURTHER ORDERED that, for a period of three (3) years from the date of entry 

of this Order, Defendant shall deliver copies of this Order as directed below: 

A. Defendant must deliver a copy of this order to (1) all of its principals, officers, 

directors, and managers; (2) all of its employees, agents, and representatives who engage in 

conduct related to the subject matter of this Order; and (3) any busines's entity resulting from any 

change in structure set forth in Subsection A of the Section titled "Compliance Reporting." For 

current personnel, delivery shall be within five (5) days of service of this Order upon Defendant. 

For new personnel, delivery shall occur prior to them assuming their responsibilities. For any 

business entity resulting from any change in structure set forth in Subsection A of the Section 

titled "Compliance Reporting," delivery shall be at least ten (10) days prior to the change in 

structure. 

B. Defendant shall secure a signed and dated statement acknowledging receipt of 

this Order, within thirty (30) days of delivery, from all persons receiving a copy of the Order 

pursuant to this Section. 

VII. ACKNOWLEDGMENT OF RECEIPT OF ORDER 

IT IS FURTHER ORDERED that Defendant, within five (5) business days of receipt of 

this Order as entered by the Court, must submit to the Commission a truthful sworn statement 

acknowledging receipt of this Order. 

VIII. RETENTION OF JURISDICTION . 

IT IS FUTHER ORDERED that this Court shall retain jurisdiction of this matter for 

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

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VI. DISTRIBUTION OF ORDER BY DEFENDANT 

IT IS FURTHER ORDERED that, for a period of three (3) years from the date of entry 

of this Order, Defendant shall deliver copies of this Order as directed below: 

A. Defendant must deliver a copy of this order to (1) all of its principals, officers, 

directors, and managers; (2) all of its employees, agents, and representatives who engage in 

conduct related to the subject matter of this Order; and (3) any busines's entity resulting from any 

change in structure set forth in Subsection A of the Section titled "Compliance Reporting." For 

current personnel, delivery shall be within five (5) days of service of this Order upon Defendant. 

For new personnel, delivery shall occur prior to them assuming their responsibilities. For any 

business entity resulting from any change in structure set forth in Subsection A of the Section 

titled "Compliance Reporting," delivery shall be at least ten (10) days prior to the change in 

structure. 

B. Defendant shall secure a signed and dated statement acknowledging receipt of 

this Order, within thirty (30) days of delivery, from all persons receiving a copy of the Order 

pursuant to this Section. 

VII. ACKNOWLEDGMENT OF RECEIPT OF ORDER 

IT IS FURTHER ORDERED that Defendant, within five (5) business days of receipt of 

this Order as entered by the Court, must submit to the Commission a truthful sworn statement 

acknowledging receipt of this Order. 

VIII. RETENTION OF JURISDICTION . 

IT IS FUTHER ORDERED that this Court shall retain jurisdiction of this matter for 

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

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20th day of April 2010.

Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 10 of 14

IX. 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 

FOR THE PLAINTIFF 

UNITED STATES OF AMERICA: 

ANNM.RAVEL 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

DANIEL G. BOGDEN 

United States Attorney 

District of Nevada 

UNIT 

Page 10 of 13 

IX. 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 

FOR THE PLAINTIFF 

UNITED STATES OF AMERICA: 

ANNM.RAVEL 

Acting Assistant Attorney General 

Civil Division 

United States Department of Justice 

DANIEL G. BOGDEN 

United States Attorney 

District of Nevada 

UNIT 

Page 10 of 13 
Case 2:10-cv-00565-RLH-PAL Document 2 Filed 04/20/10 Page 11 of 14 Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 11 of 14

-

/) JJ1' 'J' (1. , ~~9,h", " ,j J j /, 

Assistant United States Attorney 

333 South Las Vegas Blvd 

Lloyd George Federal Building 

Las Vegas, NY 89101 

(702) 388-6336 

EUGENE M. TIIIROLF 

Director 

Office of Consumer Litigation 

KENNETH L. JOST 

Deputy Director 

Office of Consumer Litigation 

A 

ttorney 

Office of Consumer Litigation 

U.S. Department of Justice 

PO Box 386 

Washington, D.C. 20044 

Telephone: 202-307-6154 

Facsimile: 202-514-8742 

E-mail: a1an.phelps@usdoj.gov 

FOR THE FEDERAL TRADE COMMISSION 

Y1, ,AMJ 

MANEESHA MITHAL 

Associate Director 

Division of Privacy and Identity Protection 

L 

1tEBECCA E. KUEHN 

Assistant Director 

Division of Privacy and Identity Protection 

Page 11 of I3 

-

/) JJ1' 'J' (1. , ~~9,h", " ,j J j /, 

Assistant United States Attorney 

333 South Las Vegas Blvd 

Lloyd George Federal Building 

Las Vegas, NY 89101 

(702) 388-6336 

EUGENE M. TIIIROLF 

Director 

Office of Consumer Litigation 

KENNETH L. JOST 

Deputy Director 

Office of Consumer Litigation 

A 

ttorney 

Office of Consumer Litigation 

U.S. Department of Justice 

PO Box 386 

Washington, D.C. 20044 

Telephone: 202-307-6154 

Facsimile: 202-514-8742 

E-mail: a1an.phelps@usdoj.gov 

FOR THE FEDERAL TRADE COMMISSION 

Y1, ,AMJ 

MANEESHA MITHAL 

Associate Director 

Division of Privacy and Identity Protection 

L 

1tEBECCA E. KUEHN 

Assistant Director 

Division of Privacy and Identity Protection 

Page 11 of I3 
Case 2:10-cv-00565-RLH-PAL Document 2 Filed 04/20/10 Page 12 of 14 Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 12 of 14

HAPATRA 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, N.W. 

Suite NJ-8122 

Washington, D.C. 20580 

Telephone: (202) 326-2252 

Facsimile: (202) 326-3768 

Page 12 of 13 

HAPATRA 

Division of Privacy and Identity Protection 

Federal Trade Commission 

601 New Jersey Avenue, N.W. 

Suite NJ-8122 

Washington, D.C. 20580 

Telephone: (202) 326-2252 

Facsimile: (202) 326-3768 

Page 12 of 13 
Case 2:10-cv-00565-RLH-PAL Document 2 Filed 04/20/10 Page 13 of 14 Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 13 of 14

FOR THE DEFENDANT: 

Scott ~ Betts, PresIdent & CEO 

Central Credit LLC 

~, ~tcc '-=A:;ND~RE=W~M;'. -=SM:-:-::IT=HC::-

Morrison & Foerster LLP 

2000 Pennsylvania Ave., NW 

Suite 6000 

Washington, D.C. 20006 

Page 13 of 13 

FOR THE DEFENDANT: 

Scott ~ Betts, PresIdent & CEO 

Central Credit LLC 

~, ~tcc '-=A:;ND~RE=W~M;'. -=SM:-:-::IT=HC::-

Morrison & Foerster LLP 

2000 Pennsylvania Ave., NW 

Suite 6000 

Washington, D.C. 20006 

Page 13 of 13 
Case 2:10-cv-00565-RLH-PAL Document 2 Filed 04/20/10 Page 14 of 14 Case 2:10-cv-00565-RLH-PAL Document 4 Filed 04/20/10 Page 14 of 14

REASONS FOR SETTLEMENT 

This statement accompanies the final order executed by defendant Central Credit 

LLC. The final order enjoins Central Credit, LLC from violating sections 607( d) and 

609(c)(2) of the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681e and 1681g as 

well as section 610.3 of the Streamlined Process Rule, 16 C.F.R. § 610.3. The final order 

also requires that entry of a judgment in the amount of one hundred and fifty thousand 

dollars ($150,000) as a civil penalty be entered against defendant. 

Pursuant to. section 5(m)(3) of the Federal Trade Commission Act ("FTC Act"), 

as amended 15 U.S.C. § 45(m)(3), the Commission hereby sets forth its reasons for 

settlement by entry of a Stipulated Final Judgment and Order for Civil Penalties, 

Permanent Injunction, and Other Equitable Relief ("final order"): 

On the basis of the allegations contained in the complaint, and the statutory 

factors in the FCRA and the FTC Act, the Commission believes that the civil penalty 

judgment of$150,000 constitutes an appropriate amount on which to base the settlement, 

and that the provision enjoining defendant from violating sections 607( d) and 609( c )(2) 

of the FCRA as well as section 610.3 of the Streamlined Process Rule should ensure 

defendant's future compliance with the law. With the entry of the final order, the time 

and expense of litigation will be avoided. 

For the foregoing reasons, the Commission believes that the settlement by entry 

ofthe attached final order is justified and well within the public interest.. 

REASONS FOR SETTLEMENT 

This statement accompanies the final order executed by defendant Central Credit 

LLC. The final order enjoins Central Credit, LLC from violating sections 607( d) and 

609(c)(2) of the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681e and 1681g as 

well as section 610.3 of the Streamlined Process Rule, 16 C.F.R. § 610.3. The final order 

also requires that entry of a judgment in the amount of one hundred and fifty thousand 

dollars ($150,000) as a civil penalty be entered against defendant. 

Pursuant to. section 5(m)(3) of the Federal Trade Commission Act ("FTC Act"), 

as amended 15 U.S.C. § 45(m)(3), the Commission hereby sets forth its reasons for 

settlement by entry of a Stipulated Final Judgment and Order for Civil Penalties, 

Permanent Injunction, and Other Equitable Relief ("final order"): 

On the basis of the allegations contained in the complaint, and the statutory 

factors in the FCRA and the FTC Act, the Commission believes that the civil penalty 

judgment of$150,000 constitutes an appropriate amount on which to base the settlement, 

and that the provision enjoining defendant from violating sections 607( d) and 609( c )(2) 

of the FCRA as well as section 610.3 of the Streamlined Process Rule should ensure 

defendant's future compliance with the law. With the entry of the final order, the time 

and expense of litigation will be avoided. 

For the foregoing reasons, the Commission believes that the settlement by entry 

ofthe attached final order is justified and well within the public interest..