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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 1 of 30 

ALDEN F. ABBOTT 

General Counsel 

ROBERTA DIANE TONELLI, Cal. Bar No. 278738 

EMILY COPE BURTON, Cal. Bar No. 221127 

COLIN A. HECTOR, Cal. Bar No. 281795 

Federal Trade Commission 

901 Market Street, Suite 570 

San Francisco, CA 94103 

rtonelli@ftc.gov, eburton@ftc.gov, chector@ftc.gov 

Tel: (415) 848-5100; Fax: (415) 848-5184 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

vs. 

AH MEDIA GROUP, LLC, a Delaware Limited 

Liability Company, 

HENRY BLOCK, individually, and as an officer 

of AH MEDIA GROUP, LLC, 

ALAN SCHILL, individually, and as an owner 

and officer of AH MEDIA GROUP, LLC and 

ZANELO, LLC, 

and 

ZANELO, LLC, a Puerto Rico Limited Liability 

Company, 

Defendants. 

Case No. 19-cv-04022-JD 

FIRST AMENDED COMPLAINT 

FOR PERMANENT INJUNCTION 

AND OTHER EQUITABLE 

RELIEF 

FIRST AM. COMPLAINT 1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 2 of 30 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

1. The FTC brings this action under Sections 13(b) and 19 of the Federal Trade

Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b) and 57b, Section 5 of the Restore Online 

Shoppers’ Confidence Act (“ROSCA”), 15 U.S.C. § 8404, and Section 918(c) of the Electronic 

Fund Transfer Act (“EFTA”), 15 U.S.C. § 1693o(c), to obtain 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), Section 4 of ROSCA, 15 U.S.C. 

§ 8403, Section 907(a) of EFTA, 15 U.S.C. § 1693e(a), and Section 1005.10(b) of Regulation E,

12 C.F.R. § 1005.10(b).

JURISDICTION, VENUE, AND INTRADISTRICT ASSIGNMENT 

This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

3. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(2), (c)(2), and (d), and

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2. 

 U.S.C. §§ 53(b) and 57b. 

4. Assignment to the San Francisco Division is proper because Defendants have

advertised and sold their products in San Francisco County to numerous consumers who reside in 

the county. 

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. The FTC also 

enforces ROSCA, 15 U.S.C. §§ 8401-8405, which prohibits merchants from selling goods or 

services on the Internet through negative option marketing without meeting certain requirements 

to protect consumers. A negative option is an offer in which the seller treats a consumer’s 

silence as consent to be charged for goods or services. Additionally, the FTC enforces EFTA, 15 

FIRST AM. COMPLAINT 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 3 of 30 

U.S.C. § 1693-1693r, which regulates the rights, liabilities, and responsibilities of participants in 

electronic fund transfer systems. 

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

attorneys, to enjoin violations of the FTC Act, ROSCA, and EFTA, 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), 57b, 8404 and 1693o(c).

DEFENDANTS 

7. Defendant AH Media Group, LLC (“AH Media”) is a Delaware limited liability

company that has held itself out as doing business at 5455 Landmark Place, #809, Greenwood 

Village, Colorado 80111. At all times material to this Complaint, acting alone or in concert with 

others, AH Media has advertised, marketed, distributed, or sold personal care products and 

dietary supplements to consumers throughout the United States. AH Media transacts or has 

transacted business in this District, including by advertising and selling products to consumers in 

this District, and throughout the United States. 

8. Defendant Zanelo, LLC (“Zanelo”) is a Puerto Rico limited liability company

that has held itself out as doing business at 7 Calle Manuel Rodriguez Sierra, Apartment 6, San 

Juan, Puerto Rico 00907. At times material to this Complaint, acting alone or in concert with 

others, Zanelo has advertised, marketed, distributed, or sold personal care products and dietary 

supplements to consumers throughout the United States. Zanelo transacts or has transacted 

business in this District, including by advertising and selling products to consumers in this 

District, and throughout the United States. Zanelo also has received substantial funds from AH 

Media. 

9. Defendant Henry Block (“Block”) is the Manager of and Registered Agent for

AH Media, as well as the authorized signer on AH Media’s bank account. Block is also the 

Managing Member of H Block Investments, LLC (“HBI”), a Colorado limited liability company 

which is a Member of and holds a 50% ownership interest in AH Media. Block signed AH 

FIRST AM. COMPLAINT 3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 4 of 30 

Media’s Operating Agreement on behalf of HBI and is also the authorized signer for HBI’s bank 

account. 

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

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

and practices of AH Media, including the acts and practices set forth in this Complaint. Among 

other things, Block has had the authority to control the advertising, marketing, promotion, 

offering for sale, or sale of AH Media’s products, including the registering of websites; the 

processing of consumers’ payments; and the handling of consumer complaints. Block also has 

recruited individuals to act as straw owners for shell companies to process payments for Zanelo, 

and maintained a Zanelo corporate email address. In connection with the matters alleged herein, 

Block transacts or has transacted business in this District, including by advertising and selling 

products to consumers in this District, and throughout the United States. 

11. Defendant Alan Schill (“Schill”) is one of two signatories on AH Media’s

Operating Agreement. Schill signed the agreement on behalf of XI Family, LP (“XI Family”), a 

Delaware Limited Partnership, which is a Member of and holds a 50% ownership interest in AH 

Media. Schill is the Managing Member of XI Management, LLC, a Delaware limited liability 

company, which is the General Partner of XI Family. Schill is the sole owner of Zanelo. 

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

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

and practices of AH Media, including the acts and practices set forth in this Complaint. Among 

other things, Schill has had the authority to control AH Media through XI Family’s 50% 

ownership stake, and has participated directly in Defendants’ responses to consumer complaints. 

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

acts and practices of Zanelo. As sole owner of Zanelo, Schill has had the authority to control the 

advertising, marketing, promotion, offering for sale, or sale of Zanelo’s products, and he has 

participated in an array of Zanelo’s practices, including branding, recruiting shell owners, and 

payment processing. In connection with the matters alleged herein, Schill transacts or has 

FIRST AM. COMPLAINT 4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 5 of 30 

transacted business in this District, including by advertising and selling products to consumers in 

this District, and throughout the United States. 

COMMERCE 

13. 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’ DECEPTIVE BUSINESS PRACTICES 

14. Since at least April 2016 and through the present, Defendants have operated an

online subscription scam, involving online marketing and sales of at least eight different product 

lines. Defendants sell mainly personal care products and dietary supplements, including 

Amabella Allure, Adelina, Parisian Glow, and Tone Fire Garcinia, which allegedly promote 

youthful skin and weight loss. Defendants offer low-cost “trials” of their products for just the 

cost of shipping and handling, typically $4.99 or less. When consumers order these trial 

products, however, Defendants enroll consumers into a continuity plan without their knowledge 

or consent. After an initial two-week trial period, Defendants automatically charge consumers 

the full price for the product—approximately $90. Defendants continue to charge consumers the 

product’s full price, plus an additional shipping and handling fee, each month until consumers 

cancel their continuity plan. Additionally, Defendants frequently charge consumers for 

additional products and enroll consumers in continuity programs related to these additional 

products, all without consumers’ knowledge or consent. As a result of their deceptive, unfair, 

and unlawful conduct, Defendants have taken more than $59 million from consumers across the 

United States. 

15. Defendants have furthered their scheme by using a network of shell companies

and straw owners to process consumer payments. Defendants formed, or caused to be formed, 

over 90 limited liability companies between April 2016 and the present (“the Associated LLCs”). 

Defendants process payments through the Associated LLCs, hiding behind purportedly 

independent entities to circumvent credit card associations’ monitoring programs, avoid 

FIRST AM. COMPLAINT 5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 6 of 30 

detection by consumers and law enforcement, and contest consumer disputes using fraudulent 

documentation. 

16. Most of the scheme’s business activities have been conducted through AH Media 

or Zanelo. Block directs much of the day-to-day work of AH Media, including working with the 

product fulfillment center, coordinating domain registration for Defendants’ websites, and 

serving as the bank account signatory for AH Media and the Associated LLCs. Block controls 

AH Media through HBI, which is an owner of AH Media. Block has received millions of dollars 

funds from the scheme described herein through HBI. 

17. Schill is involved in the regular affairs of the business (e.g., receiving consumer 

complaints, maintaining an AH Media Group email account). Schill controls AH Media through 

XI Management and XI Family, the latter of which is also an owner of AH Media. Schill has 

received more than $3 million from AH Media, including over a million dollars transferred from 

AH Media to Zanelo. 

18. In early to mid-2019, Defendants began winding down AH Media—although it 

continued to collect payments from consumer victims—and transitioned the scheme to Zanelo. 

19. Block continued to be involved in the regular affairs of the business, continuing to 

receive payments through AH Media and recruiting individuals to act as straw owners of shell 

companies created to process payments for Zanelo. 

20. Schill has been the exclusive owner and Authorized Person for Zanelo, and is the 

sole signatory on the company’s bank account. Schill also has been heavily involved in the dayto-day operation of Zanelo, including the recruitment of shell owners and opening merchant 

accounts. 

Defendants’ Deceptive Trial Offers 

21. Defendants engage third-party affiliate marketers to advertise Defendants’ 

products online. The affiliate marketers do so through various internet marketing and social 

media channels. These advertisements often state that consumers can receive a “trial” of one of 

Defendants’ products for just the cost of shipping and handling. Some of these advertisements 

also falsely state that a celebrity has endorsed the product. 

FIRST AM. COMPLAINT 6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 7 of 30 

22. When consumers click on the affiliate marketers’ advertisements, a hyperlink 

sends them to one of Defendants’ websites. Defendants have registered more than 300 websites, 

at least some of which they use or have used to market and sell their products. The account used 

to register the websites is associated with Henry Block’s name and email address. 

23. Like the affiliate marketers’ advertisements, Defendants’ websites purport to offer 

product “trials” for only the cost of shipping and handling, typically $4.99. 

Defendants’ Trial Offer Ordering Process 

Defendants’ Landing Pages 

24. After consumers click on links in the affiliate marketers’ advertisements for 

Defendants’ products, the links transfer consumers to webpages on Defendants’ websites called 

“landing pages.” Numerous landing pages contain claims regarding the efficacy of the products. 

They also say that consumers can receive a trial product.1 

25. Defendants’ landing pages create a sense of urgency by stating that there is a 

limited supply of the trial product and that consumers need to act quickly. Representative 

statements include: 

• “ATTENTION: Due to high demand from recent media coverage we can no 

longer guarantee supply. As of [today’s date] we currently have product in-stock 

and will ship within 24 hours of purchase.” 

• “ONLY [number] TRIALS AVAILABLE NOW!” 

• “HURRY! CLAIM YOUR TRIAL TODAY” 

• “Limit 1 Trial per Customer 

Don’t get left behind!” 

1 Figures 1 through 4 are excerpts from a May 16, 2018 recorded purchase of one of Defendants’ products, Adelina 

Skin Cream. The complete recording of the purchase has been reproduced as Exhibit A to Complaint. The 

recording was captured beginning at the website: 

https://tryadelinaskin.com/d/v1/index.php?affId=A5EC8C24&c1=206070&c2=&c3=. 

FIRST AM. COMPLAINT 7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 8 of 30 

26. Defendants request that consumers who are interested in the trial offer provide 

their name and contact information. After consumers do so, Defendants direct consumers to a 

payment page, as described below. 

27. Defendants’ landing pages do not include clear or conspicuous disclosures 

explaining the terms of the trial offer. The landing pages do not include any visible statements 

about the terms and conditions of the trial offer, such as (1) that Defendants will charge 

consumers the full cost of the product if they do not cancel the trial offer within a short period of 

time; (2) the cost of the product; (3) that Defendants will enroll consumers automatically in a 

continuity plan, pursuant to which Defendants will send them additional products each month 

and will charge them accordingly until they successfully cancel the continuity plan; or (4) that 

the trial offer includes restrictive cancellation and refund policies. 

28. On some of Defendants’ websites, at the very bottom on the landing page, there is 

a small link leading to the terms and conditions. In sharp contrast to the prominent and vibrantly 

colored statements concerning the trial offer, the terms and conditions link appears in small, grey 

font. To find the terms and conditions link, consumers would have to scroll down several page 

lengths, to the very bottom of the landing page. Only by clicking on the link may consumers 

view information (buried under other details and requiring the consumer to scroll down) 

regarding their enrollment in a continuity plan with recurring monthly charges. 

29. For example, Figure 1 shows Defendants’ Adelina Skin Cream landing page. On 

this page, a bright green button stating “RUSH MY TRIAL” urges consumers to provide their 

contact information and request a trial of Defendants’ product. 

FIRST AM. COMPLAINT 8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 9 of 30 

Figure 1 (portion of a landing page for Adelina Skin Cream). 

Defendants’ Payment Pages 

30. On the payment pages of their websites, Defendants request consumers’ credit or 

debit card information and state that consumers need to pay only a shipping and handling fee, 

generally $4.99 or less, to receive a trial of Defendants’ product. 

31. The payment pages prominently state that the total cost of the product is equal to 

the cost of the shipping and handling fee. Thus, the payment pages reiterate the message from 

Defendants’ landing pages that, other than the obligation to pay shipping and handling, the trial 

product is free. 

32. Defendants’ payment pages routinely lack any visible statements regarding the 

terms of the trial offer. Consumers usually can learn about the short trial period, the fact that 

they will be charged the full cost of the product at the end of the trial period, and that ordering 

the trial will enroll them in a continuity plan, only by clicking a small terms and conditions link 

(and then combing through dense text). 

FIRST AM. COMPLAINT 9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 10 of 30 

33. For example, as shown in Figure 2, Defendants’ payment page for Adelina Skin 

Cream states, “Just pay a small shipping fee,” and lists the “NEW TOTAL” as $4.99, equivalent 

to the cost of the shipping and handling fee. The “Terms” link is in small print toward the 

bottom of the webpage, away from the bright green “COMPLETE CHECKOUT” button, and 

overshadowed by brighter, larger text and graphics on the page. 

Figure 2 (excerpt of payment page for Adelina Skin Cream). 

Defendants’ Order Completion Pages 

34. After consumers enter their credit or debit card information and submit their 

requests for trials of Defendants’ products, and before they reach the final order summary page, 

Defendants often direct consumers to webpages that invite them to sign up for additional trial 

offers, allegedly for related products. 

FIRST AM. COMPLAINT 10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 11 of 30 

35. For example, consumers who click “COMPLETE CHECKOUT” on the payment 

page for Defendants’ Adelina Skin Cream (see Figure 2 above) are taken to an order completion 

page, reproduced as Figure 3 below. The order completion page displays an Adelina banner at 

the top. The page states in large, bold text “WAIT! YOUR ORDER IS NOT COMPLETE.” 

The page then offers a “FREE TRIAL” of the product Adelina Eye Serum, which will 

purportedly “amplify your results.” To get the “FREE TRIAL” of the eye serum, the text clearly 

states, “Just pay shipping of $4.97.” This page does not state that there is any additional cost 

associated with the eye serum or any additional terms or conditions of the eye serum trial offer. 

Figure 3 (excerpt of order completion page for Adelina Eye Serum). 

36. As noted in Figure 3, Defendants’ webpage indicates that consumers have not 

completed their order of the initial product until they click the bright, prominent “COMPLETE 

CHECKOUT” button, located under the advertisement for the second product. This webpage 

FIRST AM. COMPLAINT 11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 12 of 30 

does not state that, by clicking “COMPLETE CHECKOUT,” Defendants will add another item 

to the consumers’ orders. However, when consumers do click the “COMPLETE CHECKOUT” 

button, Defendants enroll the consumers in an additional continuity plan for the second product. 

37. In contrast to the prominent “COMPLETE CHECKOUT” buttons, the websites’ 

order completion pages also contain a small link at the bottom that, if clicked, allows consumers 

to complete their transaction without agreeing to another trial offer. 

38. For example, Figure 3 includes a small, gray link that says “No, Thanks. I decline 

the offer.” This link appears well below the bright green “COMPLETE CHECKOUT” button 

and does not specify whether, by clicking the link, the consumer is declining the initial trial offer 

or the trial offer for the second product. 

39. As with the initial trial offer, the order completion pages also fail to disclose 

important terms and conditions of the offer. Defendants represent that the additional product is 

free with payment of only a small shipping fee. However, in fact, Defendants charge consumers 

the full price of the additional product approximately 14 days after they request the trial product. 

Defendants also enroll consumers who click the “COMPLETE CHECKOUT” button in an 

additional continuity plan for the additional product, meaning that Defendants will charge 

consumers monthly for the full price of both the original product and the additional product until 

consumers cancel the continuity plan. Consumers can see statements about the terms and 

conditions of the trial offer only by clicking the small terms and conditions link at the bottom of 

the page. 

40. Regardless of whether consumers click on the “COMPLETE CHECKOUT” 

button or click on the link to decline the additional trial offer, Defendants often redirect them to 

another page with additional offers. Consumers must decline those offers as well to move to the 

final order summary page described below. 

Defendants’ Order Summary Pages 

41. After navigating through one or more order completion pages, consumers finally 

arrive at an order summary page on Defendants’ websites. The order summary pages 

FIRST AM. COMPLAINT 12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 13 of 30 

prominently list the products ordered and give a total cost reflecting only the cost of the shipping 

and handling fee. Some order pages contain a small statement toward the bottom of the 

webpage, which describes some terms regarding the order. Some order pages contain no such 

statement at all. 

42. For example, in Defendants’ order summary page for Adelina, reproduced as 

Figure 4 below, the page lists the “Items Ordered.” Under the “Items Ordered” heading, 

Defendants provide a cost breakdown and “Grand Total” showing only the shipping and 

handling fee. The page also restates the consumer’s billing and shipping information. Under 

these details, and below the page break on the computer screen, there is a statement in light grey 

font, which provides some limited information about the continuity plan, the product price, and 

terms for cancellation. The statement is significantly smaller and lighter than other text on the 

page. Given the small font size and light-colored text used in Defendants’ statement, it is largely 

unreadable; for this reason, Figure 4 includes an added red callout box that enlarges the text of 

the statement. Consumers visiting this website would not have the benefit of the callout box. 

FIRST AM. COMPLAINT 13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Figure 4 (excerpt of order summary page for Adelina Skin Cream; red graphics and callout box 

added to highlight and make more prominent the text of the statement). 

43. These statements displayed on Defendants’ order summary pages, when they are 

present, are neither clear nor conspicuous, and are provided only after consumers have already 

completed the order for the trial product and therefore have already been enrolled in one or more 

continuity plans. 

44. After consumers request a trial of Defendants’ products, Defendants often fail to 

send any confirmation email whatsoever. When Defendants do send consumers a confirmation 

email, it lists only the shipping and handling fee as the “Grand Total” of the order. The 

confirmation emails do not provide information about the continuity plan, additional payments, 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 15 of 30 

or cancellation procedures. The confirmation emails thus reinforce the false impression from the 

websites that, other than the obligation to pay the shipping and handling fee, the trial product is 

free. 

45. Consumers often learn that the trial is not free and that they have been enrolled in 

a continuity plan only when they see Defendants’ monthly charges on their credit card or bank 

statements or receive unexpected products. 

Defendants’ Restrictive Cancellation and Refund Practices 

46. After consumers discover that Defendants are charging them on a monthly basis 

for one or more of Defendants’ products, many attempt to cancel their enrollment in the 

continuity plan and to obtain a refund of Defendants’ unauthorized charges. 

47. Defendants require that consumers call a customer service phone number to 

cancel their enrollment. Consumers cannot cancel their continuity plan enrollment online. Some 

consumers have difficulty locating a working phone number to reach a customer service 

representative. Consumers who call Defendants’ customer service phone number often have 

difficulty reaching Defendants’ customer service representatives, despite calling numerous times. 

In some instances, consumers have been left on hold with customer service for long periods. 

Even after consumers request that Defendants cancel their enrollment, some consumers report 

that Defendants have continued charging them for monthly product shipments. 

48. Many consumers who manage to reach a customer service representative also 

encounter a range of difficulties in obtaining refunds from Defendants for the unauthorized 

charges. Defendants, or their agents, refuse some consumers refunds because the requests were 

untimely: customer service representatives tell consumers that the products’ terms and conditions 

require refund requests to be made within 30 days of ordering. When this purported refund 

period has not lapsed, Defendants’ customer service representatives tell some consumers that 

they can receive a refund only if the trial product is returned unopened and at the consumer’s 

expense. Defendants still refuse refunds to some consumers who attempt to return products by 

claiming that the company never received the products. 

FIRST AM. COMPLAINT 15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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49. In many instances, consumers attempt to get their money back by initiating 

chargebacks with their credit card companies. As described below, Defendants use fraudulent 

versions of their websites to dispute consumers’ chargeback requests. 

50. In other instances, consumers receive refunds directly from Defendants only after 

consumers complain to the Better Business Bureau or a state regulatory agency. Even in those 

instances, however, Defendants have not always issued full refunds. 

Defendants Further the Fraud Through Shell Companies With Fake Websites, Which 

Defendants Use to Launder Credit Card Payments and Contest Chargebacks 

Background on Merchant Accounts and Credit Card Laundering 

51. To accept credit card payments from consumers, a merchant must establish a 

merchant account with a merchant acquiring bank (“acquirer”). A merchant account is a type of 

account that allows businesses to process consumer purchases made using credit or debit cards. 

52. Acquirers enter into contracts with payment processors, which manage the bank’s 

merchant processing program. Payment processors in turn frequently enter contracts with 

multiple “independent sales organizations” (“ISOs”) that sign up merchants for merchant 

accounts with the acquirer. 

53. The acquirer has access to the credit card associations (“card networks”), such as 

MasterCard and VISA. The card networks require all participants in their networks, including 

the acquirers and their registered ISOs, to comply with detailed rules governing the use of the 

card networks. These rules include screening processes and underwriting standards for 

merchants, to ensure that they are legitimate, bona fide businesses, and to screen out merchants 

engaged in potentially fraudulent or illegal practices. The rules also prohibit credit card 

laundering, which is the practice of processing credit card transactions through another 

company’s merchant account. 

54. To detect and prevent illegal, fraudulent, or unauthorized merchant activity, the 

card networks operate various chargeback monitoring and fraud monitoring programs. A 

“chargeback” is when a consumer disputes a credit card charge by contacting the bank that 

issued the credit or debit card; when a chargeback is successful, the consumer recovers the 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 17 of 30 

disputed funds from the acquirer, which in turn collects the amount from the merchant. If a 

merchant generates excessive levels of chargebacks that exceed the thresholds set under a card 

network’s chargeback monitoring program, the merchant is subject to additional monitoring 

requirements and, in some cases, penalties and termination. 

55. Credit card laundering is commonly used by fraudulent merchants who cannot 

meet a bank’s underwriting criteria or who cannot obtain merchant accounts under their own 

names (whether because of excessive chargebacks, complaints, or other signs of illegal activity). 

56. Even when fraudulent merchants can qualify for a merchant account, they may 

engage in laundering as a way to conceal their true identities from consumers, the card networks, 

and law enforcement agencies. 

57. To conceal their identities, fraudulent merchants often create shell companies to 

act as fronts, and apply for merchant accounts under these shell companies. Once the merchant 

accounts are approved, the fraudulent merchant then launders its own transactions through the 

shell company’s merchant accounts. 

58. Using multiple merchant accounts allows fraudulent merchants to go undetected 

and maintain continued access to the card networks. The fraudulent merchant may use each 

merchant account for only a short period in order to go unnoticed. With multiple merchant 

accounts, the fraudulent merchant can also manage chargeback rates: when one merchant 

account receives too many chargebacks, the fraudulent merchant can switch to a new merchant 

account. Using multiple merchant accounts also may allow the merchant to maintain continued 

access to the card networks in the event any of the merchant’s accounts are terminated. 

Defendants Launder Transactions Through Dozens of Shell Companies 

59. As noted above, Defendants created, or caused to be created, over 90 Associated 

LLCs that acted as shell companies for AH Media or Zanelo. The Associated LLCs include 

those listed in Exhibit B to this Complaint. Defendants further their fraud through the 

Associated LLCs in two main ways. 

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60. First, Defendants use the Associated LLCs to engage in credit card laundering. 

Defendants obtain merchant accounts through the shell companies, hiding behind these entities 

to evade underwriting standards that target fraudulent and high-risk businesses. Defendants use 

the shell companies’ merchant accounts to process, or launder, consumer payments made 

through Defendants’ websites. 

61. The purported directors of the Associated LLCs are all straw owners, some of 

whom appear to be relatives or friends of Block or Schill. The straw owners are listed on the 

corporate documents and are held out as signatories in merchant account applications, but do not 

otherwise appear to engage in any business functions on behalf of the Associated LLCs. 

62. The Associated LLCs do not appear to have any employees or to conduct any 

business other than debiting consumers’ credit cards and financial accounts. 

63. Defendants appear to have sole control over many of the Associated LLCs. Block 

has directly controlled the business bank accounts of Associated LLCs that processed payments 

for AH Media. 

64. With respect to the Associated LLCs that processed payments for Zanelo, 

Defendants had the straw LLC owners open bank accounts, and then provide the login 

credentials for online banking to Zanelo so that Zanelo could control and manage the accounts. 

65. Defendants applied for numerous merchant accounts in the name of shell 

companies, through which they launder charges to consumers’ credit or debit cards. From April 

2016 to the present, Defendants, directly or through agents acting on their behalf and for their 

benefit, submitted over a hundred deceptive merchant applications in the name of numerous shell 

companies to ISOs. 

66. Multiple ISOs approved the merchant account applications, set up merchant 

accounts for the Associated LLCs, and began processing payments through acquiring banks. 

67. From April 2016 to the present, the Defendants have used merchant accounts in 

the name of certain Associated LLCs to process consumers’ payments for purported skin care 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 19 of 30 

and weight loss products under brand names such as Amabella Allure, Adelina, AmbroSina, 

Parisian Glow, TrimOrganix Garcinia, and Tone Fire Garcinia. 

68. When payments for Defendants’ products are processed through the merchant 

accounts that Defendants secured in the names of the Associated LLCs, the sales revenues are 

automatically transferred into the corresponding Associated LLCs’ bank accounts. From there, 

the Associated LLCs transfer consumers’ money, directly or through intermediary accounts, into 

one of two centralized accounts held by AH Media at First National Bank (the “AH Media FNB 

Account”) and Zanelo at Banco Popular. The AH Media FNB Account has paid expenses for 

Defendants’ operation and also distributes funds to HBI, Schill, and Zanelo. 

69. Even though Defendants spread their transactions across multiple accounts to help 

manage chargeback levels, a number of merchant accounts held in the name of the Associated 

LLCs were closed due to excessive chargeback levels. 

Defendants Use Dummy Websites to 

Obtain Merchant Accounts and Dispute Chargeback Requests 

70. Defendants also further their fraud by using the Associated LLCs to establish 

“dummy” websites that they use in contesting chargebacks. 

71. Underwriters for payment processors and banks (who decide whether a processor 

or bank should open an account for a merchant) may look at a merchant account applicant’s 

websites to learn about the applicant, including whether the applicant’s business practices might 

expose the processor to risk. 

72. To evade this scrutiny, Defendants create dummy underwriting websites to show 

payment processors when they seek new merchant accounts. Defendants’ dummy websites 

differ significantly from the websites that actually generate Defendants’ sales. 

73. Defendants’ dummy websites have more prominent disclosures about the terms of 

the trial offers, including information about the continuity plan and how to avoid incurring 

further charges. These dummy websites explain, in text directly below the contact information 

fields, that consumers have the option to cancel within a short period at no cost, or to be charged 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 20 of 30 

the full price of the trial product and enrolled in a monthly subscription program with monthly 

charges. The landing pages for the dummy websites also include a box for consumers to check 

stating that they had agreed to the terms of the offer. 

74. For example, Figure 5 is a reproduction of the dummy website landing page that 

associated shell company Peeps Investments LLC submitted in support of a merchant account 

application. 

Figure 5 (excerpt of landing page for Peeps Eye Serum submitted in merchant application). 

75. Defendants do not appear to use these dummy websites to sell products. Unlike 

Defendants’ consumer-facing websites (where Defendants actually sell products to consumers), 

the dummy sites do not have the security protocol typically used by merchants to accept 

payments through websites. Moreover, it appears that Defendants do not sell the products 

identified on the dummy sites. 

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76. As described above in Paragraphs 24 through 45, Defendants process their actual 

sales from consumer-facing websites, which lack clear and conspicuous disclosures about the 

trial offers. In sharp contrast to the dummy websites, the consumer-facing websites that 

Defendants use to sell their products fail to make any statements directly under the contact 

information fields. Instead, Defendants bury information about the continuity plans on the 

consumer-facing websites in small terms and conditions links, and in statements displayed in 

small font size and light-colored text that appear only after a consumer orders a product. In 

addition, Defendants’ consumer-facing websites do not have a checkbox that consumers click on 

to agree to the terms of the order. 

77. Defendants use the dummy websites to fraudulently challenge consumers’ 

chargeback requests. When consumers dispute Defendants’ charges, Defendants submit copies 

of their dummy websites to consumers’ credit card companies. In some instances, Defendants 

provide the credit card companies with copies of the dummy websites that include annotations. 

As demonstrated in one such annotated copy, reproduced below as Figure 6, these annotations 

include callouts to, and comments about, the disclosures on the dummy website as reasons 

consumers should not receive a chargeback. 

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Figure 6 (excerpt of Defendants’ submission to a credit card company to dispute a chargeback). 

78. Credit card companies sometimes relied on Defendants’ fraudulent submission of 

dummy website images as a reason to refuse consumers’ requests for chargebacks. 

79. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission. 

VIOLATIONS OF THE FTC ACT 

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

or practices in or affecting commerce.” 

81. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 23 of 30 

82. Acts or practices are unfair under Section 5 of the FTC Act if they cause or are 

likely to cause substantial injury to consumers that consumers cannot reasonably avoid 

themselves and that is not outweighed by countervailing benefits to consumers or competition. 

15 U.S.C. § 45(n). 

Count I 

Misrepresentations of the Price of Trial Offers 

83. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of personal care products and dietary supplements, Defendants 

represent, directly or indirectly, expressly or by implication, that Defendants will charge 

consumers at most only a shipping and handling fee for a one-time shipment of Defendants’ 

product. 

84. In truth and in fact, in numerous instances in which Defendants have made the 

representation set forth in Paragraph 83 of this Complaint, Defendants charge consumers more 

than a shipping and handling fee for one or more shipments of Defendants’ product. 

85. Therefore, Defendants’ representation described in Paragraph 83 of this 

Complaint is false and misleading, and constitutes a deceptive act or practice in violation of 

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

Count II 

Misrepresentations Regarding the Offer of Additional Products 

86. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of personal care products and dietary supplements to consumers who 

have already ordered a trial of one of Defendants’ products, Defendants represent, directly or 

indirectly, expressly or by implication, that clicking the “COMPLETE CHECKOUT” or similar 

button will merely complete their initial orders. 

87. In truth and in fact, in numerous instances in which Defendants have made the 

representation set forth in Paragraph 86 of this Complaint, consumers clicking the “COMPLETE 

CHECKOUT” button ordered an additional product and enrolled in a continuity plan for that 

product. 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 24 of 30 

88. Therefore, Defendants’ representation described in Paragraph 86 of this 

Complaint is false and misleading, and constitutes a deceptive act or practice in violation of 

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

Count III 

Failure to Disclose Adequately Material Terms of Trial Offer 

89. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of personal care products and dietary supplements, Defendants 

represent, directly or indirectly, expressly or by implication, that consumers can obtain a trial of 

Defendants’ product for the cost of shipping and handling, or for free. 

90. In numerous instances in which Defendants make the representation set forth in 

Paragraph 89 of this Complaint, Defendants fail to disclose, or to disclose adequately to 

consumers, material terms and conditions in their offer, including: 

a) The total cost of the product; 

b) That Defendants will charge consumers the total cost of the product upon 

expiration of the trial period, often 14 days; 

c) That Defendants will automatically enroll consumers in a continuity plan with 

additional charges; 

d) The cost of the continuity plan, and the frequency and duration of recurring 

charges; and 

e) The terms of Defendants’ return policies. 

91. In light of the representation described in Paragraph 89, Defendants’ failure to 

disclose, or to disclose adequately, the material information as set forth in Paragraph 90 

constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a). 

Count IV 

Unfairly Charging Consumers Without Authorization 

92. In numerous instances, Defendants have charged consumers without their express 

informed consent. Consumers were unaware of these pending unauthorized charges, and thus 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 25 of 30 

unable to prevent them. Defendants often refused to refund consumers the full amount of the 

unauthorized charges. 

93. Defendants’ actions cause or are likely to cause substantial injury to consumers 

that consumers cannot reasonably avoid themselves and that is not outweighed by countervailing 

benefits to consumers or competition. 

94. Therefore, Defendants’ acts or practices as described in Paragraph 92 constitute 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), (n). 

Count V 

Unfairly Injuring Consumers by Engaging in Credit Card Laundering 

95. In numerous instances, in connection with submitting applications to open 

merchant accounts to further Defendants’ online subscription scam, Defendants have engaged in 

credit card laundering by: 

a) Falsely representing, directly or through agents acting on their behalf and for 

their benefit, that the shell companies listed as the applicants on the merchant 

applications were the actual merchants who were applying for merchant 

accounts; or 

b) Falsely representing, directly or through agents acting on their behalf and for 

their benefit, that the individual signors listed as the principal owners on the 

merchant applications were the bona fide principal owners applying for 

merchant accounts. 

96. The Defendants’ actions cause or are likely to cause substantial injury to 

consumers that was not reasonably avoidable by consumers themselves and that is not 

outweighed by countervailing benefits to consumers or competition. 

97. Therefore, Defendants’ acts or practices as described in Paragraph 95 constitute 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), (n). 

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Count VI 

Unfairly Injuring Consumers by Submitting Fraudulent Chargeback Documentation 

98. In numerous instances, in connection with responding to consumer chargeback 

requests, Defendants have submitted fraudulent documentation. To dispute consumer 

chargeback requests, Defendants provided credit card companies with copies of websites, which 

were not in fact the actual websites from which the consumer completed the transaction in 

dispute. 

99. Due to Defendants’ actions, some consumers were unable to obtain a refund of 

the cost of the disputed transaction. Defendants’ actions cause or are likely to cause substantial 

injury to consumers that consumers cannot reasonably avoid themselves and that is not 

outweighed by countervailing benefits to consumers or competition. 

100. Therefore, Defendants’ acts or practices as described in Paragraph 98 constitute 

unfair acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45(a), (n). 

VIOLATIONS OF THE RESTORE ONLINE SHOPPERS’ CONFIDENCE ACT 

101. In 2010, Congress passed the Restore Online Shoppers’ Confidence Act, 15 

U.S.C. §§ 8401-8405, which became effective on December 29, 2010. Congress passed ROSCA 

because “[c]onsumer confidence is essential to the growth of online commerce. To continue its 

development as a marketplace, the Internet must provide consumers with clear, accurate 

information and give sellers an opportunity to fairly compete with one another for consumers’ 

business.” 15 U.S.C. § 8401(2). 

102. Section 4 of ROSCA, 15 U.S.C. § 8403, generally prohibits charging consumers 

for goods or services sold in transactions effected on the Internet through a negative option 

feature, as that term is defined in the Commission’s Telemarketing Sales Rule (“TSR”), 16 

C.F.R. § 310.2(w), unless the seller: (a) clearly and conspicuously discloses all material terms of 

the transaction before obtaining the consumer’s billing information; (b) obtains the consumer’s 

express informed consent before making the charge; and (c) provides a simple mechanism to 

stop recurring charges. See 15 U.S.C. § 8403. 

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103. The TSR defines a negative option feature as: “in an offer or agreement to sell or 

provide any goods or services, a provision under which the consumer’s silence or failure to take 

an affirmative action to reject goods or services or to cancel the agreement is interpreted by the 

seller as acceptance of the offer.” 16 C.F.R. § 310.2(w). 

104. As described above, Defendants advertise and sell their personal care products to 

consumers through a negative option feature as defined by the TSR. See 16 C.F.R. § 310.2(w). 

105. Under Section 5 of ROSCA, 15 U.S.C. § 8404, a violation of ROSCA is treated as 

a violation of a rule promulgated under Section 18 of the FTC Act, 15 U.S.C. § 57a, and 

therefore constitutes an unfair or 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 VII 

Violation of ROSCA—Auto-Renewal Continuity Plan 

106. In numerous instances, in connection with the selling of their products on the 

Internet through a negative option feature, Defendants have failed to: 

a) Clearly and conspicuously disclose all material terms of the negative option 

feature of the product transaction before obtaining the consumer’s billing 

information; 

b) Obtain the consumer’s express informed consent to the negative option feature 

before charging the consumer’s credit card, debit card, bank account, or other 

financial account for the transaction; or 

c) Provide simple mechanisms for a consumer to stop recurring charges for 

products to the consumer’s credit card, debit card, bank account, or other 

financial account. 

107. Defendants’ acts or practices as set forth in Paragraph 106 are a violation of 

Section 4 of ROSCA, 15 U.S.C. § 8403, and are therefore treated as a violation of a rule 

promulgated under Section 18 of the FTC Act, 15 U.S.C. § 57a, 15 U.S.C. § 8404(a), and 

therefore constitute an unfair or deceptive act or practice in or affecting commerce in violation of 

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

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VIOLATIONS OF THE ELECTRONIC FUND TRANSFER ACT AND REGULATION E 

108. Section 907(a) of EFTA, 15 U.S.C. § 1693e(a), provides that a “preauthorized” 

electronic fund transfer from a consumer’s account may be “authorized by the consumer only in 

writing, and a copy of such authorization shall be provided to the consumer when made.” 

109. Section 903(10) of EFTA, 15 U.S.C. § 1693a(10), provides that the term 

“preauthorized electronic fund transfer” means “an electronic fund transfer authorized in 

advance to recur at substantially regular intervals.” 

110. Section 1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b), provides that 

“[p]reauthorized electronic fund transfers from a consumer’s account may be authorized only by 

a writing signed or similarly authenticated by the consumer. The person that obtains the 

authorization shall provide a copy to the consumer.” 

111. Section 1005.10 of the Consumer Financial Protection Bureau’s Official Staff 

Commentary to Regulation E, 12 C.F.R. § 1005.10(b), cmt. 5, Supp. I, provides that “[t]he 

authorization process should evidence the consumer’s identity and assent to the authorization.” 

The Official Staff Commentary to Regulation E further provides that “[a]n authorization is valid 

if it is readily identifiable as such and the terms of the preauthorized transfer are clear and readily 

understandable.” 12 C.F.R. § 1005.10(b), cmt. 6, Supp. I. 

Count VIII 

Unauthorized Debiting from Consumers’ Accounts 

112. In numerous instances, Defendants debit consumers’ bank accounts on a recurring 

basis without obtaining a written authorization signed or similarly authenticated from consumers 

for preauthorized electronic fund transfers from their accounts, thereby violating Section 907(a) 

of EFTA, 15 U.S.C. § 1693e(a), and Section 1005.10(b) of Regulation E, 12 C.F.R. 

§ 1005.10(b). 

113. Further, in numerous instances, Defendants debit consumers’ bank accounts on a 

recurring basis without providing a copy of written authorization signed or similarly 

authenticated by the consumer for preauthorized electronic fund transfers from the consumer’s 

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account, thereby violating Section 907(a) of EFTA, 15 U.S.C. § 1693e(a), and Section 

1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b). 

114. Under Section 918(c) of EFTA, 15 U.S.C. § 1693o(c), a violation of EFTA and 

Regulation E constitutes a violation of the FTC Act. 

115. Accordingly, by engaging in violations of EFTA and Regulation E as alleged in 

Paragraphs 112 through 113 of this Complaint, Defendants have engaged in violations of the 

FTC Act. 15 U.S.C. § 1693o(c). 

CONSUMER INJURY 

116. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act, ROSCA, and EFTA. 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 

117. 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 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. 

118. Section 19 of the FTC Act, 15 U.S.C. § 57b, Section 5 of ROSCA, 15 U.S.C. 

§ 8404, and Section 917(c) of EFTA, 15 U.S.C. § 1693o(c), authorize this Court to grant such 

relief as the Court finds necessary to redress injury to consumers resulting from Defendants’ 

violations of the FTC Act, ROSCA, and EFTA, including the rescission or reformation of 

contracts and the refund of money. 

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Case 3:19-cv-04022-JD Document 74 Filed 10/23/19 Page 30 of 30 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Sections 13(b) and 19 of the FTC Act, 15 U.S.C. 

§ 53(b) and 57b, Section 5 of ROSCA, 15 U.S.C. § 8404, Section 917 of EFTA, 15 U.S.C. 

§ 1693o(c), and the Court’s own equitable powers, requests that the Court: 

A. Award Plaintiff such temporary and 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, an order freezing assets, and appointment of a receiver; 

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

ROSCA, and EFTA by Defendants; 

C. Award such relief as the Court finds necessary to redress injury to consumers 

resulting from Defendants’ violations of the FTC Act, ROSCA, and EFTA, 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 Plaintiff the costs of bringing this action, as well as such other and 

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

Dated: October 23, 2019 Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

/s/ Roberta Diane Tonelli 

Roberta Diane Tonelli 

Emily Cope Burton 

Colin A. Hector 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

FIRST AM. COMPLAINT 30