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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 1 of 20 Page ID #:1 

ALDEN F. ABBOTT 

General Counsel 

RHONDA P. PERKINS 

VA Bar No. 75300, rperkins@ftc.gov 

AMANDA R. GRIER 

VA Bar No. 78531, agrier@ftc.gov 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Ave., NW, CC-8528 

Washington, DC 20580 

Tel: 202-326-3222 (Perkins), 202-326-3745 (Grier) 

Fax: 202-326-3395 

STACY R. PROCTER (Local Counsel) 

CA Bar No. 221078, sprocter@ftc.gov 

FEDERAL TRADE COMMISSION 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Tel: 310-824-4343, Fax: 310-824-4380 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

APARTMENT HUNTERS, INC., a 

corporation, also d/b/a 

WeTakeSection8.com, 

ApartmentHunterz.com, and 

FeaturedRentals.com, 

REAL ESTATE DATA SOLUTIONS, 

INC., a corporation, 

RENTAL HOME LISTINGS INC., a 

corporation, 

UAB APARTMENT HUNTERS LT, a 

limited liability company, 

No. 8:18-CV-1636 

COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER 

EQUITABLE RELIEF 
 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 2 of 20 Page ID #:2 

STEVEN SHAYAN, individually and 

as an officer of Apartment Hunters, 

Inc., Real Estate Data Solutions, Inc., 

Rental Home Listings Inc., and UAB 

Apartment Hunters LT, and 

KEVIN SHAYAN, a/k/a Kaveh Shayan, 

individually and as a manager or de 

facto officer of Apartment Hunters, 

Inc., Real Estate Data Solutions, Inc., 

Rental Home Listings Inc., and UAB 

Apartment Hunters LT, 

Defendants. 

Plaintiff, the Federal Trade Commission (the “FTC” or “Commission”) for 

its Complaint alleges as follows: 

1. The FTC brings this action under Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), to obtain temporary, 

preliminary, and permanent injunctive relief, rescission or reformation of contracts, 

restitution, the refund of monies paid, disgorgement of ill-gotten monies, and other 

equitable relief for Defendants’ acts or practices in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a), in connection with the sale of access to listings of 

purportedly available rental units. 

SUMMARY OF THE CASE 

2. Defendants operate several prepaid rental listing websites, including 

WeTakeSection8.com, ApartmentHunterz.com, and FeaturedRentals.com. The 

first website specifically targets individuals seeking Section 8 housing; the other 

websites purport to offer general-access rental units. Defendants charge consumers 

a fee to access contact information for property managers of rental units listed on 

their websites. Defendants represent to consumers that the listings on their 

websites are accurate, up-to-date, and available, that consumers are likely to find 

suitable housing within a short time, and that consumers cannot find these listings 

on free websites. These representations are misleading, false, or unsubstantiated. 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 3 of 20 Page ID #:3 

For example, the majority of the listings on WeTakeSection8.com are not available 

for rent, and most of those units that are available for rent do not accept Section 8 

payments. Consumers lose money and valuable time because of Defendants’ 

deceptive marketing. 

JURISDICTION AND VENUE 

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 

1337(a), and 1345, and 15 U.S.C. §§ 45(a) and 53(b). 

4. Venue is proper in this district under 28 U.S.C. § 1391(b)(1), (b)(2), 

(c)(1), (c)(2), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFF 

5. The FTC is an independent agency of the United States Government 

created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 

affecting commerce. 

6. FTC is authorized to initiate federal district court proceedings, by its own 

attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as 

may be appropriate in each case, including rescission or reformation of contracts, 

restitution, the refund of monies paid, and the disgorgement of ill-gotten monies. 

15 U.S.C. §§ 53(b) and 56(a)(2)(A). 

DEFENDANTS 

7. Defendant Apartment Hunters, Inc., (“Apartment Hunters”), also doing 

business as WeTakeSection8.com, ApartmentHunterz.com, and 

FeaturedRentals.com, is a California corporation with its principal place of 

business at 13 Stern St., Laguna Niguel, CA 92677. Apartment Hunters transacts 

or has transacted business in this district and throughout the United States. At all 

times material to this Complaint, acting alone or in concert with others, Apartment 

Hunters has advertised, marketed, distributed, or sold access to rental listings to 

consumers throughout the United States. 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 4 of 20 Page ID #:4 

8. Defendant Real Estate Data Solutions, Inc. is a California corporation 

with its principal place of business at 13 Stern St., Laguna Niguel, CA 92677. 

Real Estate Data Solutions, Inc. opens merchant accounts for Apartment Hunters. 

Real Estate Data Solutions, Inc. transacts or has transacted business in this district 

and throughout the United States. 

9. Defendant Rental Home Listings Inc. is a California corporation with its 

principal place of business at 13 Stern St., Laguna Niguel, CA 92677. Rental 

Home Listings Inc. opens merchant accounts for Apartment Hunters. Rental Home 

Listings, Inc. transacts or has transacted business in this district and throughout the 

United States. 

10. Defendant UAB Apartment Hunters LT is a foreign limited liability 

company with its principal place of business at Savanoriu pr. 363, 49425, Kaunas, 

Lithuania. At all times material to this Complaint, acting alone or in concert with 

others, UAB Apartment Hunters LT purposefully directed its activities to the 

United States by: (1) designing and creating the content, computer code, and 

search algorithms for Apartment Hunters’ interactive websites targeted solely to 

the U.S. rental market; (2) responding to inquiries from U.S. consumers relating to 

Apartment Hunters’ websites by telephone, email, and through online chat offered 

on the websites; (3) updating and removing rental listings on Apartment Hunters’ 

websites; and (4) carrying out the design, content-creation, and maintenance of 

Apartment Hunters’ websites at the direction of the U.S.-based Defendants, who 

incorporated UAB Apartment Hunters LT in Lithuania to take advantage of 

cheaper operating expenses. UAB Apartment Hunters LT transacts or has 

transacted business in this district and throughout the United States. 

11. Defendant Steven Shayan is the owner and chief executive officer of 

Apartment Hunters, Real Estate Data Solutions, Inc., Rental Home Listings Inc., 

and UAB Apartment Hunters LT. At all times material to this Complaint, acting 

alone or in concert with others, he has formulated, directed, controlled, had the 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 5 of 20 Page ID #:5 

authority to control, or participated in the acts and practices of Apartment Hunters, 

Real Estate Data Solutions, Inc., Rental Home Listings Inc., and UAB Apartment 

Hunters LT, including the acts and practices set forth in this Complaint. Defendant 

Steven Shayan resides in this district and, in connection with the matters alleged 

herein, transacts or has transacted business in this district and throughout the 

United States. 

12. Defendant Kevin Shayan, also known as Kaveh Shayan, is a manager or 

de facto officer of Apartment Hunters, Real Estate Data Solutions, Inc., Rental 

Home Listings Inc., and UAB Apartment Hunters LT, the administrator of 

Apartment Hunters’ websites, and Steven Shayan’s brother. At all times material 

to this Complaint, acting alone or in concert with others, he has formulated, 

directed, controlled, had the authority to control, or participated in the acts and 

practices of Apartment Hunters, Real Estate Data Solutions, Inc., Rental Home 

Listings Inc., and UAB Apartment Hunters LT, including the acts and practices set 

forth in this Complaint. Defendant Kevin Shayan resides in this district and, in 

connection with the matters alleged herein, transacts or has transacted business in 

this district and throughout the United States. 

COMMON ENTERPRISE 

13. Defendants Apartment Hunters, Real Estate Data Solutions, Inc., Rental 

Home Listings Inc., and UAB Apartment Hunters LT (collectively, “Corporate 

Defendants”) have operated as a common enterprise while engaging in the 

deceptive acts and practices alleged below. Defendants have conducted the 

business practices described below through an interrelated network of companies 

that have common ownership, officers, managers, business functions, and that 

commingled funds. Because these Corporate Defendants have operated as a 

common enterprise, each of them is jointly and severally liable for the acts and 

practices alleged below. Defendants Steven Shayan and Kevin Shayan have 

formulated, directed, controlled, had the authority to control, or participated in the 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 6 of 20 Page ID #:6 

acts and practices of the Corporate Defendants that constitute the common 

enterprise. 

COMMERCE 

14. At all times material to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS ACTIVITIES 

15. Defendants’ prepaid rental listing websites – including 

WeTakeSection8.com, ApartmentHunterz.com, and FeaturedRentals.com – 

purportedly offer hundreds of thousands of available rental listings throughout the 

United States. The rental listings appear to be largely similar across Defendants’ 

websites. Defendants have represented to consumers that the listings are accurate, 

up-to-date, and available, and that consumers are likely to find suitable housing 

within seven business days or less. Defendants have also represented that they 

have exclusive rights to list thousands of rental listings on their websites, and 

exclusive rights to list Section 8 rental listings, and that consumers cannot find 

these listings on free websites. These representations are false, misleading, or 

unsubstantiated because: (1) many of the rental listings on Defendants’ websites 

are inaccurate or unavailable for rent; (2) Defendants cannot show how quickly 

subscribers to Defendants’ rental-listing websites might obtain housing using 

Defendants’ listings; and (3) Defendants do not have exclusive rights to list 

thousands of rental listings on their websites, including Section 8 rental listings, 

that consumers cannot find on free websites. 

16. As a California corporation that offers prepaid rental listing services 

(“PRLS”) to consumers, Apartment Hunters is required to have a license from the 

California Department of Real Estate, formerly known as the Bureau of Real Estate 

(“DRE”). Apartment Hunters received its PRLS license from the DRE in 2007. 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 7 of 20 Page ID #:7 

17. In 2011, Apartment Hunters was the subject of a disciplinary action by 

the DRE in part because the company did not confirm the availability of listings in 

a timely manner as required by California real estate law. Following this action, in 

2012, the DRE issued a restricted PRLS license to Apartment Hunters, which was 

suspended in 2014 after the DRE charged the company with providing false, 

misleading, or deceptive advertisements to prospective tenants. In 2015, the DRE 

adopted an administrative law judge’s (“ALJ”) decision to revoke Apartment 

Hunters’ PRLS license because Apartment Hunters willfully and deliberately 

violated California real estate law and a legal order from the Real Estate 

Commissioner by operating a PRLS business while its license was suspended. The 

ALJ also found that Apartment Hunters advertised properties in a false, 

misleading, or deceptive way. See Decision, Case No. H-39494 LA (July 1, 2015) 

(available at www.dre.ca.gov). 

18. The revocation of its license has not deterred Apartment Hunters, which 

has continued to operate a PRLS business in California without a license. 

19. Apartment Hunters has engaged in the unlawful practices alleged in this 

Complaint since at least 2013. 

Defendants’ WeTakeSection8.com Website 

20. The Section 8 Tenant-Based Assistance: Housing Choice Voucher 

Program (“Section 8”), 24 CFR Part 982, is a federal government program for 

assisting very low-income families, the elderly, and the disabled to afford decent, 

safe, and sanitary housing in the private market. 

21. The U.S. Department of Housing and Urban Development (“HUD”) 

provides funds to local housing authorities to administer the Section 8 voucher 

program. The demand for housing assistance often exceeds the limited resources 

available to HUD and local housing authorities. Many local housing authorities, 

particularly in metropolitan areas, have long waitlists such that families may wait 

several years before receiving a voucher. Once they receive a voucher, families 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 8 of 20 Page ID #:8 

typically have 60 to 90 days to find housing, with the possibility of an extension of 

up to 120 days. A family that is unable to find housing within that time risks 

losing the voucher. 

22. Defendants’ website WeTakeSection8.com purports to list thousands of 

rental properties that accept Section 8 vouchers in full or partial payment of rent. 

Consumers who visit the website can see the listed properties, but cannot access 

the contact information of the property managers for the listings unless they pay a 

subscription fee. The fee and the length of the subscription vary. Typically, 

consumers have paid $49 for two months of access to the property managers’ 

contact information. Defendants have also charged consumers $14.99 for a weekly 

subscription. 

Misrepresentations about the Availability and Accuracy of Listings 

23. To induce consumers to purchase subscriptions to 

WeTakeSection8.com, Defendants represent that the website has the most accurate 

and up-to-date listings of Section 8 housing on the Internet. As the following 

screenshot of the WeTakeSection8.com homepage shows, the website welcomes 

consumers to “the Nation’s Largest Section 8 Apartment Finder” and claims to 

help consumers find government assisted housing and rentals that accept Section 8 

vouchers. 

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SEARCH "4EM8ERS 51.ffORT SECTI0",18WAI NGUST5 .-sovrus G SIGNUP 

Section 8 & Affordable Housing Online web 

or loo ntNL-<ld! 

$ Ren ~c V V 

- .., l ... ~ 

--.. ~ ,.,,.. - --

Welcome to Nation's Largest Section 8 Apartment Finder! 

WcT• cSc,ctione.com wna~ted to p vou find~ ~,ted hou>ln~ and rc:oden .,, rentiills ~t accept Section 8 Voucher> We lvvc rccen cxPiilndcd 

our re~ lrorn ~ torn~ alone to one of the 1,rccst n111onal ~u~c.s of mmcnt subsidized hous,r,i to furthc,- help vou in thcsc touih cconom c times. We 

mannc one the mo,t up-to-dau, s tcs for rentals of ap,artments. hcuscs. townhomc:o tlut are alreiildysctup to acapl the vouchen 

Search Thousands of Listings 

fflHII provid s 

around I count,y. ~•Ill us 10 match vou with 

I I anvw You won"t "-' 10 

r.phic re anymor 

Direct Connection to the Landlord 24n Cus omer Suppor 

Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 9 of 20 Page ID #:9 

24. The homepage of WeTakeSection8.com touts “one of the largest 

national databases of government subsidized housing” and “one the most [sic] upto-date sites for rentals of apartments, houses, townhomes that are already setup to 

accept the vouchers.” It promises a “direct connection to the landlord” who is 

making the rental available and that consumers may search “500,000+ Section 8 

approved or low price apartments and homes for rent nationwide.” 

25. Defendants make numerous claims throughout WeTakeSection8.com 

about the availability and accuracy of the listings on the website. For example, on 

the “About Us” webpage, Defendants have claimed to be the leading rental search 

service for government-subsidized housing and to update listings on a daily basis, 

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www ..... ,. HKl>On8.con"Hnlo/compony/ bou1 

WE TAKE 

SECTION SEARCH MEMBl:RS SUPPORT ASOUTUS FEATUREORENTALS 

Cltyor Zip Min. Price Max. Price 

Nation's Leading Apartment Rental Search Service for Government 

Subsidized Housing 

SIGN UP 

Search 

At WeTakeS<!cllon8.corn , we understand that moving Is a dlfflcult process, panlculafly If you have special needs and searching for S<!ctlon 8 Approved Housing. So 

= ma e It as easy as possible 

Our Comprel>..M Conve111ent Coru11t,ng rvlce 

WeT. keS<!ctlon8.com p,ovldes you with lists of government subsidized housing within the reas specified. You can se rch for S<!ctlon 8 Houses. p rtments. 

townhomes and duplexes In the reas =cover. You can narrow your results by price. bedroom. within your criteria of your voucher to search for your h<>me. We list 

Section 8, !fordable housing and government subsidized housing. 

Our Tr.ck R ord 

Our cllenu lind a place within 5-7 business days. This Ism rry times fasterth.ln you re likely to find a p13Ce by driving around endlessly. 

WllyWeH t MostCom le A«urateListl 

Our site has the most complete and detailed Information on the communities than what you might find In a sho<t classified ad of a newspaper. And our un ique. d te• 

sensitive, rental software updates the listings on a dally basis. so that the data you receive from us ls the most accur te and up-to-date Information available on the 

Web today 

WeTakeSectlon8 

02001 2O17WolakoScdion8.com Torm,olU,o I PrlvKVPohcv I F•ir Housing 

Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 10 of 20 Page ID #:10 

as depicted below: 

26. In another version of the About Us webpage, Defendants have claimed 

to have “the most complete and accurate apartment search service for section 8 and 

government subsidized housing.” They represent that the advantage of using their 

website is “[w]e aggregate all government housing databases, our unique, datesensitive, rental software updates the listings on a daily basis... 

WeTakeSection8.com works hard to maintain one of the largest and most updated 

databases of voucher program rentals that are currently available in the U.S.” 

27. Defendants represent that they validate the availability of rentals and 

landlord contact information. For example, in the “Support” section of the 

website, in response to a question about why there are not enough pictures of the 

properties, Defendants claim, “Since we only assist with the search process, we 

cannot be responsible for the information that the landlords post, except in that we 

validate phone number, email addresses and availability.” 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 11 of 20 Page ID #:11 

28. In the Support section of WeTakeSection8.com, Defendants have 

represented that the website is superior to other websites that have “old listings that 

have long since been rented” because Defendants’ database is updated in real time 

and they “routinely call the landlords and update [the] listings to make sure that 

you won’t waste time calling on an apartment that has already been occupied.” 

29. On the Search tab of WeTakeSection8.com, consumers are able to view 

the rental listings. The listings for properties that accept Section 8 vouchers 

indicate that “[e]very effort is taken to verify the availability of the home of your 

choice.” Each of those listings also advises that the consumer must call to check 

availability because “the listings rent fast.” Consumers must subscribe to 

WeTakeSection8.com to obtain the landlord’s or property manager’s contact 

information. 

30. In the Support section of WeTakeSection8.com, in response to a 

question about whether someone may search specifically for Section 8 rentals, 

Defendants have claimed that if a consumer types “Section 8” in the search bar, 

“the results are available properties for immediate occupancy that accept [S]ection 

8 HUD program.” 

31. In the Support section of the website, in response to the question, “Does 

your company provide me with anything that I couldn’t do myself,” Defendants 

have encouraged consumers to pay the subscription fee for WeTakeSection8.com 

instead of wasting their time on other websites. Defendants claim, “[T]here are 

also many free services available on the Internet and through free publication 

services, but those establishments do not list actual vacancies. We take steps to 

make sure that the information is accurate and up to date on current available 

rentals.” In addition, the sign-up page of WeTakeSection8.com has promised 

consumers “thousands of updated and verified listings including exclusive listings 

not found on free websites.” (Emphasis in original.) 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 12 of 20 Page ID #:12 

32. Defendants make similar claims on mobile apps that consumers may 

download in order to access and subscribe to the WeTakeSection8.com website. 

Defendants represent that they provide “current data on more than 500,000+ 

Section 8 approved or low priced apartments, homes.” They claim to have 

“complete and accurate details and descriptions of current relevant vacant 

properties....” Defendants further represent that they have “designed the App of 

We Take Section 8, through exhaustive hours of programming, and then expanded 

it by adding the most extensive national database of America’s affordable rental 

housing, and Senior housing, and largest inventory of available open waiting lists 

in the nation. We have made sure our data are from valid property management 

companies that have active affordable rentals that are safe and decent for families 

of our clients.” 

33. Defendants’ claims are false or unsubstantiated. While Defendants 

promise that the information on WeTakeSection8.com is up-to-date, most of the 

properties listed as available for rent on WeTakeSection8.com are unavailable and 

those that are available for rent generally do not accept Section 8 vouchers. 

34. While Defendants promise that WeTakeSection8.com lists 500,000+ 

Section 8 approved or low price properties available for rent, Defendants cannot 

verify that they have this many listings in their database. 

35. Similarly, Defendants have claimed to have exclusive rights to list rental 

listings on WeTakeSection8.com. Defendants have claimed that consumers cannot 

find these listings on free websites. In truth and in fact, Defendants do not have an 

exclusive right to list properties on WeTakeSection8.com and do not know 

whether those listings are advertised on free websites. 

36. While Defendants promise that the information on WeTakeSection8.com 

is accurate and that they will connect consumers directly to landlords, they do very 

little, if anything, to verify that the landlord’s information is accurate. 

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How longwHI it take for me to find an 

apartm1

ent? 

T e amount of time that i takes to locate an apartment, of course, depends on 

th av ilability oft m r'ket w ich changes th oughou th c.ou e oft eye r, 

bu ailmost every one of our clie ts rTiee s with success wi hin jus four days of 

s a chi g. We gu r . t t t w t ln o ewe k you will l1av loc t don (if not 

more) viab e rental. 

Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 13 of 20 Page ID #:13 

Misrepresentations about How Quickly Consumers Find Rental Housing 

37. Defendants have represented that consumers who subscribe to 

WeTakeSection8.com find housing within seven business days or less. On the 

About Us page, as depicted above in paragraph 25, Defendants claim, “Our Track 

Record” – “Our clients find a place within 5-7 business days.” (Emphasis in 

original.) The Support section of the website has stated that consumers would 

likely find a suitable listing within four days, as depicted below: 

38. Defendants have made these additional claims in the Support section of 

WeTakeSection8.com about how quickly consumers find suitable housing: 

a. “The minimum duration of the membership is 2 months, but most 

of our clients are able to find a rental within one week”; and 

b. “When you subscribe to our services you will receive complete 

access to our extensive database, which we guarantee will be 

enough time for you to find an apartment. In fact, most people 

find an apartment within a week!” 

39. Defendants’ representations about how quickly consumers find suitable 

listings on WeTakeSection8.com are false or unsubstantiated. Indeed, Defendant 

Kevin Shayan knows and has admitted that these representations are inaccurate. 

Defendants’ ApartmentHunterz.com Website 

40. As with WeTakeSection8.com, Defendants claim that their other 

websites have accurate and up-to-date rental listings that will help consumers 

locate other kinds of rental housing quickly. On the homepage of 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 14 of 20 Page ID #:14 

ApartmentHunterz.com, Defendants have represented that the website has rental 

listings for more than one million apartments, condominiums, and homes 

throughout the United States that are updated daily and even hourly. As depicted 

below, Defendants have represented that users are likely to find suitable housing 

within 3-5 days: 

41. On the About Us page, Defendants represent that 

ApartmentHunterz.com has “the most complete and accurate listings” because 

Defendants purportedly work closely with managers of the listed properties, and 

because Defendants’ “unique, date-sensitive, rental software updates the listings on 

a daily basis, so that the data you receive from us is the most accurate and up-todate information available on the Web today.” 

42. The fee and the length of the subscription to ApartmentHunterz.com 

vary. Typically, consumers have paid $49 for 30 days’ access to the website. 

Defendants have also charged consumers $14.99 for a weekly subscription. 

43. Defendants encourage consumers to pay the subscription fee to access 

ApartmentHunterz.com rather than use a free rental service because their service is 

faster. On the About Us page, Defendants claim that their “Track Record” is that 

“[a]s a general rule, we find your place within 3-5 days. This is many times 

faster than you are likely to find a place through a self-serve rental agency.” In the 

Support section of the website, Defendants have represented that this “nominal” 

fee will actually “save time and money” because consumers will have access to 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 15 of 20 Page ID #:15 

“verified vacant properties” that meet their criteria and the listings provide direct 

access to property managers. 

44. Defendants reiterate these claims throughout ApartmentHunterz.com on 

the homepage, the About Us page, and in the Support section. Defendants “assure 

[consumers] complete satisfaction” by representing that they gather thousands of 

rentals from management companies directly and update listings on an hourly 

basis. 

45. Defendants make similar claims on mobile apps that consumers may 

download in order to access and subscribe to the ApartmentHunterz.com website. 

Defendants claim to have five times more listings than other websites. They 

represent that “[t]hrough our relationships we gather listings on a daily basis from 

all rental websites and management companies and present them to you in one easy 

app.” Defendants represent that some of the key features of 

ApartmentHunterz.com are: (1) “[c]omplete and accurate details and descriptions 

of current relevant vacant properties...”; (2) “[n]ew listings posted and rented ones 

removed by our staff”; and (3) “[p]hone and email verification to remove rented 

listings and verify price changes as well as post new rentals hourly as they become 

available.” 

46. Defendants’ representations that consumers who subscribe to the 

ApartmentHunterz.com website find rental housing within a few days and that the 

listings therein are accurate and up-to-date are false or unsubstantiated. Numerous 

consumers have complained to Defendants that many of the listings on 

ApartmentHunterz.com are not accurate and not available to rent. 

Defendants’ FeaturedRentals.com Website 

47. According to the homepage of FeaturedRentals.com, this “[o]ne site 

does it all” by providing access to “thousands of listings not on free rental 

websites.” The homepage of the website has touted over one million rental listings 

throughout the United States. In the Support section of FeaturedRentals.com, 

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Defendants have boasted that consumers with a good rental history will find rental 

housing within three days. 

48. Similar to WeTakeSection8.com and ApartmentHunterz.com, on the 

About Us page of FeaturedRentals.com, Defendants claim to “update [the] 

databases constantly, so you are always guaranteed of the most up-to-date listings 

for the area.” Defendants further represent on the About Us page that consumers 

will save money by accessing listings from dozens of rental databases at a single 

site. 

49. The fee and the length of the subscription vary. Typically, consumers 

have paid Defendants $49 for 30 days access to FeaturedRentals.com. 

50. Similar to ApartmentHunterz.com, in the Support section of 

FeaturedRentals.com, Defendants represent that they charge a “nominal fee to 

access the database and provide detailed verified vacant results... Save time and 

money by calling verified vacant results matching your criteria.” Defendants claim 

that they “verify the availability of the properties as opposed to free sites or yellow 

pages that just lists the community that might not have a vacancy.” 

51. In the Support section of FeaturedRentals.com, Defendants emphasize 

the quality of the listings by claiming to gather thousands of listings directly from 

landlords and management companies and update the search engine on a daily and 

hourly basis. Defendants claim to operate “a reputable rental site” that provides 

“the most up-to-date information” on all of their listings. 

52. Defendants make similar claims on mobile apps that consumers may 

download in order to access and subscribe to the FeaturedRentals.com website. 

Defendants claim that consumers will “[g]et instant access to over 700,000 RealTime Updated listings” and receive “vacant listings not found on free rental 

websites.” They represent that “[t]hrough our relationships we gather listings on a 

daily basis from all rental websites and management companies and present them 

to you in one easy app.” Defendants make some of the same representations as on 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 17 of 20 Page ID #:17 

the ApartmentHunterz.com mobile app, indicating that some of the key features of 

FeaturedRentals.com are complete and accurate details of current relevant vacant 

properties, that staff remove rented listings, and that staff post new rentals hourly 

as they become available. 

53. Defendants’ representations that consumers who subscribe to the 

FeaturedRentals.com website find rental housing within a few days and that the 

listings therein are accurate, verified, and up-to-date are false or unsubstantiated. 

Numerous consumers have complained to Defendants that many of the listings on 

FeaturedRentals.com are not accurate and not available to rent. 

54. Defendants’ claims that consumers cannot find the same rental listings 

on free websites are false or unsubstantiated. Defendants do not have an exclusive 

right to list properties on their websites and do not know whether those listings are 

advertised on free websites. 

Defendants Receive Many Complaints About Unavailable Listings on 

WeTakeSection8.com, ApartmentHunterz.com, and FeaturedRentals.com 

55. Consumers and property managers have complained directly to 

Defendants that WeTakeSection8.com, ApartmentHunterz.com, and 

FeaturedRentals.com contain inaccurate or unavailable rental listings. In 2017 

alone, hundreds of consumers complained directly to Defendants that landlords’ 

phone numbers were disconnected or incorrect, the price of the unit had changed, 

the property already had been rented for months or years earlier, the listing was 

available on other websites for free, and the property owner did not accept Section 

8 vouchers. 

56. Consumers and property managers also have filed complaints with third 

parties, such as the Better Business Bureau, to report that properties listed as 

available for rent on WeTakeSection8.com, ApartmentHunterz.com, and 

FeaturedRentals.com are not available and that these websites are scams. These 

third parties have forwarded complaints from consumers and property managers to 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 18 of 20 Page ID #:18 

Defendant Apartment Hunters and in some instances, Apartment Hunters has 

responded to these complaints. For example, after a property manager complained 

that a property listing that was not available for rent appeared on 

WeTakeSection8.com, Apartment Hunters responded that it received listings from 

data partners that sometimes contained inaccuracies in the listing description, 

price, availability, or address. 

VIOLATIONS OF THE FTC ACT 

57. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or 

deceptive acts or practices in or affecting commerce.” 

58. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

COUNT I 

59. Through the means described in Paragraphs 15 through 56, Defendants 

have represented, directly or indirectly, expressly or by implication, that the rental 

listings, including Section 8 listings, on Defendants’ websites are accurate, up-todate, and available for consumers to rent. 

60. Defendants’ representations set forth in Paragraph 59 of this Complaint 

are false or misleading, or were not substantiated at the time the representations 

were made. 

61. Therefore, the making of the representations as set forth in Paragraph 59 

of this Complaint constitutes a deceptive act or practice, in or affecting commerce 

in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT II 

62. Through the means described in Paragraphs 15 through 56, Defendants 

have represented, directly or indirectly, expressly or by implication, that consumers 

who subscribe to Defendants’ websites find rental housing, including Section 8 

housing, within seven business days or less. 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 19 of 20 Page ID #:19 

63. Defendants’ representation set forth in Paragraph 62 of this Complaint is 

false or misleading, or was not substantiated at the time the representation was 

made. 

64. Therefore, the making of the representation as set forth in Paragraph 62 

of this Complaint constitutes a deceptive act or practice, in or affecting commerce 

in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

COUNT III 

65. Through the means described in Paragraphs 15 through 56, Defendants 

have represented, directly or indirectly, expressly or by implication, that 

Defendants have exclusive rights to list thousands of rental listings on their 

websites, exclusive rights to list Section 8 rental listings, and that consumers 

cannot find these listings on free websites. 

66. Defendants’ representations set forth in Paragraph 65 of this Complaint 

are false or misleading, or were not substantiated at the time the representations 

were made. 

67. Therefore, the making of the representations as set forth in Paragraph 65 

of this Complaint constitutes a deceptive act or practice, in or affecting commerce 

in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

CONSUMER INJURY 

68. Consumers have suffered and will continue to suffer substantial injury 

as a result of Defendants’ violations of the FTC Act. In addition, Defendants have 

been unjustly enriched as a result of their unlawful acts or practices. Absent 

injunctive relief by this Court, Defendants are likely to continue to injure 

consumers, reap unjust enrichment, and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

69. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 

to grant injunctive and such other relief as the Court may deem appropriate to halt 

and redress violations of any provision of law enforced by the FTC. The Court, in 

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the exercise of its equitable jurisdiction, may award ancillary relief, including 

rescission or reformation of contracts, restitution, the refund of monies paid, and 

the disgorgement of ill-gotten monies, to prevent and remedy any violation of any 

provision of law enforced by the FTC. 

PRAYER FOR RELIEF 

Wherefore, the FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. 

§§ 53(b ), and the Court's own equitable powers, requests that the Court: 

A. A ward the Commission such preliminary injunctive and ancillary relief 

as may be necessary to avert the likelihood of consumer injury during the 

pendency of this action and to preserve the possibility of effective final relief, 

including but not limited to, temporary and preliminary injunctions; 

B. Enter a permanent injunction to prevent future violations of the FTC Act 

by Defendants; 

C. A ward such relief as the Court finds necessary to redress injury to 

consumers resulting from Defendants' violations of the FTC Act, including but not 

limited to, rescission or reformation of contracts, restitution, the refund of monies 

paid, and the disgorgement of ill-gotten monies; and 

D. Award the Commission the costs of bringing this action, as well as such 

other and additional relief as the Court may determine to be just and proper. 

Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

~~ l(~kw, i . ~ 

Rhonda P. Perkins 

Amanda R. Grier 

Stacy R. Procter (Local Counsel) 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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Case 8:18-cv-01636 Document 1 Filed 09/11/18 Page 20 of 20 Page ID #:20