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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 11 e v &J6 I q w fp ·1 l s s 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

STRATEGIC STUDENT SOLUTIONS LLC, a 

limited liability company, STRATEGIC CREDIT 

SOLUTIONS LLC, a limited liability company, COMPLAINT FOR PERMANENT 

STRATEGIC DEBT SOLUTIONS LLC, a limited INJUNCTION AND OTHER 

liability company, STRATEGIC DOC PREP EQUITABLE RELIEF 

SOLUTIONS LLC, a limited liability company, 

STUDENT RELIEF CENTER LLC, a limited (FILED UNDER SEAL) 

liability company, CREDIT RELIEF CENTER 

LLC, a limited liability company, and 

DA VE GREEN, individually and as an officer of 

STRATEGIC STUDENT SOLUTIONS LLC, 

STRATEGIC CREDIT SOLUTIONS LLC, 

STRATEGIC DEBT SOLUTIONS LLC, 

STRATEGIC DOC PREP SOLUTIONS LLC, 

STUDENT RELIEF CENTER LLC, and CREDIT 

RELIEF CENTER LLC, 

Defendants, and 

DG INVESTMENT PROPERTIES LLC, 

Relief Defendant. 

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

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

Act ("FTC Act"), 15 U.S.C. § 53(b), the Telemarketing and Consumer Fraud and Abuse 

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Prevention Act ("Telemarketing Act"), 15 U.S.C. §§ 6101-6108, and Section 410(b) of the 

Credit Repair Organizations Act, 15 U.S.C. § 1679h(b), to obtain temporary, preliminary, and 

permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of 

monies paid, disgorgement of ill-gotten monies, and other equitable relief for Defendants' acts or 

practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), the FTC's 

Telemarketing Sales Rule ("TSR"), 16 C.F .R. Part 310, and the Credit Repair Organizations Act 

("CROA''), 15 U.S.C. §§ 1679-1679j, in connection with their deceptive marketing and sale of 

student loan debt relief and credit repair services. 

JURISDICTION AND VENUE 

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

and 1345, and 15 U.S.C. §§ 45(a), 53(b), 6102(c), and 1679h(b). 

3. Venue is proper in this district under 28 U.S.C. § 1391(b)(l), (b)(2), (c)(l), (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. The FTC also 

enforces the Telemarketing Act, 15 U.S.C. §§ 6101-6108. Pursuant to the Telemarketing Act, 

the FTC promulgated and enforces the TSR, 16 C.F.R. Part 310, which prohibits deceptive and 

abusive telemarketing acts or practices in or affecting commerce. The FTC also enforces the 

CROA, 15 U.S.C. §§ 1679-1679j, which prohibits unfair or deceptive advertising and business 

practices by credit repair organizations. 

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

attorneys, to enjoin violations of the FTC Act, the TSR, and the CROA, and to secure such 

equitable relief as may be appropriate in each case, including rescission or reformation of 

contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten monies. 

15 U.S.C. §§ 53(b), 56(a)(2)(A), 6102(c), and 1679h(b). 

DEFENDANTS 

6. Defendant Strategic Student Solutions LLC ("SSS") is a Florida limited liability 

company that has held itself out as doing business at 8461 Lake Worth Road, Suite 450, Lake 

Worth, Florida 33467; 8142 Banpo Bridge Way, Delray Beach, FL 33446; and 7260 W. Azure 

Drive #140, #2027, Las Vegas, NV 89130. SSS transacts or has transacted business in this 

district and throughout the United States. At all times material to this Complaint, acting alone or 

in concert with others, SSS has advertised, marketed, distributed, or sold student loan debt relief 

services and/or credit repair services to consumers throughout the United States. 

7. Defendant Strategic Credit Solutions LLC ("SCS") is a Florida limited liability 

company that has held itself out as doing business at 8461 Lake Worth Road, Suite 450, Lake 

Worth, Florida 33467; 8142 Banpo Bridge Way, Delray Beach, FL 33446; and 7260 W. Azure 

Drive #140, #2027, Las Vegas, NV 89130. SCS transacts or has transacted business in this 

district and throughout the United States. At all times material to this Complaint, acting alone or 

in concert with others, SCS has advertised, marketed, distributed, or sold student loan debt relief 

services and/or credit repair services to consumers throughout the United States. 

8. Defendant Strategic Debt Solutions LLC ("SOS") is a Florida limited liability 

company that has held itself out as doing business at 8461 Lake Worth Road, Suite 450, Lake 

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Worth, Florida 33467; 8142 Banpo Bridge Way, Delray Beach, FL 33446; 7260 W. Azure Drive 

#140, #2027, Las Vegas, FL [sic] 89130; and 1489 West Palmetto Park Road, Suites 467 and 

495, Boca Raton, FL 33486. SDS transacts or has transacted business in this district and 

throughout the United States. At all times material to this Complaint, acting alone or in concert 

with others, SDS has advertised, marketed, distributed, or sold debt relief services and/or credit 

repair services to consumers throughout the United States. 

9. Defendant Strategic Doc Prep Solutions LLC ("SDPS") is a Florida limited 

liability company that has held itself out as doing business at 8142 Banpo Bridge Way, Delray 

Beach, FL 33446 and 7260 W. Azure Drive #140, #2027, Las Vegas, NV 89130. SDPS 

transacts or has transacted business in this district and throughout the United States. At all times 

material to this Complaint, acting alone or in concert with others, SDPS has advertised, 

marketed, distributed, or sold student loan debt relief services and/or credit repair services to 

consumers throughout the United States. 

10. Defendant Student Relief Center LLC ("SRC") is a Wyoming limited liability 

company that has held itself out as doing business at 7260 W. Azure Drive, Suite 140-212, 

Las Vegas, NV 89130 and 1489 West Palmetto Park Road, Suite 467, Boca Raton, FL 33486. 

SRC transacts or has transacted business in this district and throughout the United States. At all 

times material to this Complaint, acting alone or in concert with others, SRC has advertised, 

marketed, distributed, or sold student loan debt relief services and/or credit repair services to 

consumers throughout the United States. 

11. Defendant Credit Relief Center ("CRC") is a Wyoming limited liability company 

that has held itself out as doing business at 7260 W. Azure Drive, Suite 140-212, Las Vegas, NV 

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89130. CRC transacts or has transacted business in this district and throughout the United 

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

advertised, marketed, distributed, or sold student loan debt relief services and/or credit repair 

services to consumers throughout the United States. 

12. Defendant Dave Green ("Green") is the President and sole manager of SSS, SCS, 

SOS, SOPS, and the Relief Defendant. Green registered and paid for the mail drop listed as the 

principal place of business in the corporate records of SRC and CRC. Green is the sole signatory 

on the bank accounts, and the responsible party for the websites, of all corporate defendants. 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 the acts and practices of SSS, 

SCS, SOS, SOPS, SRC, and CRC, including the acts and practices set forth in this Complaint. 

Defendant Green 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. 

13. Relief Defendant DG Investment Properties LLC ("DG Investment Properties") is 

a Florida limited liability company that has held itself out as doing business at 8142 Banpo 

Bridge Way, Delray Beach, FL 33446; 7260 W. Azure Drive #140, #2027, Las Vegas, NV 

89130; and 1489 West Palmetto Park Road, Suite 467, Boca Raton, FL 33486. It has received at 

least $450,000 in funds that can be traced directly to Defendants' deceptive acts or practices 

alleged below, and it has no legitimate claim to those funds. DG Investment Properties is owned 

by Green. 

14. Defendants SSS, SCS, SOS, SOPS, SRC, and CRC (collectively, "Corporate 

Defendants") have operated as a common enterprise while engaging in the deceptive acts and 

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practices and other violations of law alleged below. Defendants have conducted the business 

practices described below through an interrelated network of companies that have common 

ownership, officers, managers, business functions, employees, and office locations, and that have 

commingled funds. For example, since at least February of 2017, telemarketers have begun 

answering the phone number listed on the SSS website with the name SRC. Because these 

Corporate Defendants have operated as a common enterprise, each of them is jointly and 

severally liable for the acts and practices alleged below. Defendant Green has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of the 

Corporate Defendants that constitute the common enterprise. 

COMMERCE 

15. At all times material to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as "commerce" is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

DEFENDANTS' DECEPTIVE STUDENT LOAN DEBT RELIEF AND CREDIT REPAIR 

OPERATION 

16. Since at least 2014, Defendants have operated an unlawful debt relief enterprise 

that preys on consumers with student loan debt by falsely promising to reduce their student loan 

payments or eliminate a portion of their debt through enrollment in student loan forgiveness or 

income-driven repayment programs. Defendants also promise that consumers' monthly 

payments to Defendants will be applied to their student loans. In many instances, however, 

consumers have discovered that Defendants have failed to enroll them in any debt forgiveness or 

payment reduction programs and have otherwise failed to reduce their payments or eliminate 

their debt. Further, consumers later learn that none of their monthly payments have gone 

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towards paying off their debt. Indeed, in some instances, consumers have ended up owing more 

on their student loans than when they first signed up for Defendants' program. Defendants have 

also falsely promised many consumers that their loans would be forgiven in three years or less. 

And when consumers have sought to cancel their participation in Defendants' program, 

Defendants have falsely told consumers that if they do so, it will be very difficult or impossible 

to enroll in another forgiveness program. 

17. Defendants have also falsely represented that they provide credit repair services 

and improve consumers' credit scores. But in many instances, Defendants do not provide credit 

repair services and consumers' credit scores are not improved by Defendants. 

18. In exchange for the promised debt relief and credit repair services, Defendants 

have charged illegal upfront fees of as much as $1,200 and monthly fees, typically of$49.99. 

Background on Student Loan Forgiveness and Repayment Programs 

19. Student loan debt is the second largest class of consumer debt; more than 42 

million Americans collectively owe nearly $1.3 trillion. The student loan market continues to 

show elevated levels of distress relative to other types of consumer debt. 

20. To address this mounting level of distressed debt, the U.S. Department of 

Education (ED) and state government agencies administer a limited number of student loan 

forgiveness programs. Most consumers, however, do not qualify for these forgiveness programs 

because they have strict eligibility requirements, such as demonstrating a "total and permanent 

disability" (ED's "Total and Permanent Disability Discharge") or demonstrating that the 

borrower's school has closed while the borrower was still enrolled ("Closed School Loan 

Discharge"). Many forgiveness programs require working in certain professions for years, such 

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as ED's "Teacher Loan Forgiveness," which applies to teachers who have worked full-time for 

five years in a low-income elementary or secondary school or educational service agency. 

21. The federal government also offers potential student loan forgiveness as a benefit 

of income-driven repayment ("IDR") programs. Obtaining forgiveness through IDR programs 

requires a minimum of 20 or 25 years of payments. No loans have been forgiven yet under any 

of the IDR programs, many of which, such as the income-based repayment ("IBR") program, 

have only been available relatively recently. IDR programs allow eligible borrowers to choose 

to limit their monthly payments based on a percentage of their discretionary monthly income. If 

any balance remains after making payments for 20 or 25 years, that amount may be discharged. 

However, because most borrowers will realize increased income over the payment period, 

monthly payment amounts under IDR programs may eventually increase to fully amortizing 

payments that would pay off the loans prior to reaching eligibility for loan discharge. In those 

cases, the loans would not be forgiven. Further, any discharged debt will likely be considered as 

income for tax purposes, requiring tax payments on the amount discharged. 

22. Consumers can apply for forgiveness and IDR programs through their student 

loan servicers at no cost; these programs do not require the assistance of a third-party company 

or payment of fees. 

23. Consumers enrolled in IDR or forgiveness plans can typically leave their plans 

and reenroll in them at a later date. 

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Defendants' Deceptive Marketing of Student Loan Debt Relief Services 

24. Defendants have promised to enroll consumers in student loan forgiveness or 

other programs to reduce their student loan payments and balances. Defendants have made this 

claim in online advertising and on telemarketing calls. 

25. For example, one of Defendants' websites, www.strategicstudentsolution.com, 

prominently states the following: 

Student Loan Forgiveness Program For Qualified Graduates. 

Lower Your student Loan Payments Today! 

1 Payment Student Loan Debt Relief Option. 

26. The same website also offers: 

Payments as low as $0 Monthly 

One low monthly payment 

Save 60°/o or MORE on your monthly payment 

Free no obligation consultation and debt analysis 

Qualify for student loan forgiveness 

Benefit from government programs 

27. In some instances, consumers view the website or online advertising and call 

Defendants' telemarketers for more information. In other instances, Defendants make outbound 

telemarketing calls to consumers to off er their services and convince student loan borrowers to 

sign up with the company. 

28. Defendants' telemarketers have told consumers that Defendants would enroll 

them in student loan forgiveness programs or other programs to reduce their monthly payments 

or loan balances, and at the end of the programs, their student loans would be forgiven. 

Defendants have sometimes followed up their telemarketing calls with emails. For example, one 

of Defendants' follow up emails to a prospective customer stated that Defendants "will get you 

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preapproved for Federal Government Programs that will forgive or eliminate your Federal 

student loan .... we are a forgiveness program that will ensure forgiveness." 

29. Defendants have stated that their services require an initial fee, typically ranging 

from $599 to $1200, and that monthly payments, typically $49.99, would be applied toward 

consumers' loans. Defendants' telemarketers often told consumers that after they made monthly 

payments for three years, their loans would be forgiven. 

30. Contrary to Defendants' representations, consumers' monthly payments to 

Defendants are not applied to their student loans; rather, they are kept as fees for Defendants' 

services. Further, barring rare instances of disability or closed schools, there are no student loan 

forgiveness programs that provide forgiveness in three years or less. Defendants, therefore, 

generally could not have obtained loan forgiveness for consumers in this time frame. 

31. Defendants' telemarketers have typically collected consumers' payment 

information on the initial phone call. Defendants have withdrawn payments before they 

performed work on consumers' loan accounts. 

32. In many instances, Defendants' telemarketers have e-mailed consumers a link to a 

contract to sign electronically. Defendants' telemarketers have typically pressured consumers 

into quickly electronically signing the contract while the telemarketer is still on the phone. 

Defendants' telemarketers have assured consumers that the contract simply reiterates the offer 

for reduced payments and forgiveness. Indeed, the language on the very first page reinforces 

Defendants' earlier promises to provide debt relief. It typically states that consumers will 

receive "expert assistance" to "[ o ]btain a complete discharge of your student loan; if possible, 

obtain a refund of payments you have on your loan, if appropriate[;] [ n ]egotiate an acceptable 

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settlement with your lender, and or establish a comfortable payment plan that will meet your 

needs[.]" 

33. Buried in the contract that consumers are rushed through, which is typically 16 to 

20 pages, there is often a chart containing fee and payment information. In some instances, the 

chart lists "Monthly Maint. Fee, Yearly renewals & Credit repair Fees" of$49.99 and an "Est. 

Total new Monthly Payment" of either $0 or $49.99, creating the impression that either 

consumers' new student loan payment is $0, or that the $49.99 monthly payment is being applied 

to consumers' student loans as their "Total" monthly payment for Defendants' services and the 

student loans. Adding to the confusion, the contract typically states that the upfront "filing" fees 

are "NOT applied to clients Federal Student Loan balance," but it does not make the same 

statement about consumers' monthly payments. In some instances, the contract also contains 

incongruous disclaimers contradicting the sales pitch. They state, "I understand that Strategic 

Student Solutions will not be making monthly payments on my behalf' and "I understand that 

the fees paid to Strategic Student Solutions is [sic] for Document preparation and consultation 

services only and will not be applied to my student loan balance." ln the instances where these 

appear, they are on the very last page. 

34. In many instances, Defendants have instructed consumers not to contact, work 

with, make payments to, or respond to contacts from their loan servicers. Instead, Defendants' 

representatives have told consumers to send any paperwork or bills they received from their loan 

servicers to Defendants, and that Defendants would handle it. 

35. In many instances, Defendants have failed to obtain the promised lower monthly 

payments or student loan forgiveness. In many instances, consumers have discovered that 

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Defendants had not contacted their loan servicers at all. In other instances, Defendants have 

contacted consumers' loan servicers, but only to place consumers' loans into forbearance. This 

simply delayed consumers' discovery that their student loans were not being paid and that they 

had not been enrolled in a forgiveness or income-driven repayment program, while Defendants 

continued to collect fees. As a result, many consumers have fallen behind on their student loan 

payments or have had additional interest accrue. 

36. In some instances, when consumers have contacted Defendants to cancel their 

enrollment in Defendants' program, Defendants have falsely told consumers that they could 

suffer adverse consequences for future eligibility for federal loan forgiveness programs. In many 

instances, Defendants have refused or ignored requests for refunds by consumers. 

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Defendants' False Promises to Provide Credit Repair 

37. In many instances, Defendants have also made false promises that consumers' 

credit would be improved as a result of their program. 

38. One of Defendants' websites, www.StrategicCreditSolution.com, states: "We also 

offer a unique, legal and fast way to increase your FICO Score." 

39. Another of Defendants' websites,www.CreditReliefCenters.com, states: "We 

only hire professionals with the highest level of experience in the credit industry, specifically in 

Credit Repair areas. This allows us to fulfill our commitment of quality service and to overdeliver to our clients, every time, every case. For years, we have assisted thousands of 

consumers to not only repair or delete erroneous information from their credit reports, but also to 

rebuild their credit, providing legal alternatives to increase their FICO scores." 

40. In some instances, Defendants' telemarketers have also offered credit repair 

services to consumers on initial sales calls. Additionally, Defendants' contracts typically state 

that the consumers' monthly payments were for, among other things, "Credit repair Fees." 

41. Echoing Defendants' websites, Defendants' contracts with consumers typically 

promise credit repair services that would "improve client's FICO/credit scores and credit 

history." 

42. In many instances, Defendants have failed to provide credit repair services or 

improve consumers' credit scores and credit history. 

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Defendants' Additional Unlawful Practices Once Consumers Sign Up for Services 

43. Defendants have charged consumers initial and monthly fees for purported debt 

relief services before achieving any results, and, in many instances, have failed to achieve any 

results on behalf of the consumer. 

44. Defendants have also charged these advance fees before any credit repair services 

had been performed. Defendants' advance fees have typically been in the range of $599 to 

$1,200 for the initial fee, with a $49.99 recurring monthly fee, for as long as 36 months. 

THE FTC ACT 

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

or practices in or affecting commerce." 

46. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

VIOLATIONS OF THE FTC ACT 

Count I 

Deceptive Debt Relief Representations 

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

offering for sale, or sale of debt relief services, Defendants have represented, directly or 

indirectly, expressly or by implication that: 

a. Defendants generally will enroll consumers in student loan forgiveness or 

other programs that would lower their payments or balances; 

b. consumers' monthly payments to Defendants generally will be applied to pay 

off the consumers' loans; 

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c. consumers' student loan debt generally will be forgiven in three years or less 

after payment of initial fees; and 

d. if a consumer cancels his or her enrollment in a federal student loan 

forgiveness program, it is very difficult or impossible to re-enter another 

forgiveness program. 

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

representations set forth in Paragraph 4 7 of this Complaint, such representations were false or 

not substantiated at the time Defendants made them. 

49. Therefore, Defendants' representations as set forth in Paragraph 47 of this 

Complaint are false or 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 

Deceptive Credit Repair Representations 

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

offering for sale, or sale of credit repair services, Defendants have represented, directly or 

indirectly, expressly or by implication, that consumers' credit generally will be improved as a 

result of Defendants' program. 

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

representations set forth in Paragraph 50 of this Complaint, such representations were false or 

not substantiated at the time Defendants made them. 

52. Therefore, the making of the representations as set forth in Paragraph 50 of this 

Complaint constitutes a deceptive act or practice in violation of Section 5( a) of the FTC Act, 15 

U.S.C. § 45(a). 

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THE TELEMARKETING SALES RULE 

53. Congress directed the FTC to prescribe rules prohibiting abusive and deceptive 

telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101-6108. The 

FTC adopted the original TSR in 1995, extensively amended it in 2003, and amended certain 

provisions thereafter. 16 C.F.R. Part 310. 

54. Defendants are "seller[s]" or "telemarketer[s]" engaged in "telemarketing" as 

defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg). A "seller" means any person who, in 

connection with a telemarketing transaction, provides, offers to provide, or arranges for others to 

provide goods or services to a customer in exchange for consideration. 16 C.F.R. § 310.2(dd). 

A "telemarketer" means any person who, in connection with telemarketing, initiates or receives 

telephone calls to or from a customer or donor. 16 C.F.R. § 310.2(ff). "Telemarketing" means a 

plan, program, or campaign which is conducted to induce the purchase of goods or services or a 

charitable contribution, by use of one or more telephones and which involves more than one 

interstate telephone call. 16 C.F .R. § 310.2(gg). 

55. Defendants are sellers or telemarketers of "debt relief services" as defined by the 

TSR, 16 C.F .R. § 310.2( o ). Under the TSR, a "debt relief service" means any program or service 

represented, directly or by implication, to renegotiate, settle, or in any way alter the terms of 

payment or other terms of the debt between a person and one or more unsecured creditors, 

including, but not limited to, a reduction in the balance, interest rate, or fees owed by a person to 

an unsecured creditor or debt collector. 16 C.F.R. § 310.2( o ). 

56. The TSR prohibits sellers and telemarketers from requesting or receiving payment 

of any fees or consideration for any debt relief service until and unless: 

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a. The seller or telemarketer has renegotiated, settled, reduced, or otherwise 

altered the terms of at least one debt pursuant to a settlement agreement, debt 

management plan, or other such valid contractual agreement executed by the 

customer; and 

b. The customer has made at least one payment pursuant to that settlement 

agreement, debt management plan, or other valid contractual agreement 

between the customer and the creditor; and to the extent that debts enrolled in 

a service are renegotiated, settled, reduced, or otherwise altered individually, 

the fee or consideration either: 

i. Bears the same proportional relationship to the total fee for 

renegotiating, settling, reducing, or altering the terms of the entire debt 

balance as the individual debt amount bears to the entire debt amount. 

The individual debt amount and the entire debt amount are those owed 

at the time the debt was enrolled in the service; or 

ii. Is a percentage of the amount saved as a result of the renegotiation, 

settlement, reduction, or alteration. The percentage charged cannot 

change from one individual debt to another. The amount saved is the 

difference between the amount owed at the time the debt was enrolled 

in the service and the amount actually paid to satisfy the debt. 16 

C.F.R. § 310.4(a)(5)(i). 

57. The TSR prohibits sellers and telemarketers from misrepresenting directly or by 

implication, any material aspect of any debt relief service, including, but not limited to, the 

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amount of money or the percentage of the debt amount that a customer may save by using the 

service. 16 C.F.R. § 310.3(a)(2)(x). 

58. Pursuant to Section 3( c) of the Telemarketing Act, 15 U.S.C. § 6102( c ), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a). 

VIOLATIONS OF THE TELEMARKETING SALES RULE 

Count III 

Advance Fee for Debt Relief Services 

59. In numerous instances, in connection with the telemarketing of student loan debt 

relief services, Defendants have requested or received payment of a fee or consideration for debt 

relief services before: 

a. Defendants have renegotiated, settled, reduced, or otherwise altered the terms 

of at least one debt pursuant to a settlement agreement, debt management 

plan, or other such valid contractual agreement executed by the customer; and 

b. The customer has made at least one payment pursuant to that settlement 

agreement, debt management plan, or other valid contractual agreement 

between the customer and the creditor. 

60. Defendants' acts or practices, as described in Paragraph 59 of this Complaint, are 

abusive telemarketing acts or practices that violate Section 310.4(a)(5)(i) of the TSR, 16 C.F.R. § 

310.4(a)(5)(i). 

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Count IV 

Misrepresentations 

61. In numerous instances, in connection with the telemarketing of student loan debt 

relief services, Defendants have misrepresented, directly or indirectly, expressly or by 

implication, material aspects of their debt relief services, including, but not limited to 

a. consumers' monthly payments to Defendants generally will be applied to pay 

off the consumers' loans; 

b. Defendants generally will enroll consumers in student loan forgiveness or 

other programs that would lower their payments or balances; 

c. consumers' student loan debt generally will be forgiven after three years or 

less once consumers pay the initial fees for Defendants' services; and 

d. if a consumer cancels his or her enrollment in a federal student loan 

forgiveness program, it is very difficult or impossible to re-enter another 

forgiveness program. 

62. Defendants' acts and practices, as described in Paragraph 61 of this Complaint, 

are deceptive telemarketing acts or practices that violate Section 310.3( a)(2)(x) of the TSR, 16 

C.F.R. § 310.3(a)(2)(x). 

THE CREDIT REPAIR ORGANIZATIONS ACT 

63. The Credit Repair Organizations Act took effect on April 1, 1997, and has 

remained in full force and effect since that date. 

64. Defendants are "credit repair organizations," as defined by the Credit Repair 

Organizations Act: 

[A ]ny person who uses any instrumentality of interstate commerce or the mails to 

sell, provide, or perform (or represent that such person can or will sell, provide, or 

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perform) any service, in return for the payment of money or other valuable 

consideration, for the express or implied purpose of ... improving any 

consumer's credit record, credit history, or credit rating .... 

15 U.S.C. § 1679a(3). 

65. The purposes of the Credit Repair Organizations Act, according to Congress, are: 

(1) to ensure that prospective buyers of the services of credit repair 

organizations are provided with the information necessary to make an 

informed decision regarding the purchase of such services; and (2) to 

protect the public from unfair or deceptive advertising and business 

practices by credit repair organizations. 

15 u.s.c. § 1679(b). 

66. The Credit Repair Organizations Act prohibits all persons from making or using 

any untrue or misleading representation of the services of the credit repair organization. 15 

U.S.C. § 1679b(a)(3). 

67. The Credit Repair Organizations Act prohibits credit repair organizations from 

charging or receiving any money or other valuable consideration for the performance of any 

service that the credit repair organization has agreed to perform before such service is fully 

performed. 15 U.S.C. § 1679b(b). 

68. Pursuant to Section 410(b)(l) of the Credit Repair Organizations Act, 15 U.S.C. § 

l 679h(b )(I), any violation of any requirement or prohibition of the Credit Repair Organizations 

Act constitutes an unfair or deceptive act or practice in commerce in violation of Section 5(a) of 

the FTC Act, 15 U.S.C. § 45(a). Pursuant to Section 410(b)(2) of the Credit Repair 

Organizations Act, 15 U.S.C. § 1679h(b)(2), all functions and powers of the Commission under 

the FTC Act are available to the Commission to enforce compliance with the Credit Repair 

Organizations Act in the same manner as if the violation had been a violation of any Commission 

trade regulation rule. 

20 
Case 9:17-cv-80619-WPD Document 1 Entered on FLSD Docket 05/15/2017 Page 21 of 24 

VIOLATIONS OF THE CREDIT REPAIR ORGANIZATIONS ACT 

CountV 

Misleading Representations about Credit Repair Services 

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

offering for sale, or sale of services to consumers by a credit repair organization, as that term. is 

defined in Section 403(3) of the Credit Repair Organizations Act, 15 U.S.C. § 1679a(3), 

Defendants have made representations about their credit repair services, including, but not 

limited to, the representation that consumers' credit generally will be improved as a result of 

Defendants' program. These representations are untrue or misleading because consumers' credit 

generally is not improved as a result of Defendants' program. 

70. Defendants have thereby violated Section 404(a)(3) of the Credit Repair 

Organizations Act. 15 U.S.C. § 1679b(a)(3). 

Count VI 

Advance Fee for Credit Repair Services 

71. In numerous instances, in connection with the operation of a credit repair 

organization, as that term is defined in Section 403(3) of the Credit Repair Organizations Act, 15 

U.S.C. § 1679a(3), Defendants have charged or received money or other valuable consideration 

for the performance of credit repair services that Defendants have agreed to perform before such 

services were fully performed. 

72. Defendants have thereby violated Section 404(b) of the Credit Repair 

Organizations Act, 15 U.S.C. § 1679b(b). 

21 
Case 9:17-cv-80619-WPD Document 1 Entered on FLSD Docket 05/15/2017 Page 22 of 24 

Count VII 

Relief Defendant 

73. Relief Defendant, DG Investment Properties LLC, has received, directly or 

indirectly, funds or other assets from Defendants that are traceable to funds obtained from 

Defendants' customers through the deceptive acts or practices described herein. 

74. Relief Defendant is not a bona fide purchaser with legal and equitable title to 

Defendants' customers' funds or other assets, and Relief Defendant will be unjustly enriched if it 

is not required to disgorge the funds or the value of the benefit it received as a result of 

Defendants' deceptive acts or practices. 

75. By reason of the foregoing, Relief Defendant holds funds and assets in 

constructive trust for the benefit of Defendants' customers. 

CONSUMER INJURY 

76. Consumers have suffered and will continue to suffer substantial injury as a result 

of Defendants' violations of the FTC Act, the TSR, and the CROA. 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 

77. 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, 

22 
Case 9:17-cv-80619-WPD Document 1 Entered on FLSD Docket 05/15/2017 Page 23 of 24 

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. 

78. Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and Section 410(b) 

of the Credit Repair Organizations Act, 15 U.S.C. § 1679h(b), authorize this Court to grant such 

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

violations of the TSR and the Credit Repair Organizations Act, including the rescission or 

reformation of contracts, and the refund of money. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. §§ 53(b), 

Section 6(b) of the Telemarketing Act, 15 U.S.C. § 6105(b), and Section 410(b) of the Credit 

Repair Organizations Act, 15 U.S.C. § 1679h(b), and the Court's own equitable powers, requests 

that the Court: 

A. Award Plaintiff such preliminary injunctive and ancillary relief as may be 

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

preserve the possibility of effective final relief, including but not limited to a temporary and 

preliminary injunction, asset freeze, appointment of a receiver, an evidence preservation order, 

and expedited discovery. 

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

TSR, and the CROA by Defendants; 

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

resulting from Defendants' violations of the FTC Act, the TSR, and the CROA, including but not 

23 
Case 9:17-cv-80619-WPD Document 1 Entered on FLSD Docket 05/15/2017 Page 24 of 24 

limited to, rescission or reformation of contracts, restitution, the refund of monies paid, and the 

disgorgement of ill-gotten monies; 

D. Enter an order requiring Relief Defendant to disgorge all funds and assets, or the 

value of the benefit it received from the funds and assets, which are traceable to Defendants' 

deceptive acts or practices; and 

E. Award Plaintiff the costs of bringing this action, as well as such other and 

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

Respectfully submitted, 

DA YID C. SHONKA 

Acting General Counsel 

Dated: , 2/15/J. () / 7 tfat,,, d/l/. tJ~~~· MIYA TANDON 

(Florida Special Bar No. A5502005) 

ADAM M. WESOLOWSKI 

(Florida Special Bar No. A5502173) 

NIKHIL SINGHVI 

(Florida Special Bar No. A5502332) 

Federal Trade Commission 

600 Pennsylvania Ave., NW, CC-10232 

Washington, DC 20580 

(202) 326-2351 (Tandon) 

(202) 326-3068 (Wesolowski) 

(202) 326-3480 (Singhvi) 

mtandon@ftc.gov 

awesolowski@ftc.gov 

nsinghvi@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

24 
JS 44 (Rev. 07/16) FLSD Revised 07/01/2016 CIVIL COVER SHEET 

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September I 974, is required for the use of the Clerk of Court for the purpose 

of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below. 

I. (a) PLAINTIFFS Federal Trade Commission DEFENDANTS See Attachment 

(b) County of Residence of First Listed Plaintiff County of Residence ofFirst Listed Defendant Palm Beach County 

(EXCEPT IN US PLAINTIFF CASES) (JN US. PLAINTIFF CASES ONLY) 

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF 

THE TRACT OF LAND INVOLVED. 

( C) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known) 

See Attachment 

( d) Check County Where Action Arose: 0 MIAMI- DADE 0 MONROE D BROWARD .ti PALM BEACH D MARTIN D ST. LUCIE D INDIAN RIVER D OKEECHOBEE D HIGHLANDS 

II. BASIS OF JURISDICTION (Place an "X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" inOneBoxforPlaintiff) 

(For Diversity Cases Only) and One Box for Defendant) 

IZJ I U.S. Government Federal Question PTF DEF PTF DEF 

Plaintiff (US Government Not a Party) Citizen of This State D I DI Incorporated or Principal Place D 4 D 4 

of Business In This State 

D 2 U.S. Government 04 Diversity Citizen of Another State 02 D 2 Incorporated and Principal Place D 05 

Defendant (Indicate Citizenship of Parties in Item 111) of Business In Another State 

Citizen or Subject of a 03 D 3 Foreign Nation D 6 06 

Foreign Country 

D 110 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 D 375 False Claims Act 

D 120 Marine 0310Airplane D 365Personallnjury - ofProperty21 USC881 0423Withdrawal D 376 Qui Tam (31 use 

D 130 Miller Act D 315 Airplane Product Product Liability D 690 Other 28 USC 157 3729 (a)) 

D J 40 Negotiable Instrument Liability D 367 Health Care/ D 400 State Reapportionment 

D 150 Recovery of Overpayment 410 Antitrust D 320 ~~:=~~Libel & :~~=~~~~~ c;:~~~:::;t(t~V[§]; ;:, 8 & Enforcement of Judgment 430 Banks and Banking 

D 151 Medicare Act D 330 Federal Employers' Product Liability D 830 Patent [!!I 450 Commerce 

D 152 Recovery of Defaulted Liability D 368 Asbestos Personal D 840 Trademark D 460 Deportation 

Student Loans D 340 Marine Injury Product D 470 Racketeer Influenced and 

(Exel. Veterans) D 345 Marine Product Liability ffl:i~f%11!~)~i];fi:,," ~~:~. ~~~~~ Corrupt Organizations 

D 153 Recovery of Overpayment Liability PERSONAL PROPERTY ITi10 '?a:~ Lab~; s!;.;;J~<l~" '''"El 86TttiA ('395fft . ·•:::Who D 480 Consumer Credit 

of Veteran's Benefits D 350 Motor Vehicle D 370 Other Fraud Act D 862 Black Lung (923) D 490 Cable/Sat TV 

D 160 Stockholders' Suits D 355 Motor Vehicle D 371 Truth in Lending D 720 Labor/Mgmt. Relations D 863 DIWC/DIWW (405(g)) D 850 Securities/Commodities/ 

D 190 Other Contract Product Liability D 380 Other Personal D 740 Railway Labor Act D 864 SSID Title XVI Exchange 

D J 95 Contract Product Liability D 360 Other Personal Property Damage D 751 Family and Medical D 865 RSI (405(g)) D 890 Other Statutory Actions 

D 196 Franchise Injury D 385 Property Damage Leave Act D 891 Agricultural Acts 

D 362 Personal Injury - Product Liability D 790 Other Labor Litigation D 893 Environmental Matters 

Med Malpractice D 791 Empl. Ret. Inc. D 895 Freedom oflnformation 

)c\~]~\h-;';~~,~~~f!~vlll'.RiGHi$"t~:i;~)lJ'Ri~~~ c Security Act 't"f'.:-CJi'IID~'f~,Sul'rs~~ Act 

0 210 Land Condemnation D 440 Other Civil Rights Habeas Corpus: 0 870 Taxes (U.S. Plaintiff D 896 Arbitration 

D 220 Foreclosure D 441 Voting D 463 Alien Detainee or Defendant) D 899 Administrative Procedure 

D 26 230RentLease&Ejectment 0442Employment D ~~~te~~tions to Vacate D\!JJcJ~g-Third Party Act/RevieworAppealof 

D 240 Torts to Land D i~~=~dfrions Other: Agency Decision 

D 245 Tort Product Liability D 445 Amer. w/Disabilities - D 530 General D ~~tu~~nstitutionality of State 

0 290 All Other Real Property Employment 0 535 Death Penalty 

D 446 Amer. w/Disabilities - D 540 Mandamus & Other 

Other D 550 Civil Rights Actions 

D 448 Education D 555 Prison Condition 

560 Civil Detainee -

D Conditions of Confinement 

V. ORIGIN (Place an "X" in One Box Only) 

£l Transferred from Remanded from I Original D 2 Removed D 3 Re-filed D 4 Reinstated D D 6 Multidistrict 5 0 7 Appeal to 9 another district D 8 Multidistrict D Appellate Cowt Proceeding from State (See VI or Litigation District Judge Cowt below) Reopened (specify) Transfer 

from Magistrate ~it~~~~ 

Jud ent File 

VI. RELATED/ (See instructions): a) Re-filed Case oYES litNO b) Related Cases DYES ijf NO 

RE-FILED CASE(S) JUDGE: DOCKET NUMBER: 

Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity): 

VII. CAUSE OF ACTION See Attachment 

LENGTH OF TRIAL via 5 days estimated (for both sides to try entire case) 

VIII. REQUESTED IN D CHECK IF THIS IS A CLASS ACTION DEMAND $ See Attachment CHECK YES only if demanded in complaint: 

COMPLAINT: UNDER F.RC.P. 23 

JURY DEMAND: D Yes ~No 

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE 

°57i5/~0l7 ~RE;,r7;;::;c:A~ FOR OFFICE USE ONLY 

RECEIPT# AMOUNT IFP JUDGE MAG JUDGE 

Case 9:17-cv-80619-WPD Document 1-1 Entered on FLSD Docket 05/15/2017 Page 1 of 2 
Case 9:17-cv-80619-WPD Document 1-1 Entered on FLSD Docket 05/15/2017 Page 2 of 2 

Attachment to Civil Cover Sheet 

Section I - Parties 

Defendants: 

Strategic Student Solutions LLC 

Strategic Credit Solutions LLC 

Strategic Debt Solutions LLC 

Strategic Doc Prep Solutions LLC 

Student Relief Center LLC 

Credit Relief Center LLC 

Dave Green 

DG Investment Properties LLC (Relief Defendant) 

Attorneys for Plaintiff Federal Trade Commission: 

Miya Tandon 

Adam M. Wesolowski 

Nikhil Singhvi 

Federal Trade Commission 

600 Pennsylvania Ave., NW, CC-10232 

Washington, DC 20580 

(202) 326-2351 (Tandon) 

(202) 326-3068 (Wesolowski) 

(202) 326-3480 (Singhvi) 

Section VII - Cause of Action 

FTC Act, 15 U.S.C. § 53(b); Telemarketing Act, 15 U.S.C. §§ 6101-6108; Credit Repair 

Organizations Act, 15 U.S.C. § 1679h(b). Civil law enforcement proceeding concerning 

deceptive statements and unlawful advance fees regarding student loan modification services. 

Section VIII- Requested in Complaint 

Demand - TRO, Preliminary Injunction, Permanent Injunction, and Monetary Relief.