UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

V. 

WEALTHPRESS HOLDINGS LLC, a 

limited liability company; 

INVESTPUB LLC, a limited liability 

company; 

CON OR LYNCH, individually and as an 

officer ofWEALTHPRESS HOLDINGS 

LLC; and 

ROGER SCOTT, individually and as an 

officer ofWEALTHPRESS HOLDINGS 

LLC 

Defendants. 

Case No. 3:23-cv-00046 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION, 

MONETARY JUDGMENT, 

CIVIL PENALTY JUDGMENT, 

AND OTHER RELIEF 

Plaintiff, the Federal Trade Commission ("Commission" or "FTC"), filed its 

Complaint for Permanent Injunction, Monetary Relief, Civil Penalties, and Other 

Relief ("Complaint"), for a permanent injunction, monetary relief, civil penalties, 

and other relief in this matter, pursuant to Sections 5(m)(l)(A)-(B), 13(6), and 19 

of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 45(m)(l)(A)-(B), 

and 53(6), and 57b, Section 5 of the Restore Online Shoppers' Confidence Act 

("ROSCA"), 15 U,S.C, § 8404. The Commission and Defendants stipulate to the 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 1 of 27 PageID 86 
entry of this Stipulated Order for Pennanent Injunction, Monetary Judgment, Civil 

Penalty Judgment, and Other Relief ("Order") to resolve all matters in dispute in 

this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1 ...... __ T ___ h=1 .... · s__ C .... o....,u=1i .......... h=as...,J..,.· u=r-is ..... d-ic .... t.... io .... n ___ o_v....,e ..... r-th=i-s .... m=a-tt=e ........ r 

2. The Complaint charges that Defendants participated in deceptive and 

unfair acts or practices that violate Section 5 of the FTC Act, 15 U,S,C, § 45, and 

Section 4 of ROSCA, 15 U.S.C. § 8403, and that the Commission has previously 

determined to be unfair or deceptive in connection with the advertising, marketing, 

distribution, and selling of trade recommendation services and related goods and 

services to consumers throughout the United States. 

3. Defendants neither admit nor deny any of the allegations in the 

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

action, Defendants admit the facts necessary to establish jurisdiction. 

4. Defendants waive any claim that 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. 

5. Defendants and the Commission waive all rights to appeal or 

othe1wise challenge or contest the validity of this Order. 

2 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 2 of 27 PageID 87 
DEFINITIONS 

For the purpose of this Order, the following definitions apply: 

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" or "Charged" means any attempt to collect money or other 

consideration from a consumer, including causing Billing Infonnation to be 

submitted for payment, including against the consumer's credit card, debit card, 

bank account, telephone 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 adve1iisement, the disclosure 

must be presented simultaneously in both the visual and audible p01iions 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 

3 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 3 of 27 PageID 88 
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 

ordinaiy 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 

ordinaiy consumers and must appear in each language in which the 

representation that requires the 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 1nitigated by, or 

inconsistent with, anything else in the c01rununication. 

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. 

4 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 4 of 27 PageID 89 
D. "Defendants" means all of the Individual Defendants and the 

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

1. "Corporate Defendants" means WealthPress Holdings LLC, 

InvestPub LLC, and their successors and assigns. 

2. "Individual Defendants" means Conor Lynch and Roger 

Scott, individually, collectively, or in any combination. 

E. "Earnings Claim" means any representation to consumers, specific 

or general, about income, financial gains, percentage gains, profit, net profit, gross 

profit, or return on investment. Earnings Claims include, but are not limited to: (a) 

the details of specific profitable trades, whether actual or hypothetical; (b) 

references to quitting one's job, not having to work, or living off of income from 

trading; ( c) references to increased purchases or savings, including a home, cars, 

boats, vacations, or travel; ( d) claims that consumers will not lose money if they 

use a particular trading strategy; (e) claims that profits are likely, probable, or the 

"mathematical" result of applying a particular trading strategy; (t) any statements, 

claims, success stories, endorsements, or testimonials about the performance or 

profitability of representatives, endorsers, instructors or customers; and (g) any 

representation, even hypothetical, of how much money a consumer could or would 

earn. 

5 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 5 of 27 PageID 90 
ORDER 

I. PROHIBITION CONCERNING EARNINGS 

CLAIMS 

IT IS ORDERED that Defendants, Defendants' 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 

pennanently restrained and enjoined from making any Earnings Claims or assisting 

others in making any Earnings Claims, expressly or by implication, unless: 

A. The Earnings Claims are non-misleading; 

B. At the time the Earnings Claims are made, Defendants: 

1. have a reasonable basis for the claim; 

2. have in their possession written materials that substantiate 

the claimed earnings and that the claimed earnings are 

typical for consumers similarly situated to those to whom 

the claim is made; and 

3. make the written substantiation available upon request to the 

consumer, potential purchaser, and the FTC; and 

C. Any earnings of the Defendants that fo1m the basis for the Earnings 

Claims were achieved in compliance with the law. 

6 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 6 of 27 PageID 91 
II. PROHIBITION AGAINST MISREPRESENTATIONS 

REGARDING ALGORITHMS 

IT IS FURTHER ORDERED that Defendants, Defendants' 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 the adve1iising, marketing, promoting, offering for 

sale, or selling of any good or service, are permanently restrained and enjoined 

from misrepresenting or assisting others in misrepresenting, expressly or by 

implication: 

A. That any person is personally involved in selecting or approving trades 

that Defendants recommend; 

B. That any person personally discovered or developed an algorithm or 

strategy that is used to generate trades that Defendants recommend; 

C. That trades that Defendants recommend are more likely to be profitable 

because of any person's algorithms, expe1iise, inside knowledge, or 

personal involvement in selecting such trades; 

D. That any person hired one or more others to develop an algorithm or 

system used to generate trades, or any other aspect of the development 

process including the number, qualifications, or role, of the persons 

involved; or 

E. The amount spent by any person to develop an algorithm or system used 

7 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 7 of 27 PageID 92 
to generate trades. 

III. PROHIBITION AGAINST MISREPRESENTATIONS 

IT IS FURTHER ORDERED that Defendants, Defendants' 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 the adve1iising, marketing, promoting, offering for 

sale, or selling of any good or service, are permanently restrained and enjoined 

from misrepresenting or assisting others in misrepresenting, expressly or by 

implication: 

A. The description of the good or service; 

B. That any past perfonnance referenced in Defendants' advertising, 

marketing, promoting, offering for sale, or selling of any good or service 

is indicative of future results; 

C. That any testimonials Defendants use in the advertising, marketing, 

promoting, offering for sale, or selling of any good or service reflect the 

experience that consumers are likely to have using Defendants' products 

or services; 

D. That Defendants provide personalized investment advice; 

E. That purchasers or users of Defendants' products or services will or are 

likely to achieve substantial profits or earnings; 

8 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 8 of 27 PageID 93 
F. The risk, liquidity, earnings potential, or profitability of goods or services 

that are the subject of a sales offer; 

G. The level of experience required for consumers to effectively use 

Defendants' go°'j(~r services; rS!ifJ) 

H. The time or effort required for consumers to effectively use Defendants' 

goods or services; 

I. The amount of capital required for consumers to effectively use 

Defendants' goods or services; 

J. That any specific trade in the financial markets was actually made by 

Defendants or others; 

K. The role or involvement of any person in developing Defendants' goods 

or services or providing them to purchasers; 

L. The background, expertise, or other infonnation bearing on the skill or 

accomplishments of any person whose name or likeness is used in 

marketing Defendants' goods or services to prospective purchasers; 

M. Limitations of any kind on the number of goods or services Defendants 

will or may sell, or the price at which such goods or services are or will 

be offered; 

N. That purchase or use of Defendants' goods or services carries little or no 

risk; 

9 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 9 of 27 PageID 94 
0. The nature or extent of any back-testing or other testing, research, or 

analysis of a service or strategy; 

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

exchange policy for the good or service; 

Q. Any other fact mate1ial to consumers concerning any good or service, 

such as: the total costs; any material restrictions; limitations; or 

conditions; or any material aspect of its performance, efficacy, nature, or 

central characteristics. 

IV. JUDGMENT FOR MONETARY RELIEF 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of One Million Two Hundred Seventy-Two 

Thousand Three Hundred Fifty-Six Dollars and Twenty-Two Cents 

($1,272,356.22) is entered in favor of the Commission against WealthPress 

Holdings, LLC, Conor Lynch, and Roger Scott, jointly and severally, as monetary 

relief. 

B. WealthPress Holdings, LLC, Conor Lynch, and Roger Scott are 

ordered to pay to the Commission One Million Two Hundred Seventy-Two 

Thousand Three Hundred Fifty-Six Dollars and Twenty-Two Cents 

($1,272,356.22), which, as they stipulate, their undersigned counsel holds in 

escrow for no purpose other than payment to the Commission. Such payment must 

10 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 10 of 27 PageID 95 
be made within 7 days of entry of this Order by electronic fund transfer in 

accordance with instructions previously provided by a representative of the 

Commission. 

V. JUDGMENT FOR CIVIL PENALTY 

A. Judgment in the amount of Five Hundred Thousand Dollars 

($500,000) is entered in favor of the Commission against Defendant WealthPress 

Holdings, LLC as a civil penalty. 

B. Defendant WealthPress Holdings, LLC is ordered to pay the 

Commission Five Hundred Thousand Dollars ($500,000), which, as it stipulates, 

its undersigned counsel holds in escrow for no purpose other than payment to the 

Commission. Such payment must be made within 7 days of entry of this Order by 

electronic fund transfer in accordance with instructions previously provided by a 

representative of the Commission. 

VI. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

A. Defendants relinquish dominion and all legal and equitable right, title, 

and interest in all assets transferred pursuant to this Order and may not seek the 

return of any assets. 

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

fu1iher proof, in any subsequent civil litigation by or on behalf of the Commission, 

11 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 11 of 27 PageID 96 
including in a proceeding to enforce its rights to any payment or monetary 

judgment pursuant to this Order, such as a nondischargeability complaint in any 

bankruptcy case. 

C. The facts alleged in the 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. 

D. Defendants acknowledge that their Taxpayer Identification Numbers 

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

must submit 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. 

E. All money received by the Commission pursuant to Section IV.A of 

this Order may be deposited into a fund administered by the Commission or its 

designee to be used for consumer relief, such as 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 such redress is completed, the Commission may apply any 

remaining money for such related relief as it determines to be reasonably related to 

Defendants' practices alleged in the Complaint. Any money not used for relief is to 

be deposited to the U.S. Treasury as an additional civil penalty. Defendants have 

12 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 12 of 27 PageID 97 
no right to challenge any actions the Commission or its representatives may take 

pursuant to this Subsection. 

VII. CUSTOMERINFORMATION 

IT IS FURTHER ORDERED that Defendants, Defendants' officers, agents, 

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

any of them, who receive actual notice of this Order, are pe1manently restrained 

and enjoined from directly or indirectly failing to provide sufficient customer 

information to enable the Commission to efficiently administer consumer redress. 

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

to redress, Defendants must provide it, in the form prescribed by the Commission, 

within 14 days. 

VIII. NOTICE TO CUSTOMERS 

IT IS FURTHER ORDERED that, within 7 days of entry of this Order, 

Defendant W ealthPress Holdings, LLC, shall email notice in the form shown in 

Attachment A to all persons who purchased goods or services marketed or sold by 

WealthPress Holdings, LLC, of any type at any time between January 1, 2018, and 

the date of the entry of this Order with the subject line "What the FTC Settlement 

Means for W ealthPress Customers." Notices sent by email shall be sent from an 

email address that WealthPress Holdings, LLC, regularly uses for communicating 

with consumers and Defendants shall make commercially reasonable efforts to 

13 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 13 of 27 PageID 98 
leverage technologies to ensure the deliverability of emails (for example, but not 

limited to, SPF, DKIM, and use of sending IP addresses with known good 

reputations). Within 15 days of entry of this Order, Defendants shall mail the form 

shown in Attachment A via first-class mail, postage prepaid with address 

fo1warding requested, to the last known mailing address of any intended email 

recipient whose emailed message delivery fails. No infonnation other than that. 

contained in Attachment A shall be included in or added to the notice required by 

this Section, nor shall any other materials be transmitted with the notice. 

IX. COOPERATION 

IT IS FURTHER ORDERED that 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 occunences that are the subject of the 

Complaint. Defendants must provide truthful and complete information, evidence, 

and testimony. Individual Defendants must appear, and such 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 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. 

X. ORDER ACKNOWLEDGMENTS 

14 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 14 of 27 PageID 99 
IT IS FURTHER ORDERED that Defendants obtain acknowledgments of 

receipt of this Order: 

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

the Commission an acknowledgment of receipt of this Order swo1n under penalty 

of pe1jury. 

B. For 10 years after entry of this Order, each Individual Defendant for 

any business that such 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 Defendant delivered a copy 

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

acknowledgment of receipt of this Order. 

XI. COMPLIANCE REPORTING 

15 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 15 of 27 PageID 100 
IT IS FURTHER ORDERED that Defendants make timely submissions to 

the Commission: 

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

compliance report, sworn under penalty of perjury: 

1. Each 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 c01nmunicate with 

Defendant; (b) identify all of that 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 (which Individual Defendants must 

describe if they know or should know due to their own involvement); (d) 

describe in detail whether and how that 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 

16 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 16 of 27 PageID 101 
business for which such Defendant perfonns services whether as an 

employee or otherwise and any entity in which such Defendant has any 

ownership interest; and ( c) describe in detail such 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 Defendant must submit a 

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

in the following: 

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

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

entity that 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 

subsidiaiy, 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 such Defendant performs services whether as an employee or 

othe1wise and any entity in which such Defendant has any ownership 

17 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 17 of 27 PageID 102 
interest, and identify the name, physical address, and any Internet address of 

the business or entity. 

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

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

against such 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, 

ill~c'..-

DC 

NO

205

. '.:> 

_

2 

80. 

~-c." 

The 

-Y lo ~ 

~ 

subject line must begin: FTC v. WealthPress Holdings, Inc.(~ . 

XII. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 

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

18 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 18 of 27 PageID 103 
Specifically, Corporate Defendants and each Individual Defendant for any business 

that such Defendant, individually or collectively with any other Defendants, 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 othe1wise, that person's: name; addresses; telephone 

numbers; job title or position; dates of service; and (if applicable) the reason for 

tennination; 

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 

Defendants' compliance with this Order and any failure to transfer any assets as 

required by this Order: 

19 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 19 of 27 PageID 104 
A. Within 14 days of receipt of a written request from a representative of 

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

other requested information, which must be sw01n 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, .3.Q 

(including telephonic depositions), 31, 33, 34, 36, 45, and 69. 

B. For matters conce1ning this Order, the Commission is authorized to 

communicate directly with each Defendant. Defendant must pennit 

representatives of the Commission to interview any employee or other person 

affiliated with any 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 Defendants or any individual or entity affiliated with 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-l. 

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

consumer reporting agency must fmnish consumer reports concerning Individual 

20 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 20 of 27 PageID 105 
Defendants, pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U,S,C, 

§ 168 lb(a)(l ). 

XIV. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this 

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

SO ORDERED this _25~ y of Di\.fth , zoli ~ 

UNITED STATES DISTRICT JUDGE 

21 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 21 of 27 PageID 106 
SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION 

Andrew Hudson 

ahudson@ftc.gov I (202) 326-2213 

Ryan McAuliffe 

rmcauliffe@ftc.gov I (202) 326-3404 

Attorneys 

Federal Trade Commission 

600 Pennsylvania Ave NW 

Mailstop CC-5201 

Washington, DC 20580 

Fax: (202) 326-3395 

FOR DEFENDANTS: 

Ari N. Rothman, Esq. 

Venable LLP 

600 Massachusetts Ave. NW 

Washington, DC 2000 I 

(818) 925-6114 

anrothman@venable.com 

COUNSEL for WealthPress Holdings, LLC 

22 

Date: 

12/20/2022 

-------

Date: 10-25-2022 

---------

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 22 of 27 PageID 107 
I 

I 

I 

ri 

I 

ll 

I 

I ; 

Damon W.D. \Vright 

Gordon Rees Scully Mansukhani 

110 l King Street, Suite 520 

Alexandria, VA 22314 

(703) 973-8776 

dwright@grsm.com 

COUNSElfor Invest Pub, LLC 

Date: 

Date: ________ _ 

Karl S. Kroncnbcrger 

Kronenberger Rosenfeld, LLP 

150 Post Sti-eet, Ste 520 • 

San Francisco, CA 94108 

(415)955-115Ext.114 

karl@krinternctlaw.com 

COUNSEL.for Roger Scott and Conor Lynch 

DEFENDANTS: \VealthPress Holdings, LLC, Invest Pub, LLC, Roger Scott, 

and Conor Lynch 

Roger Scott, individually 

and as an officer of WcalthPress Holdings, LLC 

Date: 

Con or Lynch, individually ---------

and as an officer ofWealthPress Holdings, LLC 

23 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 23 of 27 PageID 108 
Date: I 0/26/2022 

Damon W.D. Wright 

Gordon Rees Scully Mansukhani 

1101 King Street, Suite 520 

Alexandria, VA 22314 

(703) 973-8776 

dwright@grsm.com 

COUNSEL/or Invest Pub, LLC 

Date: /0 - Zo/- 'Z z_ 

Karl S. Kronenberger 

Kronenberger Rosenfeld, LLP 

150 Post Street, Ste 520 

San Francisco, CA 94108 

(415) 955-115 Ext. 114 

karl@krintemetlaw.com 

COUNSEL/or Roger Scott and Conor Lynch 

DEFENDANTS: WealthPress Holdings, LLC, Invest Pub, LLC, Roger Scott, 

and Conor Lynch 

Date: -------- Roger Scott, individually 

and as an officer of WealthPress Holdings, LLC 

Conor Lynch ( t 24. 2022 lG:37 EDT) Date: _O_c_t_2_4_,_2_0_2_2 __ Conor Lynch, individually 

and as an officer ofWealthPress Holdings, LLC 

23 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 24 of 27 PageID 109 
Date: _l...::;_o__;:;-)_;_r,_ .... .£.1,;4A-i. ---

as an officer ofinvcst Pub, LLC 

24 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 25 of 27 PageID 110 
ATTACHMENT A W ncd tn e., F1 e, S. c-Hlo ~ "-+ fY\ w n s. -fuc- LJJ ffi I th Pre ':) s ( v ~ ~ c IS 

Subject: ealthPress Settlement of FTC Deception Cas 

Dear <Customer>: 

Because our records show you've been a customer of our company, we're writing to let you 

know that the Federal Trade Commission, the nation's consumer protection agency, has sued 

and reached a settlement with Wealth Press, Roger Scott, and others. 

What happened? 

The FTC sued us and said that our claims about how much people could earn using our 

programs were deceptive because we didn't have sufficient evidence that customers were 

likely to earn what we said they could. 

What we're doing in response 

To settle the lawsuit with the FTC 

• We won't make claims about earnings without written proof. If we make claims about 

how much people can earn, we must have written proof that a typical customer is likely 

to get that kind of result. It also means we can't use testimonials or example trades, like 

those we have featured in our webinars, that would lead you to believe those 

experiences are typical unless we have written proof that they are. 

• We won't make claims about the typical experience our customers have without 

written proof. That includes what you'd need to participate in our program, like the 

time commitment and the amount of money or experience required to be successful. 

What you should know about investment-related offers 

Before you pay for any investment-related service or any offer that includes claims about how 

much money you can make as a participant, we and the FTC encourage you to 

• Take your time. 

• Avoid high-pressure sales pitches that require you to act now or risk losing out. 

• Be skeptical about success stories and testimonials . 

• Do your research. Search online for the company's name plus words like "review," 

"scam," or "complaint." 

We are pleased with the settlement with the FTC and ~ committed 

Y1⁄4V~ 

to follow its requirements. 

~ 

We believe that ultimately it will result in a better customer experience for all of our 

subscribers. 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 26 of 27 PageID 111 
For more information about WealthPress's settlement with the FTC, visit [FTC URL]. 

Sincerely, 

[signature for WealthPress] 

WealthPress Holdings, LLC 

Case 3:23-cv-00046-MMH-LLL Document 12 Filed 03/28/23 Page 27 of 27 PageID 112