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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF CONNECTICUT

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

GRAND TETON PROFESSIONALS, LLC, et 

al.,

Defendants.

Case No. 3:19-cv-00933-VAB

STIPULATION TO ENTER ORDER FOR PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO DEFENDANT STARTUP MASTERS NJ INC. (NEW 

JERSEY)

Plaintiff Federal Trade Commission (“FTC”) commenced this civil action on June 17, 

2019, pursuant to Sections 13(b) and 19 of the FTC Act, 15 U.S.C. §§ 53(b) and 57b, Section 

410(b) of the Credit Repair Organizations Act (“CROA”), 15 U.S.C. § 1679h(b), Section 6(b) of 

the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. § 6105(b), the 

Consumer Review Fairness Act (“CRFA”), 15 U.S.C. § 45b, Section 108(c) of the Truth in 

Lending Act (“TILA”), 15 U.S.C. § 1607(c), and Section 918(c) of the Electronic Fund Transfers 

Act (“EFTA”), 15 U.S.C. § 1693o(c). (ECF No. 1.) On June 18, 2019, on motion by the FTC, 

the Court entered an ex parte temporary restraining order (“TRO”) with asset freeze and other 

equitable relief against Defendants Grand Teton Professionals, LLC, 99th Floor, LLC, Mait 

Management Inc., Demand Dynamics LLC, Atomium Corps Inc. (Wyoming), Atomium Corps 

Inc. (Colorado), Startup Masters NJ Inc. (Wyoming), Startup Masters NJ Inc. (New Jersey), First 

Incorporation Services Inc. (Wyoming), First Incorporation Services Inc. (Florida), Douglas C. 

Filter, and Marcio G. Andrade. (ECF No. 33.) On July 23, 2019, the Court entered preliminary 

injunctions as to Defendants. (ECF Nos. 60, 61, 62.) Now, the FTC and Defendant Startup 

Masters NJ Inc. (New Jersey), by and through their undersigned counsel, stipulate to the entry of 

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this Order for Permanent Injunction and Monetary Judgment (“Order”) to resolve all matters in 

dispute in this action between them. A proposed order is attached hereto.

FINDINGS OF FACT

By stipulation of the parties, the Court finds that:

A. The Court has jurisdiction over this matter.

B. The Complaint charges that Settling Defendant participated in unlawful acts or practices in 

violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), CROA, 15 U.S.C. §§ 1679-

1679l, the FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, the CRFA, 15 

U.S.C. § 45b, TILA, 15 U.S.C. §§ 1601-1666j, and its implementing Regulation Z, 12 C.F.R. 

Part 1026, and Section 907(a) of EFTA, 15 U.S.C. § 1693e(a), and its implementing 

Regulation E, 12 C.F.R. Part 1005, in connection with the marketing and sale of credit repair 

services.

C. Settling Defendant neither admits nor denies any of the allegations in the Complaint, except 

as specifically stated in this Order. Only for purposes of this action, Settling Defendant 

admits the facts necessary to establish jurisdiction.

D. Settling Defendant waives any claim that it may have under the Equal Access to Justice Act, 

28 U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, 

and agrees to bear its own costs and attorney fees.

E. Settling Defendant waives all rights to seek judicial review or otherwise challenge or contest 

the validity of this Order.

F. This order is in the public interest. 

DEFINITIONS

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

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A. “Consumer” means any Person.

B. “Covered Communication” means a written, oral, or pictorial review, performance 

assessment, or other similar analysis of products or services, including conduct related to the 

products or services.

C. “Credit Repair Service” means any service for the express or implied purpose of: (1) 

improving any Consumer’s credit report, credit record, credit history, credit profile, credit

score, or credit rating; or (2) providing advice or assistance to any Consumer with regard to 

any activity or service the purpose of which is to improve a Consumer’s credit report, credit 

record, credit history, credit profile, credit score, or credit rating.

D. “Defendants” means Corporate Defendants and Individual Defendants, individually, 

collectively, or in any combination. “Corporate Defendants” means Grand Teton 

Professionals, LLC, 99th Floor, LLC, Mait Management Inc., Demand Dynamics LLC, 

Atomium Corps Inc. (a Wyoming company), Atomium Corps Inc. (a Colorado company), 

Startup Masters NJ Inc. (a Wyoming company), Startup Masters NJ Inc. (a New Jersey 

company), First Incorporation Services Inc. (a Wyoming company), First Incorporation 

Services Inc. (a Florida company), and each of their subsidiaries, affiliates, successors, and 

assigns. “Individual Defendants” means Douglas C. Filter and Marcio G. Andrade, 

individually, collectively, or in any combination.

E. “Financial Product or Service” means any product, service, plan, or program represented, 

expressly or by implication to (1) provide any Consumer, arrange for any Consumer to 

receive, or assist any Consumer in receiving, a loan or other extension of credit; (2) provide 

any Consumer, arrange for any Consumer to receive, or assist any Consumer in receiving, 

credit, debit, or stored value cards; or (3) provide any Consumer, arrange for any Consumer 

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to receive, or assist any Consumer in receiving, any Secured or Unsecured Debt Relief 

Product or Service.

F. “Merchant Account” means an account used to submit credit card or debit card transactions 

or process credit card or debit card transactions.

G. “Person” means a natural person, an organization or other legal entity, including a 

corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity.

H. “Review-Limiting Contract Term” means a contract term that (1) prohibits or restricts the 

ability of a Person who is a party to the contract to engage in a Covered Communication; (2) 

imposes a penalty or fee against a Person who is a party to the contract for engaging in a 

Covered Communication; or (3) transfers, or requires a Person who is a party to the contract 

to transfer, to any other Person any intellectual property rights in a Covered Communication, 

with the exception of a non-exclusive license to lawfully use a Covered Communication 

about a Person’s products or services.

I. “Secured or Unsecured Debt Relief Product or Service” means, with respect to any 

mortgage, loan, debt, or obligation between a Person and one or more secured or unsecured 

creditors or debt collectors, any product, service, plan, or program represented, expressly or 

by implication to (1) negotiate, settle, or in any way alter the terms of payment or other terms 

of the mortgage, loan, debt, or obligation, including but not limited to, a reduction in the 

amount of interest, principal balance, monthly payments, or fees owed by a Person to a 

secured or unsecured creditor or debt collector; (2) stop, prevent, or postpone any mortgage 

or deed of foreclosure sale for a Person’s dwelling, any other sale of collateral, any 

repossession of a Person’s dwelling or other collateral, or otherwise save a Person’s dwelling 

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or other collateral from foreclosure or repossession; (3) obtain any forbearance or 

modification in the timing of payments from any secured or unsecured creditor or debt 

collector; (4) negotiate, obtain, or arrange any extension of the period of time within which 

the Person may (a) cure his or her default on the mortgage, loan, debt, or obligation, (b) 

reinstate his or her mortgage, loan, debt, or obligation, (c) redeem a dwelling or other 

collateral, or (d) exercise any right to reinstate the mortgage, loan, debt, or obligation or 

redeem a dwelling or other collateral; (5) obtain any waiver of an acceleration clause or 

balloon payment contained in any promissory note or contract secured by any dwelling or 

other collateral; or (6) negotiate, obtain, or arrange, (a) a short sale of a dwelling or other 

collateral, (b) a deed-in-lieu of foreclosure, or (c) any other disposition of a mortgage, loan, 

debt, or obligation other than a sale to a third party that is not the secured or unsecured loan 

holder. The foregoing shall include any manner of claimed assistance, including, but not 

limited to, auditing or examining a Person’s application for the mortgage, loan, debt, or 

obligation.

J. “Settling Defendant” means Startup Masters NJ Inc. (a New Jersey company) and its 

successors and assigns.

ORDER

BAN ON CREDIT REPAIR ACTIVITIES

I. IT IS THEREFORE ORDERED that Settling Defendant is permanently restrained and 

enjoined from advertising, marketing, promoting, offering for sale, or selling, or assisting in 

the advertising, marketing, promoting, offering for sale, or selling, of any Credit Repair 

Service.

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PROHIBITED BUSINESS ACTIVITIES REGARDING FINANCIAL PRODUCTS AND 

SERVICES

II. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’s officers, 

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

them, who receive actual notice of this Order by personal service or otherwise, whether 

acting directly or indirectly, in connection with the advertising, marketing, promoting, 

offering for sale, or selling of any Financial Product or Service, are permanently restrained 

and enjoined from:

A. Misrepresenting, or assisting others in misrepresenting, expressly or by implication:

1. The terms or rates that are available for any loan or other extension of credit, 

including, but not limited to: (1) the type of credit (such as a credit card, line of 

credit, or loan); (2) closing costs or other fees and how such costs or fees will be 

assessed; (3) the payment schedule, monthly payment amount(s), any balloon 

payment, or other payment terms; (4) the interest rate(s), annual percentage 

rate(s), or finance charge(s), and whether they are fixed or adjustable; (5) the loan 

amount, credit amount, draw amount, or outstanding balance; the loan term, draw 

period, or maturity; or any other term of credit; (6) the amount of cash to be 

disbursed to the borrower out of the proceeds, or the amount of cash to be 

disbursed on behalf of the borrower to any third parties; (7) whether any specified 

minimum payment amount covers both interest and principal, and whether the 

credit has or can result in negative amortization; or (8) that the credit does not 

have a prepayment penalty or whether subsequent refinancing may trigger a 

prepayment penalty and/or other fees;

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2. Any material fact concerning any aspect of any Secured or Unsecured Debt Relief 

Product or Service, including but not limited to (a) the amount of savings a 

Consumer will receive from purchasing, using, or enrolling in such Secured or 

Unsecured Debt Relief Product or Service; (b) the amount of time before which a 

Consumer will receive settlement of that Consumer’s debts; or (c) the reduction or 

cessation of collection calls; or

3. Any other fact material to Consumers concerning any Financial Product or 

Service, such as: the total costs; any material restrictions, limitations, or 

conditions; or any material aspect of its performance, efficacy, nature, or central 

characteristics; or

B. Failing to disclose clearly and conspicuously, in connection with any representation 

regarding the availability of any loan or other extension of credit: (1) the type of 

credit (such as a credit card, line of credit, or loan); (2) all costs associated with such 

extension of credit and how such costs shall be assessed; (3) the interest rate(s), 

annual percentage rate(s), or finance charge(s), and whether they are fixed or 

adjustable; and (4) the loan amount, credit amount or limit, draw amount, outstanding 

balance.

PROHIBITED BUSINESS ACTIVITIES REGARDING ANY PRODUCTS OR 

SERVICES

III. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’s officers, 

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

them, who receive actual notice of this Order by personal service or otherwise, whether 

acting directly or indirectly, in connection with the advertising, marketing, promoting, or 

offering for sale of any product or service, are permanently restrained and enjoined from: 

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A. Prohibiting any Person from exercising their rights under any statute, rule, or agreement 

to dispute a charge placed on their credit or debit card or withdrawal from their bank 

account, including, but not limited to, by initiating or threatening to initiate legal action 

or imposing or threatening to impose a penalty or fee for exercising any right under any 

statute, rule, or agreement to dispute a charge placed on their credit or debit card or 

withdrawal from their bank account; 

B. Creating or causing to be created, directly or indirectly, a remotely created payment order 

as payment for any product or service; or

C. Misrepresenting, or assisting others in misrepresenting, expressly or by implication, any 

fact material to Consumers concerning any product or service, such as: the total costs; 

any material restrictions, limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics.

PROHIBITION AGAINST UNSUBSTANTIATED CLAIMS

IV. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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 the advertising, marketing, promoting, offering for sale, or selling of any

product or service, are permanently restrained and enjoined from making any representation 

or assisting others in making any representation, expressly or by implication, about the

benefits, performance, or efficacy of any product or service, unless the representation is 

non-misleading, and, at the time such representation is made, Settling Defendant possesses

and relies upon competent and reliable evidence that is sufficient in quality and quantity 

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based on standards generally accepted in the relevant fields, when considered in light of the 

entire body of relevant and reliable evidence, to substantiate that the representation is true.

PROHIBITIONS AND LIMITS ON USE OF CERTAIN CONTRACT PROVISIONS 

AND ON CERTAIN REPRESENTATIONS AND THREATS ABOUT CUSTOMER 

COMMUNICATIONS

V. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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 the advertising, marketing, promoting, offering for sale, or selling of any

product or service, are permanently restrained and enjoined from:

A. Offering to any prospective customer a contract, or offering to any customer a renewal 

contract, that includes a Review-Limiting Contract Term;

B. Requiring that a customer accept a Review-Limiting Contract Term as a condition of a 

Defendant’s fulfillment of its obligations under a customer contract;

C. Representing, including through any notice, warning, threat to enforce, or attempt to 

enforce, to any purchaser of any product or service—regardless of when purchased—that

any contract:

1. Prohibits purchasers from speaking or publishing truthful or non-defamatory negative 

comments or reviews about any Person, or such other Person’s products, services, 

agents, or employees; or

2. Imposes any precondition on purchasers speaking or publishing any comments or 

reviews about any Person, or such other Person’s products, services, agents, or 

employees;

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D. Representing that any Person could be liable for defamation or other legal liability or 

imposing or threatening to impose a penalty or fee for speaking or publishing any truthful 

or non-defamatory negative comment or review about any other Person or such other 

Person’s products or services; or

E. Retaliating, or threatening to take or taking any adverse action, against any Person who 

communicates or cooperates with, provides statements, documents, or information to, or 

testifies on behalf of, the FTC or other party in connection with any law enforcement 

investigation or litigation, or who has done so during or prior to this litigation, including 

by enforcing or threatening to enforce any contractual provision representing that it limits 

or prohibits the Person from speaking or publishing any truthful or non-defamatory 

negative comment or review about any other Person or such other Person’s products or 

services.

INJUNCTION RELATED TO EXTENSIONS OF CREDIT

VI. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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 advertisement for any extension of credit, are hereby permanently

restrained and enjoined from:

A. Stating, expressly or by implication:

1. The amount or percentage of any down payment, the number of payments or period 

of repayment, the amount of any payment, or the amount of any finance charge, 

without disclosing clearly and conspicuously all of the following terms:

a. The amount or percentage of the down payment;

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b. The terms of repayment; and

c. The annual percentage rate, using the term “annual percentage rate” or the 

abbreviation “APR.” If the annual percentage rate may be increased after 

consummation of the credit transaction, that fact must also be disclosed; or

2. A rate of finance charge without stating the rate as an “annual percentage rate” or the 

abbreviation “APR,” using that term; or

B. Violating the Truth in Lending Act, 15 U.S.C. §§ 1601-1667, or Regulation Z, 12 C.F.R. 

Part 226.

INJUNCTION RELATED TO RECURRING BANK DEBITS

VII. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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, are 

hereby permanently restrained and enjoined from:

A. Making electronic fund transfers from a Consumer’s deposit, savings or asset account on 

a recurring basis without:

1. Obtaining a written authorization signed or similarly authenticated from the 

Consumer for preauthorized electronic fund transfers from the Consumer’s account, 

which written authorization must (a) be readily identifiable as such and (b) the terms 

of the preauthorized transfer, including the amount of each transfer and the dates on 

which each transfer will be made, are clear and readily understandable; and

2. Providing to the Consumer a copy of a written authorization signed or similarly 

authenticated from the Consumer for preauthorized electronic fund transfers from the 

Consumer’s account; or

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B. Violating the Electronic Fund Transfers Act, 15 U.S.C. §§ 1693-1693r, or Regulation E, 

12 C.F.R. Part 205.

INJUNCTION RELATING TO TELEMARKETING

VIII. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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 telemarketing, advertising, marketing, promoting, offering for sale, or 

selling of any product or service, are hereby permanently restrained and enjoined from

violating the FTC’s Telemarketing Sales Rule, 16 C.F.R. Part 310.

INJUNCTION RELATING TO MERCHANT ACCOUNTS

IX. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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, are 

hereby permanently restrained and enjoined from obtaining Merchant Accounts for any 

Person engaged in any activity prohibited by Sections I, II, III, IV, V, VI, VII, or VIII of this 

Order.

CUSTOMER INFORMATION

X. IT IS FURTHER ORDERED that Settling Defendant, Settling Defendant’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, are 

hereby permanently restrained and enjoined from:

A. Failing to provide sufficient customer information to enable the FTC to efficiently 

administer consumer redress. If a representative of the FTC requests in writing any 

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information related to redress, Settling Defendant must provide it, in the form prescribed 

by the FTC, within 14 days

B. Disclosing, using, or benefitting from customer information, including the name, address, 

telephone number, email address, social security number, other identifying information, 

or any data that enables access to a customer’s account (including a credit card, bank 

account, or other financial account), that any Defendant obtained prior to entry of this 

Order in connection with the marketing and sale of Credit Repair Services; or

C. Failing to destroy such customer information in all forms in their possession, custody, or 

control within 30 days after receipt of written direction to do so from a representative of 

the FTC.

D. Provided, however, that customer information need not be disposed of, and may be 

disclosed, to the extent requested by a government agency or required by law, regulation, 

or court order.

MONETARY JUDGMENT AND PARTIAL SUSPENSION

XI. IT IS FURTHER ORDERED:

A. Judgment in the amount of NINE HUNDRED AND TWENTY NINE THOUSAND, 

AND FIFTY FOUR Dollars ($929,054) is entered in favor of the FTC against Settling

Defendant as equitable monetary relief, jointly and severally with Defendants Grand 

Teton Professionals, LLC, 99th Floor, LLC, Mait Management Inc., Demand Dynamics 

LLC, Atomium Corps Inc. (a Wyoming company), Startup Masters NJ Inc. (a Wyoming 

company), First Incorporation Services Inc. (a Wyoming company), Douglas C. Filter, 

and Marcio G. Andrade to the extent any judgment is entered against them.

B. The judgment as to Settling Defendant is suspended, subject to the Subsections below.

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C. Upon entry of this Order, the asset freeze as to Settling Defendant is dissolved.

D. The FTC’s agreement to the suspension of the judgment is expressly premised upon the 

truthfulness, accuracy, and completeness of Settling Defendant’s sworn financial 

statement and related documents (collectively, “financial representations”) submitted to 

the FTC, namely the Financial Statement of Corporate Defendant Startup Masters NJ Inc. 

(New Jersey) signed by Richard Lewis, President on July 18, 2019, including the 

attachments.

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

the FTC, 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.

F. 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 consumer injury alleged in the 

Complaint), less any payment previously made pursuant to this Section, plus interest 

computed from the date of entry of this Order.

G. 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.

H. The facts alleged in the Complaint will be taken as true, without further proof, in any 

subsequent civil litigation by or on behalf of the FTC, 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.

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I. The facts alleged in the Complaint establish all elements necessary to sustain an action by 

the FTC pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. 

§ 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes.

J. Settling Defendant acknowledges that its Taxpayer Identification Numbers, which 

Settling Defendant previously submitted to the FTC, may be used for collecting and 

reporting on any delinquent amount arising out of this Order, in accordance with 31 

U.S.C. §7701.

K. All money paid to the FTC pursuant to this Order may be deposited into a fund 

administered by the FTC 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 FTC decides that direct redress to consumers is wholly or 

partially impracticable or money remains after redress is completed, the FTC 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. Settling Defendant has no right to challenge any actions the 

FTC or its representatives may take pursuant to this Subsection.

COOPERATION

XII. IT IS FURTHER ORDERED that Settling Defendant must fully cooperate with 

representatives of the FTC in this case and in any investigation related to or associated with 

the transactions or the occurrences that are the subject of the Complaint. Settling Defendant

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

Defendant must cause its officers, employees, representatives, or agents to appear for 

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interviews, discovery, hearings, trials, and any other proceedings that a representative of the 

FTC may reasonably request upon 5 days written notice, or other reasonable notice, at such 

places and times as a representative of the FTC may designate, without the service of a 

subpoena.

ORDER ACKNOWLEDGMENTS

XIII. IT IS FURTHER ORDERED that Settling Defendant obtain acknowledgments of receipt 

of this Order:

A. Settling Defendant, within 7 days of entry of this Order, must submit to the FTC an 

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

B. For 5 years after entry of this Order, Settling Defendant 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 related to the 

subject matter of the Order; 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 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 Settling Defendant delivered a copy of this 

Order, Settling Defendant must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order.

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COMPLIANCE REPORTING

XIV. IT IS FURTHER ORDERED that Settling Defendant make timely submissions to the FTC:

A. One year after entry of this Order, Settling Defendant must submit a compliance report, 

sworn under penalty of perjury. Settling Defendant must: (a) identify the primary 

physical, postal, and email address and telephone number, as designated points of 

contact, which representatives of the FTC may use to communicate with Settling

Defendant; (b) identify all of Settling 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 products and services offered, the means of 

advertising, marketing, and sales, and the involvement of any other Defendant; (d) 

describe in detail whether and how Settling Defendant is in compliance with each Section 

of this Order; and (e) provide a copy of each Order Acknowledgment obtained pursuant 

to this Order, unless previously submitted to the FTC.

B. For 10 years after entry of this Order, Settling Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the following.

Settling Defendant must report any change in: (a) any designated point of contact; or (b) 

the structure of Settling Defendant or any entity that Settling 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.

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C. Settling Defendant must submit to the FTC notice of the filing of any bankruptcy 

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

within 14 days of its filing.

D. Any submission to the FTC 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 FTC representative in writing, all submissions to the FTC 

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. Grand Teton 

Professionals, X190030.

RECORDKEEPING

XV. IT IS FURTHER ORDERED that Settling Defendant must create certain records for 10

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

Defendant must create and retain the following records:

A. accounting records showing the revenues from all products 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;

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C. records of all Consumer complaints and refund requests, whether received directly or 

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

D. all records necessary to demonstrate full compliance with each provision of this Order, 

including all submissions to the FTC; and

E. a copy of each unique advertisement or other marketing material.

COMPLIANCE MONITORING

XVI. IT IS FURTHER ORDERED that, 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 FTC, Settling

Defendant 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 FTC 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 FTC is authorized to communicate directly with 

Settling Defendant. Settling Defendant must permit representatives of the FTC to 

interview any employee or other person affiliated with Settling Defendant who has 

agreed to such an interview. The person interviewed may have counsel present.

C. The FTC 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 FTC’s lawful use of 

Case 3:19-cv-00933-VAB Document 79 Filed 12/13/19 Page 19 of 21
Page 20 of 21

compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49 and

57b-1.

ENTRY OF JUDGMENT

XVII. IT IS FURTHER ORDERED that there is no just reason for delay of entry of this 

judgment, and that, pursuant to Federal Rule of Civil Procedure 54(b), the Clerk immediately 

shall enter this Order as a final judgment as to Defendant Startup Masters NJ Inc. (New 

Jersey).

RETENTION OF JURISDICTION

XVIII. IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for all 

purposes.

IT IS SO STIPULATED:

/s/Gregory A. Ashe

GREGORY A. ASHE (Bar No. PHV09777)

IOANA R. GORECKI (Bar No. PHV10094)

Federal Trade Commission

600 Pennsylvania Avenue NW

Washington, DC 20580

Telephone: 202-326-3719 (Ashe)

Telephone: 202-326-2077 (Gorecki)

Facsimile: 202-326-3768

Email: gashe@ftc.gov, igorecki@ftc.gov

JOHN HUGHES (CT 05289)

Assistant United States Attorney

Chief of Civil Division

157 Church Street

New Haven, CT 06510

Telephone: 203-821-3700

Facsimile: 203-773-5373

Email: john.hughes@usdoj.gov

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

/s/Richard Lewis (with permission)

STARTUP MASTERS NJ INC. (New Jersey)

Defendant

by: Richard Lewis, President

/s/ A. Nicole Phillips (with permission)

A. NICOLE PHILLIPS

Montgomery McCracken Walker 

& Rhoads LLP

1735 Market Street

Philadelphia, PA 19103

Telephone: 215-772-7283

Facsimile: 215-731-3781

Email: nphillips@mmwr.com

Attorney for Defendant Startup Masters NJ 

Inc. (New Jersey)

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on December 13, 2019, a true and correct copy of (1) 

STIPULATION TO ENTER ORDER FOR PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO DEFENDANT STARTUP MASTERS NJ INC. (NEW 

JERSEY) and (2) [proposed] STIPULATED ORDER FOR PERMANENT INJUNCTION 

AND MONETARY JUDGMENT AS TO DEFENDANT STARTUP MASTERS NJ INC.

(NEW JERSEY) were filed electronically with the United States District Court for the District 

of Connecticut using the CM/ECF system, which sent notification to all parties of interest 

participating in the CM/ECF system.

The undersigned counsel further certifies that a true and correct copy of (1) STIPULATION TO 

ENTER ORDER FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT

AS TO DEFENDANT STARTUP MASTERS NJ INC. (NEW JERSEY) and (2) [proposed] 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY 

JUDGMENT AS TO DEFENDANT STARTUP MASTERS NJ INC. (NEW JERSEY) will 

be emailed to the following non-CM/ECF participants:

Richard Newman, Esq.

A. Nicole Phillips, Esq.

Atomium Corps Inc. (Colorado)

First Incorporation Services Inc. (Florida)

/s/Gregory A. Ashe

Attorney for Plaintiff Federal Trade Commission

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