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Michael E. Tankersley 

K. Michelle Grajales 

Federal Trade Commission 

600 Pennsylvania Avenue NW 

Washington, DC 20850 

Telephone: 202-326-2991 

Email: mtankersley@ftc.gov; mgrajales@ftc.gov

Attorneys for Plaintiff, Federal Trade Commission 

IN THE UNITED STATES DISTRICT COURT FOR 

THE DISTRICT OF ARIZONA 

Federal Trade Commission, 

 Plaintiff, 

 vs. 

Blue Global, LLC, and 

Christopher Kay, 

 Defendants. 

Case Number 

COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER

EQUITABLE RELIEF

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), to obtain permanent injunctive relief, 

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). 

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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) and 53(b). 

3. Venue is proper in this district under 28 U.S.C. § 1391(b) and (c) 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, among other, things, 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. 

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

own attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as 

may be appropriate, 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). 

DEFENDANTS 

6. Defendant Blue Global, LLC (“Blue Global”), is an Arizona limited 

liability company with its principal place of business at 17302 E. Helm Drive, Suite 2005 

in Scottsdale, Arizona. Blue Global did business under the name “Blue Global Media.” 

Blue Global transacted business in this district and throughout the United States. 

7. Defendant Christopher Kay is the founder and Chief Executive Officer of 

Blue Global. Until August 2013, Kay was also the President of Blue Global. At all times 

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material to this Complaint, acting alone or in concert with others, Kay formulated, 

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

of Blue Global, including the acts and practices set forth in this Complaint. Among other 

actions, Kay reviewed and approved the content of Blue Global websites, approved Blue 

Global’s sharing of loan applications with other entities, and set policies for the storage 

and security of consumer information. Through these activities, Kay had and has 

knowledge of the misrepresentations and practices for distributing loan applications, was 

recklessly indifferent to these misrepresentations and practices, or had awareness of a 

high probability of fraud along with intentional avoidance of the truth. Kay resided in 

this district until August 2016 and, in connection with the matters alleged herein, 

transacted business in this district and throughout the United States. 

COMMERCE 

8. At all times material to this Complaint, Defendants 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’ BUSINESS ACTIVITIES

9. Starting in at least 2009, Blue Global, under the direction of Christopher 

Kay, created and operated websites that urged consumers to complete online applications 

for loans. Blue Global was not a lender, but collected loan applications from consumers, 

electronically transmitted the applications to other entities, and sold the right to use the 

information as “leads.” Defendants induced consumers to supply the information in these 

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leads by representing that they would find consumers the loan with the lowest interest 

rate and other favorable terms; that they would match each consumer to a lender selected 

from a network of 100 or more loan providers; that applicants were very likely to receive 

a loan by completing the online application; and that the information that a consumer 

provided in the loan application was always safe and secure. In fact, Defendants shared 

loan applications with and sold them to other entities without regard to loan terms, 

whether the other entity was a lender, or whether the other entity secured the application 

data in any fashion. During 2013, 2014, and 2015, Defendants sold no more than two 

percent of the applications that they collected to loan providers. 

Defendants’ Solicitation of Consumer Loan Applications 

10. From December 2012 to January 2017, Defendants operated at least 38 

Internet domains that solicited loan applications, including 100dayloans.com, 1houradvance.com, 1hourdirect.com, 1hourlend.com, 1hourpersonalloan.com, 247loan.com, 

24sevenloan.com, 3clickloan.com, 3yearloans.com, 5kloans.com, 

5minuteloanapplication.com, 800900cash.com, autoloansusa.com, cashmojo.com, 

clickcashadvance.com, clickloans.net, clicknloan.com, eloanpersonal.com, fastadvance.com, fast-advance.net, faxfreecash.com, highspeedpayday.com, 

houradvance.com, littlepayday.com, loanmarketplace.com, magicinstallmentloans.com, 

money411.com, moneynowusa.com, moneytoday.com, moomoocash.com, 

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needcash.com, netloansearch.com, netloanusa.com, oneclickloan.com, onehourloan.com, 

rockstarloan.com, sevenminuteloans.com, and supersonicpayday.com. 

11. Defendants’ sites offered services to consumers seeking a variety of loans, 

including payday loans for hundreds of dollars, personal and installment loans for as 

much as $35,000, and auto loans. 

12. The information that Defendants collected through online loan applications 

included consumers’ names, addresses, email addresses, and phone numbers. They also 

collected personal and financial information, including birthdates, social security 

numbers, bank routing and account numbers, driver’s license and state identification 

numbers, whether and where the consumers were employed, the consumers’ incomes, 

whether the consumers were in the military, whether the consumers were home owners, 

whether the consumers had filed for bankruptcy, and the consumers’ approximate credit 

scores. 

13. Defendants encouraged consumers to become regular customers of their 

service by storing consumers’ loan application information and permitting consumers to 

retrieve entries from earlier applications to quickly create new loan applications. 

Defendants’ Sharing and Selling of Leads 

14. Defendants assembled each consumer’s loan application information and 

electronically transmitted that information—including sensitive personal and financial 

information—to potential buyers as a “lead.” 

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15. Defendants offered leads to potential buyers in a sequenced sales process 

referred to as a “ping tree.” Defendants transmitted the lead to the first potential buyer in 

the ping tree within seconds after the consumer submitted a loan application. If the 

potential buyer did not accept the lead, Defendants offered the lead to the next potential 

buyer in the ping tree sequence. This process was repeated until the lead was sold or 

until every participant in the ping tree had declined to purchase the lead after having 

viewed the information contained in the consumer’s loan application. To facilitate lead 

sales, Defendants operated multiple ping trees at a time. 

16. To receive leads through Defendants’ ping tree process, potential buyers 

agreed to pay Defendants for any accepted leads. Defendants did not require that ping 

tree participants be engaged in lending or use lead information to offer loans. Defendants 

received up to $200 for each lead sold. 

Defendants’ Representations to Consumers 

Representations about Matching Consumers to the

Lowest Interest Rate and Other Favorable Loan Terms 

17. To induce consumers to complete loan applications, Defendants published 

websites that assured consumers that they would use the information provided by each 

consumer to obtain loans with the lowest interest rate and other terms that were favorable 

to the consumer. These websites contained the following statements, among others: 

a. Start off by filling out our secure online loan application. After 

you've done that, an advanced search engine uses your 

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information to find the highest loan with the lowest interest rates. 

(sevenminuteloans.com/how it works).

b. Interest rates – We search for the lowest rate based on your 

loan request.

Our Personal Loan Search Engine will search though Personal 

Loan, Installment Loans, Cash Advance, and Payday Loan 

providers to find you the highest loan amount and the lowest 

interest rates you pre-qualify for. Interest Rates for our lenders 

range from 5% APR to 32% per month based on the credit history 

of the borrower, and many other underwriting factors at the lender 

level. (www.moneynowusa.com/about-us) 

c. NetLoanUSA is America’s LARGEST online personal loan 

network that connects you to financial loan lenders, 

nationwide for FREE! START NOW by completing our easy-touse online application, and once you HIT SUBMIT, we will go to 

work for you immediately, searching banks, financial companies 

and cash advance lenders, to find YOUR highest qualified loan 

amount at the lowest interest rate possible, in UNDER 90 

seconds! (netloanusa.com/home); and

d. Once you’ve submitted your application, we’ll match your 

information with our MoneyToday lender network to try to find you 

the best available loan. Our loan matching service will try to find 

the loan with the best interest rates, lowest finance charges and 

longest repayment period. (moneytoday.com/faq.php) 

18. Contrary to the representations, Defendants did not match consumers’ loan 

applications to buyers based on loan rates or terms. When Defendants made these 

representations, they had not gathered information about the cost, quality or terms of 

loans, if any, offered by their ping tree participants. 

19. Defendants also did not use information about whether potential buyers 

offered loans, or about the cost, quality, or terms of such loans, to determine who 

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participated in their ping trees, or to determine the order in which ping tree participants 

were offered loan applications. 

20. Instead, Defendants positioned participants in the ping tree to maximize 

Defendants’ revenue. Defendants sold exclusive rights to each loan application to the 

first potential buyer that accepted the lead — even if that buyer was not a loan provider 

or did not offer favorable loan terms. 

21. Further, if a buyer that received a loan application from Defendants 

marketed, remarketed, or otherwise shared the information with other entities, 

Defendants did not know whether these other entities were involved in arranging for 

consumers to obtain loans or were using the information for unrelated purposes. 

Representations about Defendants’ Lender Network 

22. To induce consumers to complete loan applications, Defendants published 

websites representing that they searched the loan offerings of 100 or more lenders to 

match consumers’ loan applications to lenders. These websites contained the statements 

set forth in Paragraph 17 and the following statements, among others: 

a. We’ll match your needs with our lender database of more than 

100 lending partners. (100dayloans.com/how_it_works.php); 

b. Sit back while we do the dirty work. We’ll match your needs with 

our lender network of more than 100 lending partners. 

(3YearLoans.com/How-it-Works);

c. Our innovative loan matching technology reviews your needs and 

searches our expansive lender network to match you with one of 

our premium lending partners. (oneclickloan.com/how it works); and

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d. Wait less than 90 seconds, while our database searches over 

120 cash loan providers to qualify you for the highest loan 

amount at the lowest interest rate possible. (netloanusa.com). 

23. Contrary to these representations, Defendants did not match consumers 

with one of 100 or more lending partners. Because of the manner in which Defendants 

operated their ping tree process, they presented some loan applications exclusively to 

non-lenders. Indeed, Defendants sometimes sold exclusive rights to the lead to a nonlender before it reached any lender in the ping tree. 

24. In fact, when Defendants made these representations, they had matched 

most of the loan applications that they sold to non-lenders, including to entities that used 

loan applications for purposes other than providing the consumer with a loan. 

Defendants were indifferent to how these buyers used the loan applications, including 

when buyers marketed applications to undisclosed entities for unknown purposes. 

25. Also contrary to these representations, Defendants did not search the loan 

offerings of 100 or more lenders. The number of lenders that participated in Defendants’ 

ping trees at any given time when Defendants made these representations never 

approached 100. For example, on October 13, 2015, no more than seventeen lenders 

considered loan applications from Defendants. 

Representations about Data Security 

26. To induce consumers to complete loan applications, Defendants published 

websites representing that their protocols ensured that consumers’ information was 

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always secure, including representing that the information was only available to “trusted 

lending partners.” These websites contained the following statements, among others: 

a. Your personal information is completely safe and secure: we use 

industry-leading online technology to keep your information 

encrypted and only available to our trusted lending partners. Your 

privacy and online safety is of the utmost importance. 

(moneytoday.com/faq.php; money411.com/faq.php)

b. Our protocols make certain that your personal information is 

completely protected 24/7 GUARANTEED! (netloanusa.com/home)

c. Getting a loan online requires the utmost security, privacy and 

online protection. At RockstarLoan.com, we make all three our 

top priorities by using industry-leading security protocols and 

technology. Our SSL encryption services make sure that your 

personal information is always safe, always secure. 

(rockstarloan.com/home)

d. We understand that handing over this type of sensitive 

information online can be unsettling, which is why we provide the 

best security possible. The Thawte technology and HTTPS 

protocols we use are some of the Internet’s most secure ways to 

protect information. It’s our number one priority to make sure any 

information you pass along remains in good hands. 

(sevenminuteloans.com)

e. If we find a lender willing to meet your loan needs, you'll be 

redirected to your lender's site. Your encrypted information will 

pass to the lender, and we never store the information, so your 

online identity is always safe. (100dayloans.com/faq.php)

27. Separately on these websites, Defendants have posted a “Privacy Policy” 

that states: “We have implemented and maintain reasonable security procedures and 

practices to protect against the unauthorized access, use, modification, destruction or 

disclosure of your Personal Information.”

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28. Contrary to Defendants’ representations, they transmitted, passed, or 

otherwise made consumers’ loan application information available to entities other than 

“trusted lending partners.” Indeed, Defendants shared consumers’ complete, unredacted 

loan information with entities that were not engaged in lending, and whose business, use 

of the leads, and practices for securing sensitive information, were not known to 

Defendants. 

29. Defendants did not impose any restrictions or conditions to protect against 

the unauthorized access, use, modification, destruction, or disclosure of consumers’ 

sensitive personal and financial information when it was placed in the possession of 

potential buyers or in the possession of entities that received it from Defendants’ 

potential buyers. 

Representations about Application Approvals 

30. To induce consumers to complete loan applications, Defendants published 

websites representing that most consumers would be approved for a loan. These websites

contained the following statements: 

a. Step 2: Get Approved, Sign Your Loan 

With four out of every five applications approved, you have an 

excellent chance of qualifying for a loan – regardless of your credit 

history! Once you’re approved, an electronic signature is all it takes 

to complete the loan process. It’s really that easy. 

(eloanpersonal.com/how-it-works) 

b. Instant approval

Don’t wait hours or even days to see if you’re approved for your 

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loan: 4 out of every 5 applicants is approved on the spot!

(sevenminuteloans.com/apply.php).

31. Contrary to these representations, most loan applications submitted to 

Defendants were not approved for a loan. 

32. From December 2012 until they ceased operations, Defendants collected 

and marketed more than 15 million loan applications from consumers. For 

approximately 72% of these applications, Defendants were unable to find a buyer, and 

the applications were not approved for a loan. 

33. From December 2012 until they ceased operations, Defendants sold almost 

all of the remaining applications—approximately 26% of the total they have collected—

to non-lenders. Defendants sold no more than two percent of their loan applications to 

lenders. Further, Defendants’ sale of these applications did not mean that the applicants 

were approved for loans. 

34. For the minority of loan applications Defendants sold, including the small 

percentage they sold to lenders, Defendants did not know if any, or how many, of those 

applications were approved for, or resulted in, a loan to the applicant. 

35. On some of Defendants’ websites, they posted inconspicuous disclaimers 

that were inconsistent with the representations they made to induce consumers to 

complete loan applications. For example, some of the websites stated that Defendants 

would not necessarily match consumers with the lender that provides the best rates and 

terms, or that Defendants would not be responsible for the security of personal 

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information transferred to third parties. These statements, even when they appeared, 

were buried in lengthy online terms that were not as prominent as the advertising that 

they contradicted or qualified. 

Defendants Indiscriminately Shared Sensitive Consumer Information 

36. When Defendants presented loan applications to ping tree participants, they 

did not mask or otherwise restrict access to any of the sensitive personal and financial 

information in the applications, such as the social security numbers and financial account 

information. 

37. Defendants could have masked sensitive information prior to the purchase 

of a lead, but they chose not to do so. Instead, they transmitted complete loan 

applications to entities that had not purchased the lead. Indeed, because of the way 

Defendants operated their ping trees, they sent most loan applications—unmasked—to 

multiple entities that did not purchase the applications. 

38. Further, Defendants often sent complete loan applications to entities that 

were not engaged in lending, and thus, even if they purchased the lead, would not use the 

information to provide loans to the applicants. 

39. Further, Defendants often sent complete loan applications to entities about 

which Defendants had little to no information, including information about their lines of 

business, or even their location. Defendants gave loan applications to entities that had 

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provided no address for their business, or had provided only the address of a mail drop or 

a business that acted as an agent for service of process. 

40. Further, in the instances where Defendants sent complete loan applications 

to entities that Defendants claimed offer loans, many of these entities were not legally 

authorized to make consumer loans. Defendants could have inquired whether these 

entities were legally authorized to make loans and taken steps to limit ping tree 

participation to only such entities, but they did not. 

41. Further, Defendants did not require that ping tree participants use the 

information in the applications to offer loans. Instead, they sent the applications under 

agreements that did not limit the recipients’ use of purchased loan applications, and in 

some instances, Defendants entered into agreements that expressly allowed their buyers 

to use purchased loan applications for any purpose. 

42. Defendants continued to send consumers’ sensitive information—including 

social security and financial account numbers—to other entities indiscriminately, even 

after consumer complaints regarding misuse of the information. For example, consumers 

complained that, after using one of the sites operated by Defendants, they received 

demands for repayment of debts that they did not owe from persons or entities armed 

with the specific sensitive information, including social security numbers and financial 

account information, that the consumers had shared with Defendants. Defendants took 

no action to investigate or prevent the misuse of consumer information described in these 

complaints. 

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43. Further, Defendants uncovered misuse of sensitive consumer data through 

an internal tracking system. For many years, Defendants presented ping tree participants 

with phony leads naming fictitious consumers, a process known as “seeding.” In this 

way, Defendants tested when someone was using a lead that was not purchased. In 

several instances, Defendants learned through the seeding process that someone indeed 

contacted the fictitious consumers named in a phony, unpurchased lead, and made offers, 

including ones not involving loans. Defendants took no remedial action against the 

persons or entities that exploited the unpurchased leads. 

44. Beginning in 2015, Defendants drafted policies that purported to address 

these issues, but the policies were weak, and in any event, Defendants did not enforce 

them. For example, Defendants supposedly began requiring that ping tree participants 

agree not to remarket lead data, agree not to share lead data with non-lenders, and agree 

to use leads in a manner “consistent with consumers’ specific intent in providing the 

information in the lead.” Nonetheless, Defendants continued to give ping tree 

participants complete access to unredacted loan applications regardless of whether they 

agreed to such conditions, and did not require them to conform to the policy. 

45. In most, if not all, instances, consumers whose loan applications were 

collected by Defendants did not know and did not consent to Defendants sharing their 

sensitive personal and financial information with entities that were not using the 

information to provide them a loan. Consumers, therefore, could not protect themselves 

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from the harms and potential harms that the disclosures caused, including possible 

identity theft and account fraud. 

46. Defendants could have taken steps to avert the disclosure of consumers’ 

sensitive personal or financial information without injury to its legitimate business, 

including by redacting the information until purchase of the loan application and by 

obtaining consumers’ consent to sharing it with non-lenders or withholding it from such 

entities. 

VIOLATIONS OF THE FTC ACT 

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

deceptive acts or practices in or affecting commerce.” 

48. Misrepresentations or deceptive omissions of material fact are deceptive 

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

under Section 5 of the FTC Act if they cause or are likely to cause substantial injury to 

consumers that consumers cannot reasonably avoid themselves and that is not 

outweighed by countervailing benefits to consumers or competition. 15 U.S.C. § 45(n). 

Count I 

49. Through the means described in paragraphs 17-35 above, Defendants 

represented, directly or indirectly, expressly or by implication, that: 

a. They would match each consumer’s loan application to the loan with the 

lowest interest rate and other terms that were favorable to the consumer; 

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b. They searched the loan offerings of 100 or more lenders to match 

consumers’ loan applications to lenders; 

c. Their protocols ensured that the consumer’s sensitive personal and 

financial information was always secure and shared only with trusted 

lending partners; and 

d. Most consumers’ loan applications were approved. 

50. The representations set forth in Paragraph 49 were false and misleading, or 

were not substantiated at the time the representations were made. 

51. Defendants’ practices as described above constitute deceptive acts or 

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

Count II 

52. Defendants shared and sold consumers’ loan applications containing 

sensitive personal and financial information without regard for whether the recipients 

were lenders or otherwise had a legitimate need for the information, and without 

consumers’ knowledge or consent. 

53. Defendants’ practices have caused or are likely to cause substantial injury 

to consumers that consumers could not have reasonably avoided themselves and that 

were not outweighed by countervailing benefits to consumers or competition. 

54. Defendants’ practices as described above constitute unfair acts or practices 

in violation of Section 5 of the FTC Act, 15 U.S.C. §§ 45(a) and 45(n). 

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CONSUMER INJURY 

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

result of Defendants’ violations of the FTC Act. 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 

56. 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, 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. 

PRAYER FOR RELIEF

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

53(b), and the Court’s own equitable powers, requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC Act by 

Defendants; 

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

resulting from Defendants’ violations of the FTC Act, including but not limited to, 

the disgorgement of ill-gotten monies; and 

C. 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. 

Dated: July 3, 2017 Respectfully submitted,

DAVID SHONKA

Acting General Counsel

\s Michael E. Tankersley 

Michael E. Tankersley

K. Michelle Grajales

Federal Trade Commission

600 Pennsylvania Avenue NW 

Washington, DC 20850 

Telephone: 202-326-2991 

Facsimile: 202-326-3768 

Email; mtankersley@ftc.gov; mgrajales@ftc.gov

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

 

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