NOTE: CHANGES MADE BY THE COURT 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, Case No. 8:18-CV-01636-AG(DFMx) 

 

 Plaintiff, 

FINAL JUDGMENT AND ORDER 

v. FOR PERMANENT INJUNCTION

AND OTHER EQUITABLE 

APARTMENT HUNTERS, INC., et al. RELIEF AS TO ALL 

DEFENDANTS

 Defendants. 

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

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

No. 1), and moved for summary judgment on all counts against all Defendants 

(Docket No. 77). The Court granted summary judgment to the FTC (Docket No. 

91), and now issues this Final Judgment and Order for Permanent Injunction and 

Other Equitable Relief against Defendants. 

IT IS ORDERED: 

DEFINITIONS

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

A. “Corporate Defendants” means Apartment Hunters, Inc., also d/b/a 

WeTakeSection8.com, ApartmentHunterz.com, and FeaturedRentals.com; Real

Estate Data Solutions, Inc.; Rental Home Listings Inc.; UAB Apartment Hunters 

LT; and their successors and assigns. 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 2 of 8 Page ID #:2180 

B. “Defendants” means Corporate Defendants, Kevin Shayan, and 

Steven Shayan, individually, collectively, or in any combination. 

ORDER 

I. Ban on Marketing Rental Listings 

It is ordered that Defendants are permanently restrained and enjoined from

advertising, marketing, promoting, offering, selling, or assisting others in 

advertising, marketing, promoting, offering, or selling, subscriptions for or access 

to the listing of a dwelling for rent, including a single-family home, townhouse, 

apartment, or condominium unit. 

Provided, however, that this Order does not prohibit Defendants from listing 

properties that any Defendant owns for rent. 

II. Prohibition Against Misrepresentations 

It is further ordered that Defendants, Defendants’ officers, agents, 

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

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

in connection with advertising, marketing, promoting, offering, or selling of any 

good or service are permanently restrained and enjoined from misrepresenting, or 

assisting others in misrepresenting, expressly or by implication: the total cost; any 

material restriction, limitation, or condition; any material aspect of its performance, 

efficacy, nature, or central characteristics; the nature or terms of a refund or 

cancellation; or any other material fact.

III. Monetary Provisions 

It is further ordered that: 

A. Judgment in the amount of Six Million Thirty-Seven Thousand Six

Hundred Eighty-Six Dollars and Ninety-Nine Cents ($6,037,686.99) is entered in 

favor of the Commission against Defendants, jointly and severally, as equitable 

monetary relief. 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 3 of 8 Page ID #:2181 

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

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

for equitable relief, including consumer redress and any attendant expenses for the 

administration of any redress fund. If a representative of the Commission decides 

that direct redress to consumers is wholly or partially impracticable or money 

remains after redress is completed, the Commission may apply any remaining 

money for such other equitable relief (including consumer information remedies) 

as it determines to be reasonably related to Defendants’ practices alleged in the 

Complaint. Any money not used for such equitable relief is to be deposited to the 

U.S. Treasury as disgorgement. 

C. Defendants Taxpayer Identification Numbers (Social Security 

Numbers or Employer Identification Numbers), which were 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. 

IV. Order Acknowledgments 

It is further ordered that Defendants obtain acknowledgments of receipt of 

this Order: 

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

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

of perjury. 

B. For 20 years after entry of this Order, Kevin Shayan or Steven 

Shayan, for any business that he, individually or collectively with any other 

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

Corporate Defendants, must deliver a copy of this Order to: (1) all principals, 

officers, directors, and LLC managers and members; (2) all employees having 

managerial responsibilities related to approving the content of any Defendant’s 

website; 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 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 4 of 8 Page ID #:2182 

days of entry of this Order for current personnel. For all others, delivery must 

occur before they assume their responsibilities. 

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

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

acknowledgment of receipt of this Order. 

V. Compliance Reporting 

It is further ordered that Defendants make timely submissions to the 

Commission: 

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

compliance report, sworn under penalty of perjury. 

1. Each Defendant must: 

a) Identify the primary physical, postal, and email address 

and telephone number, as designated points of contact, 

which representatives of the Commission may use to 

communicate with that Defendant; 

b) Identify all of that Defendant’s businesses by all of their 

names, telephone numbers, and physical, postal, email, 

and Internet addresses; 

c) Describe the activities of each business, including the 

goods and services offered, the means of advertising, 

marketing, and sales, and the involvement of any other 

Defendant (which Kevin Shayan or Steven Shayan must 

describe if he knows or should know due to his own 

involvement); 

d) Identify all websites owned or operated, directly or 

indirectly, by that Defendant; 

e) Describe in detail whether and how that Defendant is in 

compliance with each Section of this Order; and 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 5 of 8 Page ID #:2183 

f) Provide a copy of each Order Acknowledgment obtained 

pursuant to this Order, unless previously submitted to the 

Commission. 

2. Additionally, Kevin Shayan and Steven Shayan must each: 

a) Identify all of his telephone numbers and all physical, 

postal, email and Internet addresses, including all 

residences; 

b) Identify all of his business activities, including any 

business for which he performs services whether as an 

employee or otherwise and any entity in which he has 

any ownership interest; and 

c) Describe in detail his involvement in each such business, 

including title, role, responsibilities, participation, 

authority, control, and any ownership. 

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

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

in the following: 

1. Each Defendant must report any change in: 

a) Any designated point of contact; or 

b) The structure of the Corporate Defendants or any entity 

that Defendant has any ownership interest in or controls 

directly or indirectly that may affect compliance 

obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any 

subsidiary, parent, or affiliate that engages in any acts or 

practices subject to this Order. 

2. Additionally, Kevin Shayan and Steven Shayan must each 

report any change in: 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 6 of 8 Page ID #:2184 

a) His name, including aliases or fictitious name, or 

residence address; or 

b) His title or role in any business activity, including any 

business for which he performs services whether as an 

employee or otherwise and any entity in which he has 

any ownership interest, and identify the name, physical 

address, and any Internet address of the business or 

entity. 

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

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

against him within 14 days of its filing. 

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

sworn under penalty of perjury must be true and accurate and comply with 28 

U.S.C. § 1746, such as by concluding: “I declare under penalty of perjury under 

the laws of the United States of America that the foregoing is true and correct. 

Executed on: _____” and supplying the date, signatory’s full name, title (if 

applicable), and signature. 

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

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

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

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The 

subject line must begin: FTC v. Apartment Hunters, Inc. 

VI. Recordkeeping 

It is further ordered that Defendants must create certain records for 20 

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

for any business that a Defendant, individually or collectively with any other 

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Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 7 of 8 Page ID #:2185 

Defendants, is a majority owner or controls directly or indirectly, that Defendant 

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. All records necessary to demonstrate full compliance with each 

provision of this Order, including all submissions to the Commission. 

VII. Compliance Monitoring 

It is further ordered that, for the purpose of monitoring Defendants’ 

compliance with this Order: 

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

the Commission, Defendants must: submit additional compliance reports or other 

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

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

is also authorized to obtain discovery, without further leave of court, using any of 

the procedures prescribed by Federal Rules of Civil Procedure 29, 30 (including 

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

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

communicate directly with each Defendant. Defendants must permit 

representatives of the Commission to interview any employee or other person 

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

interviewed may have counsel present. 

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

through its representatives as consumers, suppliers, or other individuals or entities, 

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

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H

* 

ONORABLE ANDREW J. GUILFORD 

UNITED STATES DISTRICT JUDGE 

Case 8:18-cv-01636-AG-DFM Document 95 Filed 12/06/19 Page 8 of 8 Page ID #:2186 

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. 

VIII. 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 6th day of December, 2019.

*THIS DOCUMENT IS SIGNED 

SUBJECT TO PREVIOUS COMMENTS 

OF THIS COURT. 

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