UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 18-61017-CIV-ALTONAGA/Seltzer

FEDERAL TRADE COMMISSION, 

Plaintiff,

v. 

POINTBREAK MEDIA, LLC; et al., 

Defendants.

__________________________________/ 

STIPULATED ORDER OF PERMANENT INJUNCTION AND MONETARY 

JUDGMENT AS TO RELIEF DEFENDANT STEPHANIE WATT

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

Amended Complaint for Permanent Injunction and Other Equitable Relief [ECF No. 109] (“First 

Amended Complaint”) under section 13(b) of the Federal Trade Commission Act (“FTC Act”), 15 

U.S.C. section 53(b). The Commission and Relief Defendant Stephanie Watt stipulate to entry of 

this Stipulated Order of Permanent Injunction and Monetary Judgment (“Order”) to resolve all 

matters in dispute in this action between them. 

Having carefully reviewed the parties’ stipulation and the record, it is 

ORDERED AND ADJUDGED as follows: 

FINDINGS

A. The Court has jurisdiction over this matter.

B. The First Amended Complaint charges that the Defendants participated in 

deceptive acts or practices in violation of section 5 of the FTC Act, 15 U.S.C. section 45, in the 

marketing and sale of Google “claiming and verification” and search engine optimization services. 

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C. The First Amended Complaint also charges that Relief Defendant Stephanie Watt

has received assets from the Defendants, that she has no legitimate claim to those assets, that such 

assets are subject to a constructive trust, and that she will be unjustly enriched if she is not required 

to disgorge the assets or the value thereof. 

D. Relief Defendant Stephanie Watt neither admits nor denies any of the allegations 

in the First Amended Complaint, except as specifically stated in this Order. Only for purposes of 

this action, Relief Defendant Stephanie Watt admits the facts necessary to establish jurisdiction.

E. Relief Defendant Stephanie Watt waives any claim that she may have under the 

Equal Access to Justice Act, 28 U.S.C. section 2412, concerning the prosecution of this action 

through the date of this Order, and agrees to bear her own costs and attorney fees. 

F. Relief Defendant Stephanie Watt and the Commission waive all rights to appeal 

or otherwise challenge or contest the validity of this Order.

DEFINITIONS

 For purposes of this Order, the following definitions apply: 

A. “Defendants” means all of the Individual Defendants and the Corporate

Defendants, individually, collectively, or in any combination. 

B. “Individual Defendants” means Dustin Pillonato; Justin Ramsey; Aaron Michael 

Jones, a/k/a Michael Aaron Jones and Mike Jones; Ricardo Diaz; Michael Pocker; Steffan Molina; 

Vincent Yates; and Daniel Carver; individually, collectively, or in any combination. 

C. “Corporate Defendants” means Pointbreak Media, LLC; DCP Marketing, LLC,; 

Modern Spotlight LLC; Modern Spotlight Group LLC; Modern Internet Marketing LLC; Modern 

Source Media, LLC; Perfect Image Online LLC; Allstar Data, LLC; National Business Listings, 

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LLC; and Pinnacle Presence LLC; and their successors and assigns, individually, collectively, or 

in any combination. 

D. “Settling Defendant” means Relief Defendant Stephanie Watt. 

E. “Receiver” means Jonathan E. Perlman, Esq., whom the Court appointed as

Receiver in Section XI of the Preliminary Injunction as to Defendants Dustin Pillonato; Justin 

Ramsey; Aaron Michael Jones; Michael Pocker; Pointbreak Media, LLC; DCP Marketing, LLC; 

Modern Spotlight LLC; Modern Spotlight Group LLC; Modern Internet Marketing LLC; and 

Modern Source Media, LLC (see [ECF No. 64]); in Section XI of the Preliminary Injunction as to 

Defendants Steffan Molina and Perfect Image Online LLC [ECF No. 58]; and in Section XI of the 

Preliminary Injunction as to Defendants Allstar Data, LLC; National Business Listings, LLC; 

Pinnacle Presence LLC; Vincent Yates; and Daniel Carver [ECF No. 169]. 

ORDER

I. MONETARY JUDGMENT

A. Judgment in the amount of $62,279.00 is entered in favor of the Commission and 

against Settling Defendant as equitable monetary relief.

B. Settling Defendant is ordered to pay to the Receiver $20,000.00. Such payment 

must be made within seven days of entry of this Order by electronic fund transfer in 

accordance with instructions provided by a representative of the Receiver. Upon such 

payment, the remainder of the judgment is suspended, subject to the Subsections below. 

C. The Commission’s agreement to the suspension of part of the judgment is expressly 

premised upon the truthfulness, accuracy, and completeness of Settling Defendant’s sworn 

financial statements and related documents (collectively, “financial representations”) 

submitted to the Commission, namely: 

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1. the Financial Statement of Stephanie Watt signed on August 30, 2018, 

including all attachments and other documentation provided by Settling 

Defendant’s counsel on September 18, 2018 with this Financial Statement; 

2. the Declaration of Stephanie Watt signed on September 24, 2018; 

3. the information and documents submitted by Settling Defendant’s counsel 

on November 6, 2018 to counsel for the Federal Trade Commission; and

4. the information and documents submitted by Settling Defendant’s counsel 

on December 4, 2018 to counsel for the Federal Trade Commission. 

D. The suspension of the judgment will be lifted as to Settling Defendant if, upon 

motion by the Commission, the Court finds that Settling Defendant failed to disclose any 

material asset, materially misstated the value of any asset, or made any other material 

misstatement or omission in the financial representations identified above. 

E. If the suspension of the judgment is lifted, the judgment becomes immediately due 

as to Settling Defendant in the amount specified in Subsection A above (which the parties 

stipulate only for purposes of this Section represents the unjust enrichment received by 

Settling Defendant, as alleged in the First Amended Complaint), less any payment 

previously made pursuant to this Section, plus interest computed from the date of entry of 

this Order.

II. ADDITIONAL MONETARY PROVISIONS

A. Settling Defendant relinquishes dominion and all legal and equitable right, title, 

and interest in all assets transferred pursuant to this Order and may not seek the return of 

any assets.

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B. The facts alleged in the First Amended Complaint will be taken as true, without 

further proof, in any subsequent civil litigation by or on behalf of the Commission, 

including in a proceeding to enforce its rights to any payment or monetary judgment 

pursuant to this Order, such as a nondischargeability complaint in any bankruptcy case. 

C. The facts alleged in the First Amended Complaint establish all elements necessary 

to sustain an action by the Commission pursuant to section 523(a)(2)(A) of the Bankruptcy 

Code, 11 U.S.C. section 523(a)(2)(A), and this Order will have collateral estoppel effect 

for such purposes. 

D. Settling Defendant acknowledges that her Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Settling Defendant

previously submitted to the Commission, may be used for collecting and reporting on any 

delinquent amount arising out of this Order, consistent with 31 U.S.C. section 7701. 

E. All money paid to the Commission under 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 First Amended Complaint. Any money not used for such equitable relief is 

to be deposited to the United States Treasury as disgorgement. Settling Defendant has no 

right to challenge any actions the Commission or its representatives may take under this 

Subsection. 

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III. LIFTING OF ASSET FREEZE

The freeze against the assets of Settling Defendant pursuant to the August 31, 2018 

Stipulated Preliminary Injunction [ECF No. 170] is modified to permit the payment identified in 

the Monetary Judgment Section. Upon completion of that payment, the asset freeze is dissolved

as to Settling Defendant only. 

IV. COOPERATION

The Settling Defendant must fully cooperate with representatives of the Commission and 

the Receiver in this case and in any investigation related to or associated with the transactions or 

the occurrences that are the subject of the First Amended Complaint in this matter. Settling 

Defendant must provide truthful and complete information, evidence, and testimony. Settling 

Defendant must appear for interviews, discovery, hearings, trials, and any other proceedings that 

a Commission representative or Receiver representative may reasonably request upon 14 days 

written notice, or other reasonable notice, at such places and times as a Commission representative 

or Receiver representative may designate, without the service of a subpoena. This section does 

not abrogate Settling Defendant’s right to assert any applicable legal privilege. 

V. ORDER ACKNOWLEDGMENT

The Settling Defendant, within seven days of entry of this Order, must submit to the 

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

VI. REPORTING REQUIREMENTS

The Settling Defendant must make timely submissions to the Commission as follows: 

A. Settling Defendant must submit to the Commission notice of the filing of any 

bankruptcy petition, insolvency proceeding, or similar proceeding by or against Settling

Defendant within 14 days of its filing. 

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B. 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. section 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,” and supplying the date, signatory’s full 

name, title (if applicable), and signature.

C. 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. 

Stephanie Watt, X180031. 

VII. COMPLIANCE MONITORING 

For the purpose of monitoring Settling Defendant’s compliance with this Order, including 

the financial representations upon which part of the judgment was suspended and any failure to 

transfer any assets as required by this Order: 

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

Commission, Settling Defendant must: submit 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. Notwithstanding the provisions of Local Rule 26.1(i), the Commission is not 

required to provide notice to Settling Defendant of, or make available for inspection by 

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Settling Defendant, any objections, documents, electronically stored information, or things 

received in response to a subpoena. 

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

directly with Settling Defendant. Settling Defendant must permit representatives of the 

Commission to interview any employee or other person affiliated with any Settling 

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 Settling 

Defendant or any individual or entity affiliated with Settling Defendant, without the 

necessity of identification or prior notice. Nothing in this Order limits the Commission’s 

lawful use of compulsory process under sections 9 and 20 of the FTC Act, 15 U.S.C. 

sections 49, 57b-1. 

D. Upon written request from a representative of the Commission, any consumer 

reporting agency must furnish consumer reports concerning Settling Defendant under the 

Fair Credit Reporting Act, 15 U.S.C. section 1681b(a)(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. 

DONE AND ORDERED in Miami, Florida, this 25th day of April, 2019. 

 

____________________________________ 

CECILIA M. ALTONAGA

 UNITED STATES DISTRICT JUDGE

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SO STIPULATED AND AGREED:

FOR PLAINTIFF FEDERAL TRADE COMMISSION:

_________________________________________ 

Evan M. Mendelson, Special Bar No. A5502430 

Christopher J. Erickson, Special Bar No. A5502434 

Brian M. Welke, Special Bar No. A5502432 

Federal Trade Commission

600 Pennsylvania Ave. NW 

Mailstop CC-9528 

Washington, DC 20580 

(202) 326-3320; emendelson@ftc.gov 

(202) 326-3671; cerickson@ftc.gov 

(202) 326-2897; bwelke@ftc.gov 

Fax: (202) 326-3197 

RELIEF DEFENDANT STEPHANIE WATT: 

_________________________________________

Stephanie Watt

Individually

FOR RELIEF DEFENDANT STEPHANIE WATT: 

_________________________________________ 

ANDREW N. COVE, ESQUIRE

Florida Bar No.: 0562122 

anc@covelaw.com 

MITCHELL N. ROTH, ESQUIRE

Virginia Bar No.: 35863 

mroth@rothjackson.com 

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