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UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

In the Matter of

SKYMED INTERNATIONAL, INC., 

 also doing business as SkyMed Travel

 and Car Rental Pro,

 a Nevada corporation.

FILE NO. 1923140

AGREEMENT CONTAINING 

CONSENT ORDER

The Federal Trade Commission (“Commission”) has conducted an investigation of 

certain acts and practices of SkyMed International, Inc. (“Proposed Respondent”). The 

Commission’s Bureau of Consumer Protection (“BCP”) has prepared a draft of an administrative 

Complaint (“draft Complaint”). BCP and Proposed Respondent enter into this Agreement 

Containing Consent Order (“Consent Agreement”) to resolve the allegations in the attached draft 

Complaint through a proposed Decision and Order to present to the Commission, which is also 

attached and made a part of this Consent Agreement. 

IT IS HEREBY AGREED by and between Proposed Respondent and BCP, that:

1. The Proposed Respondent is SkyMed International, Inc., also doing business as 

SkyMed Travel and as Car Rental Pro, is a corporation with its principal office or place of 

business at 9089 E. Bahia Drive, Suite 100, Scottsdale, AZ 85260.

2. Proposed Respondent neither admits nor denies any of the allegations in the draft 

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

action, Proposed Respondent admits the facts necessary to establish jurisdiction.

3. Proposed Respondent waives:

a. Any further procedural steps;

b. The requirement that the Commission’s Decision contain a statement of 

findings of fact and conclusions of law; and

c. All rights to seek judicial review or otherwise to challenge or contest the 

validity of the Decision and Order issued pursuant to this Consent 

Agreement.

4. This Consent Agreement will not become part of the public record of the 

proceeding unless and until it is accepted by the Commission. If the Commission accepts this 

Consent Agreement, it, together with the draft Complaint, will be placed on the public record for 
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thirty (30) days and information about them publicly released. Acceptance does not constitute 

final approval, but it serves as the basis for further actions leading to final disposition of the 

matter. Thereafter, the Commission may either withdraw its acceptance of this Consent 

Agreement and so notify Proposed Respondent, in which event the Commission will take such 

action as it may consider appropriate, or issue and serve its Complaint (in such form as the 

circumstances may require) and decision in disposition of the proceeding, which may include an 

Order. See Section 2.34 of the Commission’s Rules, 16 C.F.R. § 2.34 (“Rule 2.34”).

5. If this agreement is accepted by the Commission, and if such acceptance is not 

subsequently withdrawn by the Commission pursuant to Rule 2.34, the Commission may, 

without further notice to Proposed Respondent: (1) issue its Complaint corresponding in form 

and substance with the attached draft Complaint and its Decision and Order; and (2) make 

information about them public. Proposed Respondent agrees that service of the Order may be 

effected by its publication on the Commission’s website (ftc.gov), at which time the Order will 

become final. See Rule 2.32(d). Proposed Respondent waives any rights it may have to any 

other manner of service. See Rule 4.4.

6. When final, the Decision and Order will have the same force and effect and may 

be altered, modified, or set aside in the same manner and within the same time provided by 

statute for other Commission orders.

7. The Complaint may be used in construing the terms of the Decision and Order. 

No agreement, understanding, representation, or interpretation not contained in the Decision and 

Order or in this Consent Agreement may be used to vary or contradict the terms of the Decision 

and Order.

8. Proposed Respondent agrees to comply with the terms of the proposed Decision 

and Order from the date that Proposed Respondent signs this Consent Agreement. Proposed 

Respondent understands that it may be liable for civil penalties and other relief for each violation 

of the Decision and Order after it becomes final.

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1923140

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman

Noah Joshua Phillips

Rohit Chopra

Rebecca Kelly Slaughter

Christine S. Wilson

In the Matter of

SKYMED INTERNATIONAL, INC., 

 also doing business as SkyMed Travel

 and Car Rental Pro,

 a Nevada corporation.

DECISION AND ORDER

DOCKET NO.

DECISION

The Federal Trade Commission (“Commission”) initiated an investigation of certain acts 

and practices of the Respondent named in the caption. The Commission’s Bureau of Consumer 

Protection (“BCP”) prepared and furnished to Respondent a draft Complaint. BCP proposed to 

present the draft Complaint to the Commission for its consideration. If issued by the 

Commission, the draft Complaint would charge the Respondent with violations of the Federal 

Trade Commission Act, 15 U.S.C. § 45(a)(1).

Respondent and BCP thereafter executed an Agreement Containing Consent Order 

(“Consent Agreement”). The Consent Agreement includes: (1) statements by Respondent that it 

neither admits nor denies any of the allegations in the draft Complaint, except as specifically 

stated in this Decision and Order, and that only for purposes of this action, it admits the facts 

necessary to establish jurisdiction; and (2) waivers and other provisions as required by the 

Commission’s Rules. 

The Commission considered the matter and determined that it had reason to believe that 

Respondent has violated the Federal Trade Commission Act, and that a Complaint should issue 

stating its charges in that respect. The Commission accepted the executed Consent Agreement 

and placed it on the public record for a period of thirty (30) days for the receipt and consideration 

of public comments. The Commission duly considered any comments received from interested 

persons pursuant to Section 2.34 of its Rules, 16 C.F.R. § 2.34. Now, in further conformity with 

the procedure prescribed in Rule 2.34, the Commission issues its Complaint, makes the 

following Findings, and issues the following Order:
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Findings

1. The Respondent is SkyMed International, Inc., also doing business as SkyMed Travel 

and as Car Rental Pro, a corporation with its principal office or place of business at 9089 

E. Bahia Drive, Suite 100, Scottsdale, AZ 85260.

2. The Commission has jurisdiction over the subject matter of this proceeding and over 

Respondent, and the proceeding is in the public interest.

ORDER

Definitions

For purposes of this Order, the following definitions apply:

1. “Affected Consumers” means all consumers that received an email from Respondent on

or around May 2, 2019 with the subject line, “IMPORTANT MESSAGE relative to 

SkyMed data exposure.”

2. “Covered Incident” means any instance in which (a) any United States federal, state, or 

local law or regulation requires Respondent to notify any U.S. federal, state, or local 

government entity that information collected or received, directly or indirectly, by 

Respondent from or about an individual consumer was, or is reasonably believed to have 

been, accessed or acquired without authorization; or (b) individually identifiable Health 

Information from or about an individual consumer was, or is reasonably believed to have 

been, accessed, acquired, or publicly exposed without authorization.

3. “Health Information” means information relating to the health of an individual consumer, 

including but not limited to medical history information, prescription information, 

hospitalization information, clinical laboratory testing information, health insurance 

information, or physician exam notes.

4. “Personal Information” means individually identifiable information from or about an 

individual consumer, including: (a) a first and last name; (b) a home or physical address, 

including street name and name of city or town; (c) an email address or other online 

contact information; (d) a mobile or other telephone number; (e) a date of birth; (f) a 

government-issued identification number, such as a driver’s license, military 

identification, passport, or Social Security number, or other personal identification 

number; (g) credit card or other financial account information; (h) Health Information; or 

(i) user account credentials, such as a login name and password.

5. “Respondent” means SkyMed International, Inc., its successors and assigns, and Global 

Emergency Travel Services, and its successors and assigns.
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Provisions

I. Prohibition Against Misrepresentations

IT IS ORDERED that Respondent; Respondent’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, in connection with any product 

or service, must not misrepresent in any manner, expressly or by implication:

A. The extent to which Respondent is a member of, adheres to, complies with, is certified 

by, is endorsed by, or otherwise participates in any privacy or security program 

sponsored by a government or any third party, including any self-regulatory or standardsetting organization;

B. The extent of any Covered Incident or unauthorized disclosure, misuse, loss, theft, 

alteration, destruction, or other compromise of Personal Information;

C. The extent of any investigation and the results thereof, whether conducted by 

Respondent, a governmental agency, or a third party, into any Covered Incident or 

unauthorized disclosure, misuse, loss, theft, alteration, destruction, or other compromise 

of Personal Information;

D. The extent to which Respondent collects, maintains, uses, discloses, deletes, or permits or 

denies access to any Personal Information; and

E. The extent to which Respondent otherwise protects the privacy, security, availability, 

confidentiality, or integrity of any Personal Information.

II. Required Notice to Consumers About Respondent’s Security Incident Response

IT IS FURTHER ORDERED that, within fourteen (14) days after the effective date of 

this Order, Respondent must directly notify all Affected Consumers by sending an email, 

consisting solely of an exact copy of the notice attached hereto as Exhibit A (“Notice”), with the 

subject line “Update: May 2019 Data Exposure.” Respondent shall not include with the Notice 

any other information, documents, or attachments.

III. Mandated Information Security Program

IT IS FURTHER ORDERED that Respondent, in connection with the collection, 

maintenance, use, disclosure, or provision of access to Personal Information, must, within thirty 

(30) days of issuance of this Order, establish and implement, and thereafter maintain, a 

comprehensive Information Security Program (“Information Security Program”) that protects the 

security, confidentiality, and integrity of Personal Information. To satisfy this requirement, 

Respondent must, at a minimum:
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A. Document in writing the content, implementation, and maintenance of the Information 

Security Program;

B. Provide the written program and any evaluations thereof or updates thereto to 

Respondent’s board of directors or governing body or, if no such board or equivalent 

governing body exists, to a senior officer of Respondent responsible for Respondent’s 

Information Security Program at least once every twelve (12) months and promptly (not 

to exceed thirty (30) days) after a Covered Incident;

C. Designate a qualified employee or employees to coordinate and be responsible for the 

Information Security Program;

D. Assess and document, at least once every twelve (12) months and promptly (not to 

exceed thirty (30) days) following a Covered Incident, internal and external risks to the 

security, confidentiality, or integrity of Personal Information that could result in the (1) 

unauthorized collection, maintenance, use, disclosure of, or provision of access to, 

Personal Information; or the (2) misuse, loss, theft, alteration, destruction, or other 

compromise of such information;

E. Design, implement, maintain, and document safeguards that control for the internal and 

external risks Respondent identifies to the security, confidentiality, or integrity of 

Personal Information identified in response to sub-Provision III.D. Each safeguard must

be based on the volume and sensitivity of the Personal Information that is at risk, and the 

likelihood that the risk could be realized and result in the (1) unauthorized collection, 

maintenance, use, disclosure of, or provision of access to, Personal Information; or the 

(2) misuse, loss, theft, alteration, destruction, or other compromise of such information. 

Such safeguards must also include:

1. Policies, procedures, and technical measures to systematically inventory Personal 

Information in Respondent’s control and delete Personal Information that is no longer 

necessary; 

2. Policies, procedures, and technical measures to log and monitor access to repositories 

of Personal Information in Respondent’s control;

3. Encryption of, at a minimum, all passport numbers, financial account information, 

and Health Information in Respondent’s control. 

4. Training of all of Respondent’s employees, at least once every twelve (12) months,

on how to safeguard Personal Information;

5. Technical measures to monitor all of Respondent’s networks, including all systems 

and assets within those networks, to identify data security events, including 

unauthorized attempts to exfiltrate Personal Information from those networks; and
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6. Data access controls for all repositories of Personal Information in Respondent’s

control, such as (a) restricting inbound connections to approved IP addresses, (b)

requiring authentication to access them, and (c) limiting employee access to what is 

needed to perform that employee’s job function.

F. Assess, at least once every twelve (12) months and promptly (not to exceed thirty (30) 

days) following a Covered Incident, the sufficiency of any safeguards in place to address 

the risks to the security, confidentiality, or integrity of Personal Information, and modify 

the Information Security Program based on the results;

G. Test and monitor the effectiveness of the safeguards in place at least once every twelve 

(12) months and promptly (not to exceed thirty (30) days) following a Covered Incident, 

and modify the Information Security Program based on the results. Such testing and 

monitoring must include: (1) vulnerability testing of Respondent’s network once every 

four (4) months and promptly (not to exceed thirty (30) days) after a Covered Incident,

and (2) periodic penetration testing of Respondent’s network and promptly (not to exceed 

thirty (30) days) after a Covered Incident;

H. Select and retain service providers capable of safeguarding Personal Information they 

access through or receive from Respondent, and contractually require service providers to 

implement and maintain safeguards for Personal Information; and 

I. Evaluate and adjust the Information Security Program in light of any changes to 

Respondent’s operations or business arrangements, a Covered Incident, or any other 

circumstances that Respondent knows or has reason to know may have an impact on the 

effectiveness of the Information Security Program. At a minimum, Respondent must 

evaluate the Information Security Program at least once every twelve (12) months and 

modify the Information Security Program based on the results.

IV. Information Security Assessments by a Third Party

IT IS FURTHER ORDERED that, in connection with compliance with Provision III of 

this Order, titled Mandated Information Security Program, Respondent must obtain initial and 

biennial assessments (“Assessments”):

A. The Assessments must be obtained from a qualified, objective, independent third-party 

professional (“Assessor”), who: (1) uses procedures and standards generally accepted in 

the profession; (2) conducts an independent review of the Information Security Program; 

and (3) retains all documents relevant to each Assessment for five (5) years after 

completion of such Assessment and will provide such documents to the Commission

within ten (10) days of receipt of a written request from a representative of the 

Commission. No documents may be withheld on the basis of a claim of confidentiality, 

proprietary or trade secrets, work product protection, attorney client privilege, statutory 

exemption, or any similar claim.
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B. For each Assessment, Respondent must provide the Associate Director for Enforcement 

for the Bureau of Consumer Protection at the Federal Trade Commission with the name,

affiliation, and qualifications of the proposed Assessor, who the Associate Director shall 

have the authority to approve in his sole discretion.

C. The reporting period for the Assessments must cover: (1) the first 180 days after the 

issuance date of the Order for the initial Assessment; and (2) each two-year period 

thereafter for twenty (20) years after issuance of the Order for the biennial Assessments.

D. Each Assessment must, for the entire assessment period:

1. determine whether Respondent has implemented and maintained the Information 

Security Program required by Provision III; 

2. assess the effectiveness of Respondent’s implementation and maintenance of subProvisions III.A-I;

3. identify any gaps or weaknesses in, or instances of material noncompliance with, the 

Information Security Program; 

4. address the status of gaps or weaknesses in, or instances of material non-compliance 

with, the Information Security Program that were identified in any prior Assessment 

required by this Order; and

5. identify specific evidence (including, but not limited to, documents reviewed, 

sampling and testing performed, and interviews conducted) examined to make such 

determinations, assessments, and identifications, and explain why the evidence that 

the Assessor examined is (a) appropriate for assessing an enterprise of Respondent’s 

size, complexity, and risk profile; and (b) sufficient to justify the Assessor’s findings. 

No finding of any Assessment shall rely solely on assertions or attestations by 

Respondent’s management. The Assessment must be signed by the Assessor, state 

that the Assessor conducted an independent review of the Information Security 

Program and did not rely solely on assertions or attestations by Respondent’s 

management, and state the number of hours that each member of the assessment team 

worked on the Assessment. To the extent Respondent revises, updates, or adds one or 

more safeguards required under Provision III in the middle of an Assessment period, 

the Assessment must assess the effectiveness of the revised, updated, or added 

safeguard(s) for the time period in which it was in effect, and provide a separate 

statement detailing the basis for each revised, updated, or additional safeguard. 

E. Each Assessment must be completed within sixty (60) days after the end of the reporting 

period to which the Assessment applies. Unless otherwise directed by a Commission 

representative in writing, Respondent must submit the initial Assessment to the 

Commission within ten (10) days after the Assessment has been completed via email to 

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

Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 
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600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin, 

“In re SkyMed International, FTC File No. 1923140.” All subsequent biennial 

Assessments must be retained by Respondent until the Order is terminated and provided 

to the Associate Director for Enforcement within ten (10) days of request.

V. Cooperation with Third-Party Information Security Assessor

IT IS FURTHER ORDERED that Respondent, whether acting directly or indirectly, in 

connection with any Assessment required by Provision IV must:

A. Provide or otherwise make available to the Assessor all information and material in its 

possession, custody, or control that is relevant to the Assessment for which there is no 

reasonable claim of privilege;

B. Provide or otherwise make available to the Assessor information about Respondent’s 

networks and all of Respondent’s IT assets so that the Assessor can determine the scope 

of the Assessment, and visibility to those portions of the networks and IT assets deemed 

in scope; and

C. Disclose all material facts to the Assessor, and not misrepresent in any manner, expressly 

or by implication, any fact material to the Assessor’s: (1) determination of whether 

Respondent has implemented and maintained the Information Security Program required 

by Provision III; (2) assessment of the effectiveness of the implementation and 

maintenance of sub-Provisions III.A-I; or (3) identification of any gaps or weaknesses in, 

or instances of material noncompliance with, the Information Security Program.

VI. Annual Certification

IT IS FURTHER ORDERED that Respondent must:

A. One year after the issuance date of this Order, and each year thereafter, provide the 

Commission with a certification from a senior corporate manager, or, if no such senior 

corporate manager exists, a senior officer of Respondent responsible for Respondent’s 

Information Security Program that: (1) Respondent has established, implemented, and 

maintained the requirements of this Order; (2) Respondent is not aware of any material 

noncompliance that has not been (a) corrected or (b) disclosed to the Commission; and 

(3) includes a brief description of all Covered Incidents that Respondent verified or 

confirmed during the certified period. The certification must be based on the personal 

knowledge of the senior corporate manager, senior officer, or subject matter experts upon 

whom the senior corporate manager or senior officer reasonably relies in making the 

certification.

B. Unless otherwise directed by a Commission representative in writing, submit all annual 

certifications to the Commission pursuant to this Order via email to DEbrief@ftc.gov or 

by overnight courier (not the U.S. Postal Service) to: Associate Director for

Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 600 
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Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin, “In re 

SkyMed International, FTC File No. 1923140.”

VII. Covered Incident Reports

IT IS FURTHER ORDERED that Respondent, within thirty (30) days after 

Respondent’s discovery of a Covered Incident, must submit a report to the Commission. The 

report must include, to the extent possible:

A. The date, estimated date, or estimated date range when the Covered Incident occurred;

B. A description of the facts relating to the Covered Incident, including the causes and scope 

of the Covered Incident, if known;

C. A description of each type of information that was affected or triggered any notification 

obligation to the U.S. federal, state, or local government entity;

D. The number of consumers whose information triggered any notification obligation to the 

U.S. federal, state, or local government entity;

E. The acts that Respondent has taken to date to remediate the Covered Incident and protect 

Personal Information from further exposure or access, and protect affected individuals 

from identity theft or other harm that may result from the Covered Incident; and

F. A representative copy of each materially different notice sent by Respondent to 

consumers or to any U.S. federal, state, or local government entity.

Unless otherwise directed by a Commission representative in writing, all Covered Incident 

reports to the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by 

overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau 

of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin, “In re SkyMed International, FTC File 

No. 1923140.”

VIII. Acknowledgments of the Order

IT IS FURTHER ORDERED that Respondent obtain acknowledgments of receipt of 

this Order:

A. Respondent, within ten (10) days after the effective date of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury.

B. For twenty (20) years after the issuance date of this Order, Respondent 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 
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related to the subject matter of the Order; and (3) any business entity resulting from any 

change in structure as set forth in Provision IX. Delivery must occur within ten (10) days 

after the effective date 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 Respondent delivered a copy of this Order, 

Respondent must obtain, within thirty (30) days, a signed and dated acknowledgment of 

receipt of this Order.

IX. Compliance Report and Notices

IT IS FURTHER ORDERED that Respondent make timely submissions to the Commission:

A. One year after the issuance date of this Order, Respondent must submit a compliance 

report, sworn under penalty of perjury, in which Respondent must: (1) 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 

Respondent; (2) identify all of Respondent’s businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; (3) describe the activities of 

each business, including the goods and services offered, what Personal Information is 

collected, and the means of advertising, marketing, and sales; (4) describe in detail 

whether and how Respondent is in compliance with each Provision of this Order, 

including a discussion of all of the changes that Respondent made to comply with the 

Order; and (5) provide a copy of each Acknowledgment of the Order obtained pursuant to 

this Order, unless previously submitted to the Commission.

B. Respondent must submit a compliance notice, sworn under penalty of perjury, within 

fourteen (14) days of any change in the following: (1) any designated point of contact; or 

(2) the structure of Respondent or any entity that Respondent 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. Respondent must submit notice of the filing of any bankruptcy petition, insolvency 

proceeding, or similar proceeding by or against Respondent within fourteen (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 
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overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue 

NW, Washington, DC 20580. The subject line must begin, “In re SkyMed International, 

FTC File No. 1923140.”

X. Recordkeeping

IT IS FURTHER ORDERED that Respondent must create certain records for twenty 

(20) years after the issuance date of the Order, and retain each such record for five (5) years, 

unless otherwise specified below. Specifically, Respondent must create and retain the following 

records:

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

incurred in generating those revenues, and resulting net profit or loss; 

B. Personnel records showing, for each person providing services in relation to any aspect of 

the Order, 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. Copies or records of all consumer complaints and refund requests, whether received 

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

D. A copy of each unique advertisement or other marketing material making a representation 

subject to this Order;

E. A copy of each widely disseminated representation by Respondent that describes the 

extent to which Respondent maintains or protects the privacy, security, availability, 

confidentiality, or integrity of any Personal Information, including any representation 

concerning a change in any website or other service controlled by Respondent that relates 

to privacy, security, availability, confidentiality, or integrity of Personal Information; 

F. For five (5) years after the date of preparation of each Assessment required by this Order, 

all materials and evidence that the Assessor considered, reviewed, relied upon or 

examined to prepare the Assessment, whether prepared by or on behalf of Respondent, 

including all plans, reports, studies, reviews, audits, audit trails, policies, training 

materials, and assessments, and any other materials concerning Respondent’s compliance 

with related Provisions of this Order, for the compliance period covered by such 

Assessment;

G. For five (5) years from the date received, copies of all subpoenas and other 

communications with law enforcement, if such communications relate to Respondent’s

compliance with this Order;
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H. For five (5) years from the date created or received, all records, whether prepared by or 

on behalf of Respondent, that tend to show any lack of compliance by Respondent with 

this Order; and

I. All records necessary to demonstrate full compliance with each Provision of this Order, 

including all submissions to the Commission.

XI. Compliance Monitoring

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

compliance with this Order:

A. Within ten (10) days of receipt of a written request from a representative of the 

Commission, Respondent must: submit additional compliance reports or other requested 

information, which must be sworn under penalty of perjury, and produce records for 

inspection and copying.

B. For matters concerning this Order, representatives of the Commission are authorized to 

communicate directly with Respondent. Respondent must permit representatives of the 

Commission to interview anyone affiliated with Respondent who has agreed to such an 

interview. The interviewee 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 Respondent or 

any individual or entity affiliated with Respondent, 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.

XII. Order Effective Dates

IT IS FURTHER ORDERED that this Order is final and effective upon the date of its 

publication on the Commission’s website (ftc.gov) as a final order. This Order will terminate 

twenty (20) years from the date of its issuance, (which date may be stated at the end of this 

Order, near the Commission’s seal), or twenty (20) years from the most recent date that the 

United States or the Commission files a complaint (with or without an accompanying settlement) 

in federal court alleging any violation of this Order, whichever comes later; provided, however, 

that the filing of such a complaint will not affect the duration of:

A. Any Provision in this Order that terminates in less than twenty (20) years;

B. This Order’s application to any Respondent that is not named as a defendant in such 

complaint; and

C. This Order if such complaint is filed after the Order has terminated pursuant to this 

Provision. 
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Provided, further, that if such complaint is dismissed or a federal court rules that the Respondent

did not violate any provision of the Order, and the dismissal or ruling is either not appealed or 

upheld on appeal, then the Order will terminate according to this Provision as though the 

complaint had never been filed, except that the Order will not terminate between the date such 

complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date 

such dismissal or ruling is upheld on appeal.

By the Commission.

April J. Tabor

Acting Secretary

SEAL:

ISSUED: