COMPLAINT

[2023122] 

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Rebecca Kelly Slaughter, Acting Chair

Noah Joshua Phillips 

Rohit Chopra

Christine S. Wilson

In the Matter of

GENNEX MEDIA LLC, a limited liability 

company, also d/b/a Brandnex, BrandStrong, 

PMGOA, and Promotional Manufacturing 

Group of America; and 

AKIL KURJI, individually and as an officer of 

GENNEX MEDIA LLC. 

DOCKET NO.

The Federal Trade Commission, having reason to believe that Gennex Media LLC, a 

limited liability company also d/b/a Brandnex, BrandStrong, PMGOA, and Promotional 

Manufacturing Group of America, and Akil Kurji, individually and as an officer of Gennex 

Media LLC (collectively, “Respondents”), have violated the provisions of the Federal Trade 

Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges:

1. Respondent Gennex Media LLC (“Gennex”), also doing business as Brandnex, 

BrandStrong, PMGOA, and Promotional Manufacturing Group of America, is a Texas limited 

liability company with its principal office or place of business at 4771 Sweetwater Blvd. #241, 

Sugar Land, TX 77479. 

2. Respondent Akil Kurji (“Kurji”) is Gennex’s sole officer and shareholder. Individually 

or in concert with others, he controlled or had the authority to control, or participated in the acts 

and practices of Gennex, including the acts and practices alleged in this complaint. His principal 

office or place of business is the same as that of Gennex. 

3. At all times material to this Complaint, Kurji has been responsible for Gennex’s ongoing 

operations. Kurji’s responsibilities include, but are not limited to: creating content for the 

Brandnex.com website; approving changes to the Brandnex.com website; creating content for 

social media posts; approving all social media content; and creating and approving content for 

YouTube. 
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4. At all times material to this Complaint, Kurji was responsible for the contracts between 

Gennex and its suppliers, including overseas suppliers. 

5. The acts and practices of Respondents alleged in this Complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act.

6. Since at least 2012, Respondents have advertised, offered for sale, sold, and distributed 

customizable promotional products to consumers, including, but not limited to, wristbands, 

lanyards, temporary tattoos, and buttons. 

7. Respondents have sold their promotional products on their websites including, but not 

limited to, brandnex.com and pmgoa.com, as well as on third-party sales platforms such as 

amazon.com. 

8. Respondents have disseminated or have caused to be disseminated advertisements and

promotional materials for customizable promotional products, including but not necessarily 

limited to the attached Exhibits A through D. These materials contain the following statements

and depictions: 

A. “Made in USA”
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(Exhibit A, Brandnex website) 

B. “MADE IN USA” 

(Exhibit B, Brandnex Price List) 

C. “Made in USA” and “USA MADE.”

(Exhibit C, Brandnex Facebook Header) 
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D. “. . . MANUFACTURED RIGHT HERE IN AMERICA!”

(Exhibit D, Brandnex YouTube Video). 

9. In numerous instances, including, but not limited to, the promotional materials referenced 

in Paragraph 8, Respondents have represented, expressly or by implication, that their 

customizable promotional products are all or virtually all made in the United States.

10. In fact, in numerous of these instances, Respondents’ customizable promotional products 

are wholly imported from China. 

11. In some cases, Respondents’ products ship directly from Chinese manufacturers to 

consumers, without even passing through a U.S. facility controlled by Respondents. 

12. Therefore, Respondents’ express or implied representations that their customizable 

promotional products are all or virtually all made in the United States deceive consumers. 

13. Despite knowing that, in numerous instances, Respondents’ customizable promotional 

products are wholly imported from China, Kurji formulated or approved the promotional 

materials referenced in Paragraph 8. 

Count I 

False or Unsubstantiated Representation – Made in USA

14. In connection with the advertising, promotion, offering for sale, or sale of customizable 

promotional products, Respondents have represented, directly or indirectly, expressly or by 

implication, that such products, including the materials and subcomponents used to make such 

products, are all or virtually all made in the United States.
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15. In fact, in numerous instances, Respondents’ customizable promotional products are 

wholly imported or incorporate significant imported materials or subcomponents. Therefore, the 

representation set forth in paragraph 14 is false or misleading, or was not substantiated at the 

time the representation was made.

Violations of Section 5 

16. The acts and practices of Respondents as alleged in this complaint constitute unfair or 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act.

 THEREFORE, the Federal Trade Commission this _______ day of _______, 20__, has 

issued this Complaint against Respondents. 

By the Commission.

 [April J. Tabor] 

 [Acting Secretary] 

SEAL: