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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

Docket No. C-XXXX 

COMPLAINT 

Pursuant to the provisions of the Federal Trade Commission Act, as amended, 15 U.S.C. § 41, et 

seq., and by virtue of the authority vested in it by said Act, the Federal Trade Commission 

(“Commission”), having reason to believe that Prudential Security, Inc. (“Prudential Security”), a 

corporation; Prudential Command Inc. (“Prudential Command”), a corporation; Greg Wier, 

individually and as an officer and co-owner of Prudential Security, Inc. and Prudential Command 

Inc.; and Matthew Keywell, individually and as an officer and co-owner of Prudential Security, 

Inc. and Prudential Command Inc., hereinafter sometimes referred to as “Prudential” or 

“Respondents,” have violated the provisions of Section 5 of the Federal Trade Commission Act, 

15 U.S.C. § 45, and it appearing to the Commission that a proceeding by it in respect thereof would 

be in the public interest, hereby issues this Complaint stating its charges in that respect as follows: 

In the Matter of

Prudential Security, Inc., 

a corporation, 

Prudential Command Inc, 

a corporation, 

Greg Wier, 

a natural person, 

and

Matthew Keywell, 

a natural person.
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NATURE OF THE CASE 

1. This action addresses the unfair use of post-employment covenants not to compete by 

Prudential Security, Inc. and Prudential Command Inc., affiliated security guard 

companies, and Greg Wier and Matthew Keywell, the sole co-owners and officers of these 

companies. The term post-employment covenants not to compete (or “Non-Compete 

Agreements”), as used in this complaint, refers to contract terms that, following the 

conclusion of a worker’s employment with one employer, restrict the worker’s freedom to

accept employment with competing businesses, to form a competing business, or otherwise 

to compete with the employer. Such agreements tend to be coercive and exploitative. 

2. Respondents’ imposition of Non-Compete Agreements took advantage of the unequal 

bargaining power between Respondents and their employees, particularly low-wage 

security guard employees. Respondents’ use of Non-Compete Agreements harmed 

employees by reducing job mobility, limiting competition for employee services, and thus 

depriving employees of higher wages and more favorable working conditions. 

Respondents repeatedly used their Non-Compete Agreements to block their employees 

from accepting alternative employment, including employment at significantly higher 

wages than the employees had earned working for Respondents. 

RESPONDENTS 

3. Respondent Prudential Security, Inc. (a.k.a. Trollpru, Inc.) is a corporation organized and 

existing under, and by virtue of, the laws of the State of Michigan that, prior to August 26, 

2022, maintained its executive offices and principal place of business at 20600 Eureka 

Road, Suite 900 Taylor, MI 48180. 

4. Respondent Prudential Command Inc. (a.k.a. Commandbabyyoda, Inc.) is a corporation 

organized and existing under, and by virtue of, the laws of the State of Michigan that, prior 

to August 26, 2022, maintained its executive offices and principal place of business at 

20600 Eureka Road, Suite 900 Taylor, MI 48180. Prudential Command Inc. is an affiliate 

of Respondent Prudential Security, Inc. 

5. Respondent Greg Wier is an owner and President of Prudential Security, Inc. and 

Prudential Command Inc. Individually or in concert with others, including Matthew 

Keywell, he formulated, directed, or controlled the policies, acts, or practices of Prudential 

Security and Prudential Command. His principal office or place of business is located at 

. 

6. Respondent Matthew Keywell is an owner and officer of Prudential Security, Inc. and 

Prudential Command Inc. Individually or in concert with others, including Greg Wier, he 

formulated, directed, or controlled the policies, acts, or practices of Prudential Security and 

Prudential Command. His principal office or place of business is located at 

. 
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JURISDICTION 

7. At all times relevant herein, Prudential Security and Prudential Command have been, and 

are now, corporations, as “corporation” is defined in Section 4 of the Federal Trade 

Commission Act, 15 U.S.C. § 44. 

8. At all times relevant herein, Greg Wier and Matthew Keywell have been the sole owners 

and officers of Prudential Security and Prudential Command. 

9. Respondents have engaged in commerce and activities affecting commerce in the United 

States, as the term “commerce” is defined in Section 4 of the Federal Trade Commission 

Act, 15 U.S.C. § 44. 

RESPONDENTS’ NON-COMPETE AGREEMENTS 

10. Prior to August 2022, Respondents provided security guard services across several states. 

Respondents hired security guards as employees who were then assigned to work at their 

clients’ facilities. Respondents maintained offices in Michigan, Pennsylvania, South 

Carolina, Tennessee, and Wisconsin. 

11. Prior to August 2022, Respondents required all of their security guard employees to sign 

Non-Compete Agreements as a condition of employment. These employees made up the 

vast majority of Respondents’ workforce. 

12. Respondents’ Non-Compete Agreements require that, for two years following the 

conclusion of an employee’s employment with Respondent, the employee may not 

“[a]ccept employment with or be employed by” a competing business “within a one 

hundred (100) mile radius” of the employee’s primary jobsite with Respondents. 

Respondents’ Non-Compete Agreements also contain other terms restricting their 

employees’ post-employment activities that prevent them from joining or forming a 

competing firm. These restrictions include, but are not limited to, requiring that former 

employees may not “[a]ssist, aid or in any manner whatsoever help any firm, corporation, 

partnership or other business to compete with” Respondents. 

13. Respondents’ Non-Compete Agreements contain a “liquidated damages” clause, which 

requires that the employee pay Respondents $100,000 as a penalty for any conduct that 

contravenes Respondents’ Non-Compete Agreement. 

14. Respondents’ security guard employees typically earned hourly wages at or only slightly 

above minimum wage. Respondents did not offer their security guard employees any 

additional compensation in exchange for signing Non-Compete Agreements. 

15. Respondents did not permit their security guard employees to negotiate the terms of their 

Non-Compete Agreements, and such employees were required to accept Respondents’

standard terms as a condition of employment with Respondents. Respondents’ security 
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guard employees seldom, if ever, consulted with attorneys before signing their NonCompete Agreements. 

16. In August 2022, Respondents sold the bulk of their security guard assets to another security 

guard company, Titan Security Group, LLC (“Titan”). Respondents no longer provide 

security guard services and former Prudential security guards who now work for Titan are 

not subject to Non-Compete Agreements with Titan. But approximately 1,500 of 

Respondents’ former employees are still subject to Non-Compete Agreements with 

Respondents. These agreements enable Respondents to attempt to block former employees 

from working for any other security guard company for two years and to seek significant 

monetary penalties from such employees if they do seek to work for another such company. 

17. Greg Wier and Matthew Keywell continue to own and control other businesses that employ 

workers. In addition, Mr. Wier and Mr. Keywell may launch new business ventures in the 

future. 

RESPONDENTS’ ENFORCEMENT OF NON-COMPETE AGREEMENTS 

18. Respondents used their Non-Compete Agreements to block their security guard employees 

from seeking or accepting alternative employment. Respondents threatened individual 

employees with enforcement of their Non-Compete Agreements if they accept positions 

with competing employers. Respondents repeatedly brought lawsuits against both 

individual employees and competing security guard companies to enforce their NonCompete Agreements. 

19. Respondents contacted competing security guard companies to ask the competing 

companies to refrain from hiring Respondents’ security guard employees because the 

employees had signed Non-Compete Agreements with Respondents. 

20. Respondents used their Non-Compete Agreements to block employees from accepting 

employment at higher wages with competing security guard companies. For example, in 

2018, a competing security guard company offered employment to a number of 

Respondents’ security guard employees. The competing security guard company offered 

Respondents’ employees significant raises and more favorable working conditions. When 

Respondents became aware of the competing offer, they sued several of the security guards 

to prevent them from accepting employment with the competing company. 

21. Similarly, in 2019, a competing security guard company hired one of Respondents’ former 

employees. The former employee had joined Respondents as a security guard and had 

signed a Non-Compete Agreement as a condition of his employment as a security guard. 

Respondents sued the former employee and the competing company, seeking injunctive 

and monetary relief. The competing company terminated Respondents’ former employee, 

and the employee reached a settlement with Respondents, which required the employee to 

refrain from working for any other security guard company. 
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22. In 2019, a Michigan state court held that Respondents’ Non-Compete Agreements with 

their security guard employees were unreasonable and unenforceable under state law. 

Nevertheless, Respondents continued to require all of their security guard employees to 

sign identical Non-Compete Agreements. 

EFFECTS OF THE CHALLENGED CONDUCT 

23. Respondents’ use of Non-Compete Agreements has harmed employees. 

24. Respondents’ employees, particularly their security guard employees, had significantly 

less bargaining power than Respondents. Largely because of this unequal bargaining 

power, Respondents were able to impose onerous Non-Compete Agreements on their 

employees. 

25. Respondents’ use of Non-Compete Agreements limited their employees’ ability to work 

for other firms in the security guard industry. Respondents repeatedly blocked their 

employees from accepting alternative employment. This interference with competition 

forced employees to accept significantly lower wages and less favorable working 

conditions. 

26. Any possible legitimate objectives of Respondents’ conduct as alleged herein could have 

been achieved through significantly less restrictive means, including, for example, by 

entering confidentiality agreements that prohibited disclosure of any confidential 

information. 

UNFAIR METHOD OF COMPETITION 

27. The allegations in all of the paragraphs above are re-alleged and incorporated by reference 

as though fully set forth herein. 

28. Respondents’ use of Non-Compete Agreements is a “method of competition” within the 

meaning of Section 5 of the Federal Trade Commission Act, as amended, 15 U.S.C. § 45. 

29. Respondents’ use of Non-Compete Agreements is coercive and exploitative and tends to 

negatively affect competitive conditions. 

30. Respondents’ conduct is an unfair method of competition harming employees in the 

security guard services industry. 

31. Respondents’ conduct violates Section 5 of the Federal Trade Commission Act, as 

amended, 15 U.S.C. § 45. Such conduct, or the effects thereof, is likely to recur in the 

absence of appropriate relief. 
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WHEREFORE, THE PREMISES CONSIDERED, the Federal Trade Commission on 

this [insert] day of [insert month], 2022, issues its complaint against Respondents. 

By the Commission. 

April Tabor 

Secretary 

SEAL