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STIPULATED ORDER FOR PERMANENT 

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ALDEN F. ABBOTT KARL S. KRONENBERGER 

General Counsel Bar No. 226112 

 LIANA CHEN 

ROBERTA DIANE TONELLI Bar No. 296965 

Cal. Bar No. 278738 Kronenberger Rosenfeld, LLP 

EMILY COPE BURTON 150 Post Street, Suite 520 

Cal. Bar No. 221127 San Francisco, CA 94108 

Federal Trade Commission karl@krinternetlaw.com 

901 Market Street, Suite 570 liana@krinternetlaw.com 

San Francisco, CA 94103 Tel: (415) 955-1155 Ext. 114 

rtonelli@ftc.gov; eburton@ftc.gov Fax: (415) 955-1158 

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

 Attorneys for Defendants 

Attorneys for Plaintiff AH MEDIA GROUP, LLC 

FEDERAL TRADE COMMISSION HENRY BLOCK, ALAN SCHILL 

 and ZANELO, LLC 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

AH MEDIA GROUP, LLC, HENRY 

BLOCK, ALAN SCHILL, and ZANELO, 

LLC 

Defendants. 

 Case No.: 19-cv-04022-JD 

Hon. James Donato 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AGAINST 

ALAN SCHILL AND ZANELO, LLC 

 Plaintiff, Federal Trade Commission (“Commission”), filed its Amended 

Complaint for Permanent Injunction and Other Equitable Relief in this matter, pursuant 

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to 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). The Commission and Defendants Zanelo, LLC, and 

Alan Schill, (collectively, “Stipulating Defendants”), stipulate to the entry of this 

Stipulated Order for Permanent Injunction and Monetary Judgment (“Order”) to resolve 

all matters in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

A. This Court has jurisdiction over this matter. 

B. The Amended Complaint charges that Defendants participated in deceptive 

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

Section 4 of the Restore Online Shoppers’ Confidence Act (“ROSCA”), 15 U.S.C. 

§ 8403, and Section 907(a) of the Electronic Fund Transfer Act (“EFTA”), 15 U.S.C. 

§ 1693e(a), and Section 1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b), in the 

marketing and sale online of skin care products and weight loss supplements. 

C. Stipulating Defendants neither admit nor deny any of the allegations in the 

Amended Complaint, except as specifically stated in this Order. Only for purposes of 

this action, the Stipulating Defendants admit the facts necessary to establish jurisdiction. 

D. Stipulating Defendants waive any claim they may have under the Equal 

Access to Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this action 

through the date of this Order, and agree to bear their own costs and attorney fees. 

E. Stipulating Defendants waive all rights to appeal or otherwise challenge or 

contest the validity of this Order. 

DEFINITIONS

 For purposes of this Order, the following definitions apply: 

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A. “Billing Information” means any data that enables any person to access a 

customer’s account, such as a credit card, checking, savings, share or similar account, 

utility bill, mortgage loan account, or debit card. 

B. “Charge,” “Charged,” or “Charging,” means any attempt to collect 

money or other consideration from a consumer, including but not limited to causing 

Billing Information to be submitted for payment, including against a consumer’s credit 

card, debit card, bank account, phone bill, or other account. 

C. “Clear(ly) and Conspicuous(ly)” means that a required disclosure is 

difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers, 

including in all of the following ways: 

1. In any communication that is solely visual or solely audible, the 

disclosure must be made through the same means through which the communication is 

presented. In any communication made through both visual and audible means, such as a 

television advertisement, the disclosure must be presented simultaneously in both the 

visual and audible portions of the communication even if the representation requiring the 

disclosure is made in only one means; 

2. A visual disclosure, by its size, contrast, location, the length of time it 

appears, and other characteristics, must stand out from any accompanying text or other 

visual elements so that it is easily noticed, read, and understood; 

3. An audible disclosure, including by telephone or streaming video, 

must be delivered in a volume, speed, and cadence sufficient for ordinary consumers to 

easily hear and understand it; 

4. In any communication using an interactive electronic medium, such as 

the Internet or software, the disclosure must be unavoidable; 

5. The disclosure must use diction and syntax understandable to ordinary 

consumers and must appear in each language in which the representation that requires the 

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disclosure appears; 

6. The disclosure must comply with these requirements in each medium 

through which it is received, including all electronic devices and face-to-face 

communications; 

7. The disclosure must not be contradicted or mitigated by, or 

inconsistent with, anything else in the communication; and 

8. When the representation or sales practice targets a specific audience, 

such as children, the elderly, or the terminally ill, “ordinary consumers” includes 

reasonable members of that group. 

D. “Corporate Defendant” means Zanelo, LLC by whatever other names it 

may be known, and its subsidiaries, affiliates, successors, and assigns, and any fictitious 

business entities or business names created or used by these entities. 

 E. “Individual Defendant” means Alan Schill and his officers, agents, 

employees, and attorneys. 

 F. “Negative Option Feature” means, in an offer or agreement to sell or 

provide any good or service, a provision under which the consumer’s silence or failure to 

take affirmative action to reject a good or service or to cancel the agreement is interpreted 

by the seller or provider as acceptance or continuing acceptance of the offer. 

 G. “Preauthorized Electronic Fund Transfer,” as defined by the Electronic 

Fund Transfer Act, 15 U.S.C. § 1693a(10), means an electronic fund transfer authorized 

in advance to recur at substantially regular intervals. 

 H. “Preliminary Injunction” means the Stipulated Preliminary Injunction as 

to Defendants entered on August 28, 2019 (Dkt. #52). 

 I. “Receiver” means Robb Evans & Associates LLC, appointed as Receiver 

pursuant to Section XIV of the Preliminary Injunction. 

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 J. “Receivership Entities” means the Corporate Defendant and its 

subsidiaries, affiliates, successors, and assigns, including but not limited to, Accolade 

Industries LLC; Aleja Vital Balance LLC; Alpha AMC Health LLC; Alpha Brudze LLC; 

Alpha JF Health LLC; Alpha Stout LLC; Angel Eyes Health LLC; Antidote Industries 

LLC; Artful Media LLC; Birdman Health Solutions LLC; BJB Health LLC; Byzantine 

Companies LLC; Cactus Enterprises LLC; CJC Well Being LLC; Cognizant LLC; 

Dreamy Dawn Products LLC; IkaIka Wellness LLC; Intricate Enterprises LLC; Jaded 

Excellence LLC; JR Comprehensive Solutions LLC; Kalani Health Solutions LLC; KLG 

Health LLC; La Puissance Health LLC; PERK Health LLC; Picco Power Solutions LLC; 

Ponts Capital LLC; RMD Health LLC; Sarah’s Remedies LLC; Sloan Simple Solutions 

LLC; SMG Investments LLC; SMK Solutions LLC; Spring Chicken Health LLC; Stebo 

Health Solutions LLC; Street Smart Restoratives LLC; Tremendous Totton LLC; and 

Wild Cosmo Enterprises LLC. 

K. “Stipulating Defendants” means the Individual Defendant and the 

Corporate Defendant, individually, collectively, or in any combination. 

ORDER 

I. BAN RELATING TO NEGATIVE OPTION FEATURES 

IT IS THEREFORE ORDERED that Stipulating Defendants, whether acting 

directly or through an intermediary, are permanently restrained and enjoined from 

promoting or offering for sale any good or service with a Negative Option Feature. 

II. PROHIBITED BUSINESS ACTIVITES 

IT IS FURTHER ORDERED that Stipulating Defendants, their officers, agents, 

employees, and attorneys, and all other persons in active concert or participation with any 

of them, who receive actual notice of this Order, whether acting directly or indirectly, in 

connection with promoting or offering for sale any good or service, are permanently 

restrained and enjoined from: 

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A. Misrepresenting or assisting others in misrepresenting, expressly or by 

implication, any fact material to consumers concerning any good or service, such as: 

1. Any cost to the consumer to purchase, receive, use, or return the 

initial good or service; 

2. That the consumer will not be Charged for any good or service; 

3. That a good or service is offered on a “free,” “sample,” “bonus,” 

“gift,” “no obligation,” “discounted” basis, or words of similar import, denoting or 

implying the absence of an obligation on the part of the recipient of the offer; 

4. That the consumer can obtain a good or service for a processing, 

service, shipping, handling, or administrative fee with no further obligation; 

5. The purpose(s) for which the consumer’s Billing Information will be 

used; 

6. The date by which the consumer will incur any obligation or be 

Charged; 

7. That a transaction has been authorized by the consumer; 

8. Any material aspect of the nature or terms of a refund, cancellation, 

exchange, or repurchase policy for the good or service; 

9. any material restrictions, limitations, or conditions to purchase, 

receive, or use any good or service; or 

10. any material aspect of the performance, efficacy, nature, or central 

characteristics of a good or service. 

B. Before a customer consents to pay for such good or service, failing to 

disclose, or assisting others in failing to disclose, in a Clear and Conspicuous manner, 

expressly or by implication, all material terms and conditions of any offer, including: 

 1. The total cost or price of the good or service; 

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 2. The amount, timing, and manner of all fees, Charges or other amounts 

that a consumer will be Charged or billed, including but not limited to the date of the 

Charge, and whether it will be a credit card or checking account Charge; and 

 3. The mechanism for consumers to stop a Charge. 

C. Before a customer consents to pay for such good or service, failing to 

disclose, or assisting others in failing to disclose, in a Clear and Conspicuous manner, 

expressly or by implication, all material terms and conditions of any refund and 

cancellation policy, such as: 

 1. The specific steps and means by which such requests must be 

submitted; 

 2. The customer service telephone number or numbers that a customer 

must call to cancel and return goods or services; 

 3. The email address, web address, or street address to which such 

requests must be directed; 

 4. Any mechanism that customers must use to return any goods or 

services, including any requirement for specific tracking methods or delivery 

confirmation for a package; 

 5. If there is any policy of not making refunds or cancellations, including 

any requirement that a product will not be accepted for return or refund unless it is 

unopened and in re-sellable condition, a statement regarding this policy; and 

 6. The duration of Corporate Defendant’s refund and cancellation policy, 

including the date that it begins to run. 

III. OBTAINING EXPRESS INFORMED CONSENT 

IT IS FURTHER ORDERED that Stipulating Defendants, their officers, agents, 

employees, and attorneys, and all other persons in active concert or participation with any 

of them, who receive actual notice of this Order, whether acting directly or indirectly, in 

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connection with promoting or offering for sale any good or service, are permanently 

restrained and enjoined from failing to obtain a consumer’s express informed consent by 

causing Billing Information to be submitted for payment, or collecting or attempting to 

collect payment for goods or services, without the consumer’s express verifiable 

authorization, which shall include: (a) the customer’s signature, including an electronic or 

digital form of signature that is recognized as a valid signature under federal law; or (b) 

express oral authorization that is audio-recorded and made available to the customer and 

the customer’s bank or other billing entity, and that evidences clearly both the customer’s 

authorization of payment and the customer’s receipt of the following information: (i) The 

number of debits, charges, or payments (if more than one); (ii) the date(s) the debit(s), 

charge(s), or payment(s) will be submitted for payment; (iii) the amounts of the debit(s), 

charge(s), or payment(s); (iv) the customer’s name; (v) the customer’s Billing 

Information identified with sufficient specificity such that the customer understands what 

account will be used to collect payment; (vi) identification of the seller’s name, physical 

address, and telephone number; and (vii) the date of the customer’s oral authorization. 

IV. PREAUTHORIZED ELECTRONIC FUND TRANSFERS

IT IS FURTHER ORDERED that Stipulating Defendants, their officers, agents, 

employees, and attorneys, and all other persons in active concert or participation with any 

of them, who receive actual notice of this Order, whether acting directly or indirectly, in 

connection with promoting or offering for sale any good or service, are permanently 

restrained and enjoined from: 

A. Failing to timely obtain written authorization signed or similarly 

authenticated by the consumer for any Preauthorized Electronic Fund Transfer from a 

consumer’s account before initiating any Preauthorized Electronic Fund Transfer; or 

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B. Failing to timely provide the consumer a copy of a valid written 

authorization signed or similarly authenticated by the consumer for any Preauthorized 

Electronic Fund Transfer. 

V. MONETARY JUDGMENT AND PARTIAL SUSPENSION

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of SEVENTY-FOUR MILLION, FIVE 

HUNDRED THOUSAND DOLLARS ($74,500,000) is entered in favor of the 

Commission against Stipulating Defendants, jointly and severally, as equitable monetary 

relief. The liability of Stipulating Defendants for the judgment shall be joint and several 

with any and all other Defendants named in the Complaint against whom the Court may 

enter judgment, jointly and severally, for equitable monetary relief. 

B. In partial satisfaction of this judgment, Stipulating Defendants shall, within 

10 business days from receipt of a copy of this Order, transfer to Receiver 415,973.437 

units of Chainlink cryptocurrency (“Cryptocurrency”), currently in the possession of Karl 

Kronenberger and identified in the affidavit of Alan Schill dated January 13, 2020. The 

Receiver shall hold the Cryptocurrency as a separate asset, and not as part of the 

receivership estate. Defendant Schill claims no ownership interest in the Cryptocurrency, 

which may be subject to potential claims by a third party. The Receiver and Individual 

Defendant Schill shall take all steps necessary to transfer the Cryptocurrency to a new 

account in the sole possession and control of the Receiver. The Receiver shall hold the 

Cryptocurrency until otherwise directed by court order. 

C. Upon transfer of the assets identified in this Section V, the remainder of this 

judgment as to Stipulating Defendants is suspended, subject to the Subsections below. 

D. The Commission’s agreement to the suspension of part of the judgment is 

expressly premised upon the truthfulness, accuracy, and completeness of Stipulating 

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Defendants’ sworn financial statements and related documents (collectively, “financial 

representations”) submitted to the Commission, namely: 

1. Alan Schill’s August 5, 2019 sworn Financial Statement of Individual 

Defendant, including attachments, as revised on August 16, 2019; 

2. Alan Schill’s August 5, 2019 Cryptocurrency Financial Statement; 

3. Affidavit of Alan Schill, dated January 13, 2020, including attachments; 

and 

4. Zanello, LLC’s August 23, 2019 sworn Corporate Financial Disclosure 

Form, including attachments. 

E. The suspension of the judgment will be lifted as to any Stipulating 

Defendant if, upon motion by the Commission, the Court finds that the Stipulating 

Defendant failed to disclose any material asset, materially misstated the value of any 

asset, or made any other material misstatement or omission in the financial 

representations identified above. 

F. If the suspension of the judgment is lifted, the judgment becomes 

immediately due as to that Stipulating Defendant in the amount specified in Subsection A 

above (which the parties stipulate only for purposes of this Section represents the 

consumer injury alleged in the Amended Complaint), less any payment previously made 

pursuant to this Section, plus interest computed from the date of entry of this Order. 

G. Stipulating Defendants relinquish dominion and all legal and equitable right, 

title, and interest in all assets, including the Cryptocurrency, transferred pursuant to this 

Order and all assets of the Receivership Entities and may not seek the return of any 

assets. 

H. The facts alleged in the Amended Complaint will be taken as true, without 

further proof, in any subsequent civil litigation by or on behalf of the Commission, 

including in a proceeding to enforce its rights to any payment or monetary judgment 

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pursuant to this Order, such as a nondischargeability complaint in any bankruptcy case. 

I. The facts alleged in the Amended Complaint establish all elements 

necessary to sustain an action by the Commission pursuant to Section 523(a)(2)(A) of the 

Bankruptcy Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel 

effect for such purposes. 

J. Stipulating Defendants acknowledge that their Taxpayer Identification 

Numbers (Social Security Numbers or Employer Identification Numbers), which 

Stipulating Defendants previously submitted to the Commission, may be used for 

collecting and reporting on any delinquent amount arising out of this Order, in 

accordance with 31 U.S.C. § 7701. 

K. All money paid to the Commission pursuant to this Order may be deposited 

into a fund administered by the Commission or its designee to be used for equitable 

relief, including consumer redress and any attendant expenses for the administration of 

any redress fund. If a representative of the Commission decides that direct redress to 

consumers is wholly or partially impracticable or money remains after redress is 

completed the Commission may apply any remaining money for such other equitable 

relief (including consumer information remedies) as it determines to be reasonably 

related to Defendants’ practices alleged in the Amended Complaint. Any money not used 

for such equitable relief is to be deposited to the U.S. Treasury as disgorgement. 

Stipulating Defendants have no right to challenge any actions the Commission or its 

representatives may take pursuant to this Subsection. 

VI. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Stipulating Defendants, their officers, agents, 

employees, and attorneys, and all other persons in active concert or participation with any 

of them, who receive actual notice of this Order, are permanently restrained and enjoined 

from directly or indirectly: 

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A. Failing to provide sufficient customer information to enable the Commission 

to efficiently administer consumer redress. Stipulating Defendants represent that they 

have provided all redress information in their possession or control to the Commission. 

If a representative of the Commission requests in writing any information related to 

redress, Stipulating Defendants must provide it, in the form prescribed by the 

Commission, within 14 days. 

B. Disclosing, using, or benefitting from customer information, including the 

name, address, telephone number, email address, social security number, other 

identifying information, or any data that enables access to a customer’s account 

(including a credit card, bank account, or other financial account), that any Defendant 

obtained prior to entry of this Order in connection online transactions promoting or 

offering for sale any good or service with a Negative Option Feature. 

C. Failing to destroy such customer information in all forms in their possession, 

custody, or control within 30 days after receipt of written direction to do so from a 

representative of the Commission. 

Provided, however, that customer information need not be disposed of, and may be 

disclosed, to the extent requested by a government agency or required by law, regulation, 

or court order. 

VII. COOPERATION 

IT IS FURTHER ORDERED that Stipulating Defendants must fully cooperate 

with representatives of the Commission in this case and in any investigation related to or 

associated with the transactions or the occurrences that are the subject of the Amended 

Complaint. Stipulating Defendants must provide truthful and complete information, 

evidence, and testimony. Individual Defendants must appear and Corporate Defendants 

must cause their officers, employees, representatives, or agents to appear for interviews, 

discovery, hearings, trials, and any other proceedings that a Commission representative 

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may reasonably request upon 5 days written notice, or other reasonable notice, at such 

places and times as a Commission representative may designate, without the service of a 

subpoena. 

VIII. CONTINUATION OF RECEIVER 

IT IS FURTHER ORDERED that the appointment of the Receiver over the 

Defendants pursuant to Section XIV of the Preliminary Injunction is hereby continued. 

A. Upon entry of this Order, the Receiver is authorized to liquidate all 

remaining receivership property as to the Receivership Entities. 

B. Upon resolution of this case with respect to all Defendants, the Receiver is 

authorized to dispose of all remaining files and records relating to Stipulating 

Defendants. 

C. Upon resolution of this case with respect to all Defendants, and after final 

payment to the Receiver of all approved fees, costs, and expenses, the Receiver shall turn 

over to the Commission or its designated agent all remaining assets of Stipulating 

Defendants in the receivership estate. 

D. The Receiver is directed to wind up the Receivership Entities and liquidate 

all assets of these entities within 90 days after entry of this Order, but any party or the 

Receiver may request that the Court extend the Receiver’s term for good cause. 

E. Upon completion of the above tasks, the duties of the receivership shall 

terminate. 

IX. DISSOLUTION OF ASSET FREEZE AS TO STIPULATING 

DEFENDANTS 

 IT IS FURTHER ORDERED that the freeze on assets of Stipulating Defendants 

imposed pursuant to the Temporary Restraining Order entered on July 18, 2019 (Dkt. 

#26) and the Preliminary Injunction entered on August 28, 2019 (Dkt. #52) is modified to 

permit the payments and other transfers identified in Section V above. Upon completion 

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of all payments and other obligations identified in Sections V and VIII above, the asset 

freeze is dissolved as to Stipulating Defendants. A financial institution shall be entitled 

to rely upon a letter from a representative of the Commission stating that the freeze on a 

Stipulating Defendant’s assets has been lifted. 

X. ORDER ACKNOWLEDGEMENTS 

 IT IS FURTHER ORDERED that Stipulating Defendants obtain 

acknowledgments of receipt of this Order: 

A. Each Stipulating Defendant, within 7 days of entry of this Order, must 

submit to the Commission an acknowledgment of receipt of this Order sworn under 

penalty of perjury. 

B. For 5 years after entry of this Order, the Individual Defendant for any 

business that such Individual Defendant, individually or collectively with any other 

Defendants, is the majority owner or controls directly or indirectly, and each Corporate 

Defendant, must deliver a copy of this Order to: (1) all principals, officers, directors, and 

LLC managers and members; (2) all employees having managerial responsibilities for 

conduct related to the subject matter of the Order and all agents and representatives who 

participate in conduct related to the subject matter of the Order; and (3) any business 

entity resulting from any change in structure as set forth in the Section titled Compliance 

Reporting. Delivery must occur within 7 days of entry of this Order for current 

personnel. For all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which a Stipulating Defendant delivered a 

copy of this Order, that Stipulating Defendant must obtain, within 30 days, a signed and 

dated acknowledgment of receipt of this Order. 

XI. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Stipulating Defendants make timely 

submissions to the Commission: 

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A. One year after entry of this Order, each Stipulating Defendant must submit a 

compliance report, sworn under penalty of perjury. 

1. Each Stipulating Defendant must: (a) identify the primary physical, 

postal, and email address and telephone number, as designated points of contact, which 

representatives of the Commission may use to communicate with Stipulating Defendant; 

(b) identify all of that Stipulating Defendant’s businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; (c) describe the activities of 

each business, including the goods and services offered, the means of advertising, 

marketing, and sales, and the involvement of any other Defendant in this matter (which 

each Individual Defendant must describe if he knows or should know due to his own 

involvement); (d) describe in detail whether and how that Stipulating Defendant is in 

compliance with each Section of this Order; and (e) provide a copy of each Order 

Acknowledgment obtained pursuant to this Order, unless previously submitted to the 

Commission. 

2. Additionally, each Individual Defendant must: (a) identify all 

telephone numbers and all physical, postal, email and Internet addresses, including all 

residences; (b) identify all business activities, including any business for which that 

Individual Defendant performs services whether as an employee or otherwise and any 

entity in which that Individual Defendant has any ownership interest; and (c) describe in 

detail the Individual Defendant’s involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership; 

B. For 20 years after entry of this Order, each Stipulating Defendant must 

submit a compliance notice, sworn under penalty of perjury, within 14 days of any 

change in the following: 

1. Each Stipulating Defendant must report any change in: (a) any 

designated point of contact; or (b) the structure of any Corporate Defendant or any entity 

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that Stipulating Defendant has any ownership interest in or controls directly or indirectly 

that may affect compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate that engages 

in any acts or practices subject to this Order. 

2. Additionally, each Individual Defendant must report any change in: 

(a) name, including aliases or fictitious name, or residence address; or (b) title or role in 

any business activity, including any business for which the Individual Defendant 

performs services, whether as an employee or otherwise, and any entity in which 

Individual Defendant has any ownership interest, and identify the name, physical address, 

and any Internet address of the business or entity. 

C. Each Stipulating Defendant must submit to the Commission notice of the 

filing of any bankruptcy petition, insolvency proceeding, or similar proceeding by or 

against such Stipulating Defendant within 14 days of its filing. 

D. Any submission to the Commission required by this Order to be sworn under 

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as 

by concluding: “I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. Executed on: ” and supplying 

the date, signatory’s full name, title (if applicable), and signature. 

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: Associate 

Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 

600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin: 

FTC v. AH Media Group, LLC, et al., FTC Matter No. X190034.

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XII. RECORDKEEPING 

IT IS FURTHER ORDERED that Stipulating Defendants must create certain 

records for 20 years after entry of the Order, and retain each such record for 5 years. 

Specifically, Stipulating Defendants for any business that such Stipulating Defendant, 

individually or collectively with any other Defendant in this matter, is a majority owner 

or controls directly or indirectly, must create and retain the following records: 

A. Accounting records showing the revenues from all goods or services sold; 

B. Personnel records showing, for each person providing services, whether as 

an employee or otherwise, that person’s: name; addresses; telephone numbers; job title or 

position; dates of service; and (if applicable) the reason for termination; 

C. Records of all consumer complaints and refund requests, whether received 

directly or indirectly, such as through a third party, and any response; 

D. All records necessary to demonstrate full compliance with each provision of 

this Order, including all submissions to the Commission; and 

E. A copy of each unique advertisement or other marketing material. 

XIII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Stipulating 

Defendants’ compliance with this Order, including the financial representations upon 

which part of the judgment was suspended and any failure to transfer assets as required 

by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission, each Stipulating Defendant must: submit additional compliance reports or 

other requested information, which must be sworn under penalty of perjury; appear for 

depositions; and produce documents for inspection and copying. The Commission is also 

authorized to obtain discovery, without further leave of court, using any of the procedures 

prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic depositions), 

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31, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission is authorized to

communicate directly with each Stipulating Defendant. Stipulating Defendants must 

permit representatives of the Commission to interview any employee or other person 

affiliated with any Stipulating Defendant who has agreed to such an interview. The 

person interviewed may have counsel present. 

C. The Commission may use all other lawful means, including posing, through

its representatives as consumers, suppliers, or other individuals or entities, to Stipulating 

Defendants or any individual or entity affiliated with Stipulating Defendants, without the 

necessity of identification or prior notice. Nothing in this Order limits the Commission’s 

lawful use of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 

U.S.C. §§ 49, 57b-1. 

D. Upon written request from a representative of the Commission, any

consumer reporting agency must furnish consumer reports concerning Individual 

Defendant Alan Schill, pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 

U.S.C. § 1681b(a)(1). 

XIV. RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retain jurisdiction of this matter for 

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

SO ORDERED this ____ day of ____________________, 2020. 

Honorable James Donato 

United States District Judge 

6th March

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

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A

IT IS SO ORDERED

Judge James Donato

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6 Date: ~11 I 2:D ToMi 

7 Emily Cope Burton 

8 Federal Trade Commission, Western Region 901 Market Street, Suite 570 

9 San Francisco, CA 94103 

10 (415) 848-5111 rtonelli@ftc.gov 

11 eburton@ftc.gov 

12 Attorneys for Plaintiff Federal Trade Commission 

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15 FOR STIPULATING DEFF."~t ' . . 

16 17 18 ];.t 11T~~ Date: I -3/ -z.o 19 Karl Kronenberger Liana Chen 

20 Kronenberger Rosenfeld, LLP 21 150 Pos_t Street, Ste 520 San Francisco, CA 94108 

22 karl@krintemetJaw.com 

23 liana@krintemetlaw.com (415) 955-1155 Ext. 114 

24 Attorneys for Defendants 

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Case 3:19-cv-04022-JD Document 111 Filed 03/06/20 Page 20 of 20

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4 Alan Schill, individually 

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Zanelo,Ll£W 

7 Alan Schill, Managing Member 

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