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FILED 

2016 M)E 27 P:·i 12: 32 

UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA h:_.~.L ... 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

EXPAND, INC., a corporation, also d/b/a Gigats, 

also d/b/a Education Match, also d/b/a SoftRock, 

Inc., and 

A YMAN A. DIFRA WI, a/k/a Alec Difrawi, a/k/a 

Ayman El-Difrawi, individually and as an officer 

or director of EXPAND, INC., 

Defendants. 

LnLh.-,j~·, ,.:.._ 

Case No. -----

COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER 

EQUITABLE RELIEF 

Plaintiff, the Federal Trade Commission ("FTC .. ), for its Complaint alleges: 

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

Commission Act (''FTC AcC), 15 U.S.C. § 53(b) to obtain preliminary and permanent 

injunctive relief, rescission or reformation of contracts, restitution, 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 generating consumer leads for sale 

to educational and other institutions. 
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JURISDICTION AND VENUE 

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

I 337(a), and 1345, and 15 U.S.C. §§ 45(a) and 53(b). 

3. Venue is proper in this district under 28 U.S.C. § 1391 (b)(I ), (b)(2), (b)(3), 

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

PLAINTIFF 

4. 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. 

5. The 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, and the 

disgorgement ofill-gotten monies. 15 U.S.C. §§ 53(b) and 56(a)(2)(A). 

DEFENDANTS 

6. Defendant Expand, Inc. ("Expand"), also doing business as Gigats, also doing 

business as Education Match, also doing business as SoftRock, Inc., is an Illinois corporation 

with its principal place of business in Orlando, FL. Expand transacts or has transacted 

business in this district and throughout the United States. 

7. Defendant Ayman A. Difrawi, also known as Alec Difrawi, also known as 

Ayman El-Difrawi, is the founder, self-described ·'quarterback," chief executive officer, and 

a director of Expand. 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 

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the acts and practices of Expand, including the acts and practices set forth in this Complaint. 

Defendant Difrawi 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. 

COMMERCE 

8. 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 

9. Defendants serve as lead generators for other businesses, particularly 

post-secondary schools and career training programs. Lead generators collect consumer 

contact and other information. They then sell this information to third parties as "leads." 

The third parties use the leads for their own purposes, including to market their own products 

or services. 

I 0. Defendants misrepresent that consumers may apply for jobs with prospective 

employers through Defendants, including by claiming that they pre-screen consumers on 

behalf of the prospective employers. In reality, many of the jobs Defendants advertise to 

consumers are not current job opportunities, and even when the job opportunities are current, 

Defendants are not authorized by the prospective employers to collect applications, screen 

applicants, or interview them for those jobs. In addition, although consumers may 

subsequently be instructed by Defendants to go to a prospective employer's website to apply 

to a job, Defendants do not pass along any information to the prospective employers about 

consumers who believe they have applied for the advertised position. 

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I I. Defendants further misrepresent to the same consumers that Defendants are 

also independent educational advisors who will assist consumers in finding the "best" 

educational options to help the consumers achieve their career goals. Defendants are, 

however, not searching for the best options for consumers, but rather confine their search to 

those educational institutions that will pay Defendants for consumer leads. Defendants 

engage in these deceptive practices in order to collect consumer information, such as names, 

contact information, and education and employment status, which Defendants then sell as 

leads primarily to educational and other institutions. 

12. Defendants' business has generated millions of dollars in revenue by selling 

consumer leads to educational and other institutions. 

Defendants Post Purported Job Openings on Gigats.com 

13. Since at least 2012, Defendants have owned and operated the website 

www.gigats.com, which they have used as a vehicle for collecting consumer leads. 

14. Defendants have collected information regardingjob openings at prospective 

employers, including multinational companies and government agencies, from various 

sources on the internet. Defendants have then drafted summaries of these job openings and 

posted these summaries on gigats.com. These posts resemble job announcements seeking 

applications from consumers. 

15. Consumers have found the job posts on gigats.com either after conducting 

internet searches for jobs or by being redirected to gigats.com from other websites. These 

websites include internet job boards on which Defendants have listed their job posts. In 

these listings, Defendants typically provide the job title, prospective employer, location, and 

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a brief description of the advertised position. as well as a I ink to the job post on gigats.eom. 

Defendants' listings contain internet links that direct consumers to gigats.com. not to the 

prospecti ve employer's website. 

16. Defendants ha ve crafted the job posts on gigats.com to appear as if they are 

posted by. or at the direction of. rhe prospective employer. The following is an example of a 

job post on gigats.com: 

I 

(.• · ft • D 

· • · .... J 

Bank Teller 

,. ... .. ~. lote. .. A..fl•"'"' 

_,.. 

••a.cittr"f\Oll~:.A,IV'n' 

··--·--·----...... _.. ..... -..... ..,. ___ _ -·---...,...---- . _ ....... - .... ~--·--- ·-- ---· 

O Chase 

-

"C:.-iQ-.~"'O'• _ .... -- _..,.,. 

..... ____ --·-'--~ ..,.. _ _,.. -- -

_._..._.,._ .. _.,. ........ __ __ -_ --.----·----·- ·-_ ..... __.,. .. _,_,. ..,, ___ .... .., ... - ........ ----. ~ 

---·-. .. --... ...... _.,., __ _ -..... -....-. ................ _ - ,,,._... ... 'OI.-....,,.._ 

___ ,,,. ....... -,,,, .................. ~ .. -·-· _.. 

.... 

_ '1-·-·- .. _...,,,.._ ...... --,.....-· ......... ., _______ _... ....... 

' 

--

17. The other job posts on gigats.corn fo llow a similar template as the above 

example. The job title (in the example above ... Bank Teller" ') is listed in the upper left hand 

corner. In the upper right hand corner is the name of the prospective employer. typically 

including that employer·s real logo. 

18. The ri ght-hand column contains a .. Position Description .. that includes the 

name and location or the purported job opening and then a description of the opening that 

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may discuss, among other things, pay, benefits, responsibilities, and required experience or 

skills. The Position Description then typically closes with an exhortation for the consumer 

to immediately apply for the position - for example, in the screenshot above, .. Apply online 

now to get started as a Chase Bank Teller!" 

19. The left-hand column seeks information that consumers reasonably would 

expect to be requested on a job application, including name, contact information, and 

education and employment status, and provides the option to upload a resume. 

20. Many consumers submit their information to gigats.com believing they are 

applying for, or that submitting their information is a necessary step in applying for, the 

position listed in the job post. 

Consumers Are Instructed to Call Defendants for an "lntenriew" 

21. Consumers who submit their information on gigats.com are instructed by 

Defendants to call for an "interview," sometimes immediately upon submitting their 

information on gigats.com. 

22. These consumers are instructed to do so by being shown a web page similar to 

the following: 

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Please Call an Employment Specialist 

• o corr;_ :Y 'IUU!' tt"J "t·1:.1~ "I ctnil ape , fJt the Te- ier POS 1,1 '\ ., J mv\1 f r .. 1 

"f':f~., Y.i1h a G} •s (IT o:o,me-rt S:::.?03-~ ~ tr"O'O)ir~t ~t-•.~sl 15 

cu1·E-•:.,ir ~torr<t .oyOUtai rxr,\' 

1-855-460-8663 

rtJ: er 

JPMn11an C:Mse 

It )CU fl'n un.i'l.blO :o ca r.int&Qa! )~fr Pase CJldr. ne-:-e to sct"i'90J:(I nn Ar.Nnulr 1 mu 

for your pre so~ "'"'"""v 

'~ I r: '•I ...C- '!-

23. This web page again lists the position and prospective employer to which the 

consumer believes he or she is applying and informs the consumer that ''To complete your 

registration and a pply for the [advertised I position, yo u must first interview with a 

Gigats Employment Specialist" (emphasis added). The consumer is then told to call a 

Gigats Employment Spec ialist at the number listed. 

24. If the consumer is unable to call the Gigats Employment Specialist at that 

moment. the consumer is urged to schedu le an alternate time. In the example above, 

consumers are urged to "schedule an alternate time for your pre-sc reening interview" 

(emphasis added). A pre-screening interview is a common practice of hiring employers that 

typically includes using a short phone intervi ew in order to whittle down th e number of job 

appli cants to a manageable number. 

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25. Defendants also have contacted consumers to schedule an "interview" via text 

messages. Defendants send texts to consumers who have submitted their information on 

gigats.com. The text references the purported job opening and urges the consumer to call to 

talk about it. For example, "Hi (consumer's name], you inquired about the (advertised] Job. 

Call me at [phone number] to talk about the next steps. (text STOP to cancel)." 

During the Purported Interview, Defendants Attempt to Sell Consumers on Education 

26. Many consumers, believing the telephone interview is the next step in the job 

application process, call the number provided by Defendants. Since at least 2012, some 

consumers calling for the purported interview have been connected to a live employee of 

Defendants, whom Defendants refer to as, among other names, Employment Specialists, Job 

Specialists, or Career Specialists (hereinafter, "Employment Specialist"). Employment 

Specialists are trained to follow a script provided by Defendants in their conversations with 

consumers (discussed further below). Failure to follow the script could result in disciplinary 

action being taken against the Employment Specialist. Defendants also train the 

Employment Specialists in ways to overcome consumers' objections and concerns, and 

provide the Employment Specialists with stock responses to questions raised by consumers. 

27. Beginning in 2013, some consumers calling Defendants for the purported 

interview alternatively have been connected to a computer program that Defendants have 

referred to as, among other names, the SaleMaker or SR program (hereinafter, the 

"SaleMaker program''). The SaleMaker program conducts the purported interview by using 

a pre-recorded script to mimic a call conducted by an Employment Specialist. Each call in 

which Defendants employ the SaleMaker program is monitored by a live representative of 

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Defendants. If a consumer makes a comment, asks a question, or raises a concern, the 

representative is able to select an appropriate response from a list of pre-recorded messages. 

The consumer then hears the pre-recorded response selected by Defendants' representative. 

28. Many consumers believe the purpose of the purported telephone interview is 

to apply for a job, and this is a belief that Defendants actively encourage. For example, 

Defendants have instructed their Employment Specialists to emphasize, at the beginning of 

the call, the position and prospective employer to which the consumer believes he or she is 

applying. An internal training document of Defendants explains that the "psychology" 

behind this is to cause the consumer to "immediately assume that the call is beneficial to his 

or her interest in the particular position ... .'' 

29. During the interview, the Employment Specialists or SaleMaker program ask 

the consumers to confirm the information they submitted on gigats.com, as well as basic 

questions about career history and goals. Defendants tell consumers that the purpose of 

these questions is to determine if the advertised position is a "good match" for the consumer, 

although Defendants have not been hired, engaged, or otherwise authorized by any 

prospective employer to screen or interview applicants for advertised positions. Defendants 

may use the information they gather to match the consumers with other job opportunities, but 

another purpose of these questions and the purported interview as a whole is to collect 

consumers' information to sell to educational and other institutions. 

30. Employment Specialists are trained, and the SaleMaker program is 

programmed, to ask consumers questions designed to segue the purported interview away 

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from employment and towards education. For example, the SaleMaker program asks 

consumers: 

• ''If you had the opportunity to continue your education in a way that 

did not interfere with your current job search or your family life and if 

you also found you qualified for financial aid to help with the cost of 

tuition, is there anything else that could stop you from going back or 

furthering your education if all of that were possible?" 

• .. What I'm asking is this, if you found employment and everything 

fell into place for you, you got a job and it didn't interfere with your 

work or your personal life, if you were given the opportunity to 

complete some education goals, I'd assume you'd want to do that 

within the next one to two months, right?" 

31. After answering the questions posed by the Employment Specialists or 

SaleMaker program, consumers typically are transferred to different employees of 

Defendants, whom Defendants have referred to as, among other names, "Education 

Advisors,'' ''Education Specialists,'' or "Academic Guides" (hereinafter, "Education 

Advisor"). 

32. Similar to the Employment Specialists, the Education Advisors are instructed 

to follow a script provided by Defendants and are trained to overcome common concerns or 

objections of consumers regarding enrolling in a post-secondary school or career training 

program. 

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33. During calls with consumers, Education Advisors represent that they are 

.. independent" advisors helping consumers find the "best" option for consumers to continue 

their education. After asking consumers questions about their education history and 

interests, the Education Advisors use the information to identify schools and programs to 

recommend to the consumer from among the schools that have agreed to pay Defendants a 

fee for the leads. 

34. Depending on the school, time of day, and availability of the consumer, 

Defendants' Education Advisors may directly transfer the consumer to the representative of a 

post-secondary school or career training program. Defendants refer to this as a .. warm 

transfer.·· 

35. Instead of a warm transfer, Education Advisors may send the consumer's 

contact and other information collected by Defendants to multiple schools or programs. 

Representatives of the schools or programs then contact the consumer directly at a later date 

or time. Defendants refer to this as a .. student matching profile." 

36. Defendants typically receive between $22 and $125 for each qualified lead 

sold. A qualified lead is one that meets the requirements set by the school or program for 

enrollment. 

Defendants Mislead Consumers About Their Purported Services 

37. In order to obtain consumers' information to sell as leads, Defendants 

misrepresent that by submitting their information on gigats.com or participating in the 

purported interview, consumers have applied or are applying for an open job position. 

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38. For example, the process alleged in Paragraphs 13-25 by which Defendants 

drive traffic to gigats.com and induce consumers to call Defendants for a purported interview 

mimics many consumers' experiences in applying for jobs online. Similarly, in order to 

induce consumers to set up the purported interview with an Employment Specialist, 

Defendants have represented to consumers: 

• To .. apply for the [advertised position], you must first interview with 

a Gigats Employment Specialist.'• (emphasis added); 

• ·'[Consumer name] we haven't heard from you. If you are still 

interested in the [advertised position) opening, call [phone number].'. 

39. In addition, Employment Specialists and the SaleMaker program, following 

the training and scripts provided by Defendants, continue to represent to consumers during 

the purported interview that the consumers have applied or are applying for the advertised 

job position. For example, Employment Specialists and the SaleMaker program have 

represented to consumers: 

• "I see you're calling about an open job position you applied for 

online." 

• "'My job is to ask you some questions to determine if the (advertised 

position] is a good match for you.'· 

• "I'm an Employment Specialist here. My job today is just to ask you 

a few questions to determine if the position you applied for is going to 

be a good match for you." 

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• ''Now I know that you were interested in the position you started 

applying for. Is that the ideal type of job that you want or do you feel 

like that's all you're really qualified for at this moment?" 

• .. I see here that you are interested in the [advertised position] with [the 

advertised employer], is that correct?" 

• ''Today I'm going to ask you some pre-screening questions and I'm 

also going to go ahead and send you out an email so you can finish up 

that application you started.'' 

40. Defendants have also provided the Employment Specialists or SaleMaker 

program with stock responses to "frequent" consumer questions. These stock responses 

likewise represent to consumers that they have applied for or are applying for the advertised 

job position. For example: 

• In response to the question, ''Do I have to speak to you before my 

application goes to the employer?", "Yes, my job is to ask you a few 

question to help determine if the [advertised position] is a good match 

for you." 

• In response to any "odd" question, "It's just a bit of an odd question. 

I'm just trying to do my job today and get you through the 

pre-screening. You are still looking for a job, right?" 

41. Contrary to Defendants' representations, by submitting their information on 

gigats.com or participating in the purported interview, consumers have not applied and are 

not applying for an open job position. Defendants do not transfer or otherwise pass along 

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consumers' applications, contact information, or even interest in a position to prospective 

employers. Indeed, in some cases, the purported job openings may no longer even exist. 

After the purported interview, Defendants send consumers an email containing a link to the 

prospective employer's actual job application site. However, some consumers who follow 

the link or otherwise contact the prospective employer directly report that the purported job 

opening did not exist, was already filled, or was outdated. 

42. Employment Specialists and the SaleMaker program, following the training 

and scripts provided by Defendants, also misrepresent to consumers during the purported 

interviews that the prospective employers have engaged Defendants to represent the 

employers in the hiring process by, among other things, screening potential applicants. For 

example, Employment Specialists and the SaleMaker program have represented to 

consumers: 

• "What we do at Gigats is we match job-seekers like you with open 

positions that different companies are looking to fill. Now those 

companies they actually pay us because we are able to save them time 

and money by sending them out only qualified candidates." 

• •'When you started your application online, it was through Gigats. 

We get paid by the employers to screen their applicants for them and 

only send out qualified candidates." 

• "The employers pay us because we save them time by screening 

applicants and only sending them candidates that we've qualified." 

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• "We are paid by employers to find qualified candidates for open 

positions." 

• "The reason why I ask you these questions is because the employers 

they just really want to get a good gauge on what your future goals 

are:· 

43. Contrary to Defendants' representations, Defendants have not been hired, 

engaged, or otherwise authorized by any prospective employer to solicit applicants, collect 

applications, screen applicants, or interview applicants for purported job openings. 

Defendants are not paid by the prospective employers; rather, their revenue comes primarily 

from selling consumers' contact information as leads to educational institutions and others. 

44. Defendants have also misled consumers about the role of their so-called 

Education Advisors. In keeping with the training and scripts provided by Defendants, the 

Education Advisors misrepresent that they are independent advisors who are helping 

consumers find the best program for their needs and interests. For example, Education 

Advisors have told consumers: 

• ··1 just want to make sure you know I'm an independent education 

advisor and that I do not work for any schools or enroll students." 

• ''I'm just really here to find the best options for you based on my 

understanding of your career goals and any concerns you might have." 

• "To find the best solution for you ... I would need to know how soon 

you would want to start the right program to meet your goals.'' 

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• .. In order to help you locate the very best program to meet your career 

goals, [Expand] does maintain a database of programs that are offered 

by thousands of colleges, universities, and trade schools in the United 

States." 

45. Contrary to their representations, Defendants' Education Advisors are not 

independent advisors searching for the best program to fit a consumer's needs and interests. 

Instead, Defendants' Education Advisors only recommend post-secondary schools or career 

training programs that have agreed (or their representatives or marketing partners have 

agreed) to pay Defendants for leads. 

VIOLATIONS OF THE FfC ACT 

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

acts or practices in or affecting commerce:' 

47. Misrepresentations or deceptive omissions of material fact constitute 

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

Count I 

48. In numerous instances in connection with generating leads to sell to 

educational or other institutions, Defendants have represented, directly or indirectly, 

expressly or by implication, that by submitting their information to Defendants or by 

participating in a purported interview, consumers have applied or are applying for an open 

job position. 

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49. Jn truth and in fact, consumers have not applied and are not applying for an 

open job position by submitting their information to Defendants or by participating in the 

purported interview. 

50. Therefore, Defendants' representation as set forth in Paragraph 48 of this 

Complaint are false and misleading and constitute deceptive acts or practices in violation of 

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

Count II 

51. In numerous instances in connection with generating leads to sell to 

educational or other institutions, Defendants have represented, directly or indirectly, 

expressly or by implication, that Defendants are acting on behalf of prospective employers 

hiring for open job positions. 

52. Jn truth and in fact, Defendants are not acting on behalf of prospective 

employers hiring for open job positions. 

53. Therefore, Defendants' representation as set forth in Paragraph 51 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 

54. Jn numerous instances in connection with generating leads to sell to 

educational or other institutions, Defendants have represented, directly or indirectly, 

expressly or by implication, that their employees are independent advisors searching for the 

best educational option for consumers. 

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55. In truth and in fact, Defendants' employees are not independent advisors 

searching for the best educational option for consumers. 

56. Therefore, Defendants' representation as set forth in Paragraph 54 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). 

CONSUMER INJURY 

57. 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 

58. 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. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Section I 3(b) of the FTC Act, 15 U.S.C. 

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

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A. Award PlaintifTsuch preliminary injunctive and ancillary reli ef as may be 

necessary to avert the likelihood of consumer injury during the pendency of this action and to 

preserve the possibility of effective fina l relief, including but not limited to, a preliminary 

injunctions; 

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

Defendants; 

C. Award such relief as the Court linds necessa ry lo redress injury to consumers 

resulting from Defendants' violations of the PTC Act, including but not limited to, rescission 

or reformation of contracts, restitution. the refund of monies paid, and the disgorgement of 

il l-gotten monies; and 

D. Award Pl ai ntiff 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: L//zl/ Zo {6 ' 

19 

Respectfully Submitted, 

DA YID C. SHONKA 

BRIA

Acting 

NS

Ge

. 

n

SHULL 

eral Counsel 

~ 

DANIEL DWYER 

Federa l Trade Commission 

600 Pennsylvania A venue NW 

Washington, DC 20850 

Telephone: 202-326-3720 (Shull) 

Telephone: 202-326-2957 (Dwyer) 

Facsimile: 202-326-3768 

Email: bshull@flc.gov, ddwyer@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION