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UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

FEDERAL TRADE COMMISSION

 Plaintiff,

 v.

GEORGE JIRI STRNAD II, individually and also

d/b/a Abstract United, PayStubDirect.com, 

PaycheckStubOnline.com, and

iVerifyme.com,

 Defendant.

Case No. ____________

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY 

JUDGMENT

Plaintiff the Federal Trade Commission (“Commission”), filed its Complaint for 

Permanent Injunction and Other Equitable Relief, pursuant to Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b). The Commission and Defendant stipulate to 

the entry of this Stipulated Order for Permanent Injunction and Other Equitable Relief (“Order”) 

to resolve all matters in dispute in this action between them.

THEREFORE, IT IS ORDERED as follows:

FINDINGS

1. This Court has jurisdiction over this matter.

2. The Complaint charges that Defendant participated in unfair acts or practices in violation 

of Section 5 of the FTC Act, 15 U.S.C. § 45, in connection with the Defendant’s marketing and 

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sale of fake pay stubs, fake bank statements, fake tax forms, and a service for “verifying” fake 

employment information. 

3. Defendant neither admits nor denies any of the allegations in the Complaint, except as 

specifically stated in this Order. Only for purposes of this action, Defendant admits the facts 

necessary to establish jurisdiction. 

4. Defendant waives any claims that he 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 his own costs and attorney fees.

5. Defendant and the Commission waive all rights to appeal or otherwise challenge or 

contest the validity of this Order.

DEFINITIONS

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

A. “Defendant” means George Jiri Strnad II individually and also d/b/a Abstract United, 

PayStubDirect.com, PaycheckStubOnline.com, and iVerifyme.com.

B. “Fake Document” means any document, in paper or electronic form, that misrepresents 

any person’s identity, residency, finances, taxes, or employment, or otherwise misrepresents the 

document’s source, provenance, authenticity, or accuracy.

ORDER

I. PROHIBITION AGAINST FAKE DOCUMENTS

IT IS ORDERED that Defendant is permanently restrained and enjoined from 

advertising, marketing, promoting, or offering for sale, or assisting in the advertising, marketing, 

promoting, or offering for sale any Fake Document or any service, template, or mechanism for 

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creating any Fake Document.

II. PROHIBITION AGAINST PROVIDING THE MEANS AND 

INSTRUMENTALITIES TO DECEIVE CONSUMERS

IT IS FURTHER ORDERED that Defendant, Defendant’s 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, are permanently 

restrained and enjoined from providing to others the means and instrumentalities with which to 

make, expressly or by implication, any statement or representation of material fact that 

misrepresents: 

A. any person’s identity, residency, finances, taxes, or employment; or

B. the source, provenance, authenticity, or accuracy of any document related to identity, 

residency, finances, taxes, or employment.

III. MONETARY JUDGMENT

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of One Hundred Thirty-Three Thousand Seven Hundred 

Seventy-Seven Dollars ($133,777) is entered in favor of the Commission against Defendant as 

equitable monetary relief.

B. Defendant is ordered to pay to the Commission One Hundred Thirty-Three Thousand 

Seven Hundred Seventy-Seven Dollars ($133,777), which, as Defendant stipulates, his

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.

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IV. ADDITIONAL MONETARY PROVISIONS

IT IS FURTHER ORDERED that: 

A. Defendant relinquishes 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 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 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. Defendant acknowledges that his Taxpayer Identification Numbers (Social Security 

Numbers or Employer Identification Numbers), which Defendant 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.

E. 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 

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determines to be reasonably related to Defendant’s practices alleged in the Complaint. Any 

money not used for such equitable relief is to be deposited to the U.S. Treasury as disgorgement. 

Defendant has no right to challenge any actions the Commission or its representatives may take 

pursuant to this Subsection.

 V. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Defendant obtains acknowledgments of receipt of this 

Order:

A. 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, Defendant for any business that Defendant is the 

majority owner or controls directly or indirectly 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 Defendant delivered a copy of this Order, 

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this 

Order.

VI. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

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Commission:

A. One year after entry of this Order, Defendant must submit a compliance report, sworn 

under penalty of perjury. Defendant must:

1. identify all telephone numbers and all physical, postal, email and Internet addresses, 

including all residences;

2. identify all business activities, including any business for which Defendant performs 

services whether as an employee or otherwise and any entity in which such Defendant has any 

ownership interest;

3. describe in detail Defendant’s involvement in each such business, including title, role, 

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

4. 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 the Defendant;

5. identify all of Defendant’s businesses by all of their names, telephone numbers, and 

physical, postal, email, and Internet addresses;

6. describe the activities of each business, including the goods and services offered, the 

means of advertising, marketing, and sales;

7. describe in detail whether and how Defendant is in compliance with each Section of this 

Order; and

8. provide a copy of each Order Acknowledgment obtained pursuant to this Order, unless 

previously submitted to the Commission.

B. For 20 years after entry of this Order, Defendant must submit a compliance notice, sworn 

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under penalty of perjury, within 14 days of any change in the following: 

1. name, including aliases or fictitious name, or residence address;

2. title or role in any business activity, including any business for which Defendant performs 

services whether as an employee or otherwise and any entity in which Defendant has any 

ownership interest, and identify the name, physical address, and any Internet address of the 

business or entity;

3. any designated point of contact; or

4. the structure of 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 subsidiary, parent, or affiliate that engages in any 

acts or practices subject to this Order.

C. Defendant must submit to the Commission notice of the filing of any bankruptcy petition, 

insolvency proceeding, or similar proceeding by or against 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 N.W., Washington, 

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DC 20580. The subject line must begin: FTC v. George Jiri Strnad II, FTC Matter No.

1723152.

VII. RECORDKEEPING

IT IS FURTHER ORDERED that Defendant must create certain records for 20 years 

after entry of the Order, and retain each such record for 5 years. Specifically, Defendant for any 

business that Defendant 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; and

D. all records necessary to demonstrate full compliance with each provision of this Order, 

including all submissions to the Commission.

VIII. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant’s 

compliance with this Order and any failure to transfer any assets as required by this Order:

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

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 

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leave of court, using any of the procedures prescribed by Federal Rules of Civil Procedure 29, 30 

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

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

with Defendant. Defendant must permit representatives of the Commission to interview any 

employee or other person affiliated with 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 Defendant or any 

individual or entity affiliated with Defendant, 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 Defendant, pursuant to Section 604(1) of the 

Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(1).

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IX. 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 __ day of __________ :, 2018. 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

Katherine White, Attorney-in-Charge 

Virginia Bar Number 68779 

S.D. Texas (pendingpro hac vice) 

Email: kwhite@ftc.gov 

Elisa Jillson 

DC Bar Number 989763 

S.D. Texas (pending pro hac vice) 

Email: ejillson@ftc.gov 

James E. Elliott 

Texas Bar Number 06557100 

S.D. Texas #14 

Email: jelliott@ftc.gov 

UNITED STATES DISTRICT JUDGE 

Date: !l/til / J 8 

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Attorneys for Plaintiff 

Federal Trade Commission 

600 Pennsylvania Ave N.W. 

Washington, DC 20580 

(202) 326-2878 (Ms. White) 

(202) 326-3001 (Ms. Jillson) 

(214) 979-9373 (Mr. Elliott) 

(202) 326-3062 (Facsimile) 

FOR DEFENDANT: 

George' Jiri Strnad II, individually, and also d/b/a 

Abstract United, PayStubDirect.com, 

PaycheckStubOnline.com, and iVerifyme.com 

~ .. 

Michael Brandwein 

Andrew B. Gordon 

Gordon Law Group, Ltd. 

400 Central Ave, Suite 340 

Northfield, IL 60093 

Email: michaelb@gordonlawltd.com 

(84 7) 496-0846 (Brandwein) 

(847) 235-6095 (Gordon) 

Attorneys for Defendant George Jiri Strnad II, 

Individually, and also d/b/a Abstract United, 

PayStubDirect.com, PaycheckStubOnline.com, 

and iVerifyme.com 

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Date: 

Date: