Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 1 of 43 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF UTAH 

Federal Trade Commission, 

Plaintiff,

vs. 

Apply Knowledge, LLC, et al., 

Defendants. 

Case No. 2:14-cv-00088 (DB) 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND MONETARY 

JUDGMENT AS TO DEFENDANTS DAHM INTERNATIONAL, LLC; DOMINION 

OF VIRGO INVESTMENTS, INC.; ESSENT MEDIA, LLC; EVI, LLC; NEMROW 

CONSULTING, LLC; NOVUS NORTH, LLC; PURPLE BUFFALO, LLC; 

365DAILYFIT, LLC; VENSURE INTERNATIONAL, LLC; JESSICA BJARNSON; 

PHILLLIP EDWARD GANNUSCIA II; RICHARD SCOTT NEMROW; JEFFREY 

NICOL; and THOMAS J. RISKAS III 

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

Complaint for Permanent Injunction and Other Equitable Relief (Dkt. No. 216) (“Complaint”) in 

this matter pursuant to Sections 13(b) and 19 of the Federal Trade Commission (“FTC Act”), 15 

U.S.C. §§ 53(b) and 57b, and the Telemarketing and Consumer Fraud Abuse Prevention Act 

(“Telemarketing Act”), 15 U.S.C. §§ 6101-6108. The Commission and Dahm International 

LLC; Dominion of Virgo Investments, Inc.; Essent Media LLC, EVI LLC (d/b/a Members 

Learning Center); Nemrow Consulting LLC; Novus North LLC (d/b/a MyMentoring, Yes 

International LLC, and Your eCommerce Support International LLC); Purple Buffalo LLC (d/b/a 

NetMarketing); 365DailyFit LLC (d/b/a Net Training); Vensure International LLC; Jessica 

Bjarnson; Phillip Edward Gannuscia, II; Richard Scott Nemrow; Jeffrey Nicol; and Thomas J. 

Riskas, III (“Essent Defendants or Defendants”) hereby stipulate to the entry of this Stipulated 

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

dispute in this action between them. 

FINDINGS 

1. This Court has jurisdiction over the subject matter. 

2. The Complaint charges that Defendants participated in deceptive acts or practices 

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

Fraud and Abuse Prevention Act, 15 U.S.C. §§ 6101-6108, and the Telemarketing Sales Rule, 16 

C.F.R. Part 310, in the marketing of business coaching services to consumers throughout the 

United States. 

3. The Essent Defendants neither admit nor deny any of the allegations in the 

Complaint, except as specifically stated in this Order. Only for purposes of this action, 

Defendants admit the facts necessary to establish jurisdiction. 

4. The Essent Defendants waive any claim that they 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 agree to bear their own costs and attorney fees. 

5. The Essent Defendants waive and release any claims that they may have against 

the Commission and its respective agents that relate to this action. 

6. The Essent Defendants and the Commission waive all rights to appeal or 

otherwise challenge or contest the validity of this Order. 

ORDER 

DEFINITIONS 

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

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1. “Acquirer” or “Acquiring Bank” means a business organization, Financial Institution, 

or an agent of a business organization or Financial Institution that has authority from an 

organization that operates or licenses a credit card system (e.g., Visa, MasterCard, American 

Express, or Discover) to authorize merchants to accept, transmit, or process payment by credit 

card through the credit card system for money, goods or services, or anything else of value. 

2. “Add-on Services” means any additional product offered to a consumer who has 

purchased a product. 

3. “Assisting Others” means providing assistance or support to any Person, including 

providing any of the following services: (a) performing customer service functions, including 

receiving or responding to consumer complaints; (b) formulating or providing, or arranging for 

the formulation or provision of, any sales script or other promotional material; (c) providing 

names of, or assisting in the generation of, potential customers; (d) verifying, processing, 

fulfilling, or arranging for the fulfillment of orders; (e) hiring, recruiting, or training personnel; 

(f) performing promotional or marketing services of any kind; or (g) processing or arranging for 

processing of credit cards, debit cards, Automated Clearinghouse (“ACH”) debits, remotelycreated checks, or payments through any other system. 

4. “Business Coaching Program” means any program, plan, or product, including those 

related to work-at-home-opportunities, that is represented, expressly or by implication, to train or 

teach a participant or purchaser how to establish a business or earn money or other consideration 

through a business or other activity. 

5. “Credit Card Laundering” means: (a) presenting or depositing into, or causing or 

allowing another to present or deposit into, the credit card system for payment, a Credit Card 

Sales Draft generated by a transaction that is not the result of a credit card transaction between 

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the cardholder and the Merchant; (b) employing, soliciting, or otherwise causing or allowing a 

Merchant, or an employee, representative, or agent of a Merchant, to present or deposit into the 

credit card system for payment, a Credit Card Sales Draft generated by a transaction that is not 

the result of a credit card transaction between the cardholder and the Merchant; or (c) obtaining 

access to the credit card system through the use of a business relationship or an affiliation with a 

Merchant, when such access is not authorized by the Merchant Account agreement or the 

applicable credit card system. 

6. “Credit Card Sales Draft” means any record or evidence of a credit card transaction. 

7. “Corporate Defendant(s)” means Dahm International, LLC; Dominion of Virgo, 

Investments, Inc.; Essent Media, LLC; EVI, LLC; Nemrow Consulting, LLC; Novus North, 

LLC; Purple Buffalo, LLC; 365DailyFit, LLC; Vensure International, LLC; and their 

subsidiaries, affiliates, successors, and assigns. 

8. “Essent Defendant(s)” means the Corporate Defendants and the Individual Defendants. 

9. “Financial Institution” means any institution the business of which is engaging in 

financial activities as described in section 4(k) of the Bank Holding Company Act of 1956, 12 

U.S.C. § 1843(k). An institution that is significantly engaged in financial activities is a Financial 

Institution. 

10. “Individual Defendant(s)” means Jessica Bjarnson, Phillip Edward Gannuscia II, 

Richard Scott Nemrow, Jeffrey Nicol, and Thomas J. Riskas III. 

11. “Investment Opportunity” means anything, tangible or intangible, that is offered, 

offered for sale, sold, or traded based wholly or in part on representations, either express or 

implied, about past, present, or future income, profit, or appreciation. 

12. “Merchant” means a Person who is authorized under a written contract with an Acquirer 

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to honor or accept credit cards, or to transmit or process for payment credit card payments, for 

the purchase of products. 

13. “Merchant Account” means any account with an Acquiring Bank or other Financial 

Institution, service provider, payment processor, independent sales organization, or other entity 

that enables an individual, a business, or other organization to accept payments of any kind. 

14. “Payment Processing” means providing a Person, directly or indirectly, with the means 

used to charge or debit accounts through the use of any payment mechanism, including remotely 

created payment orders, remotely created checks, ACH debits, or debit, credit, prepaid, or stored 

value cards. Whether accomplished through the use of software or otherwise, payment 

processing includes, among other things: (a) reviewing and approving merchant applications for 

Payment Processing services; (b) providing the means to transmit sales transactions data from 

Merchants to Acquiring Banks or other Financial Institutions; (c) clearing, settling, or 

distributing proceeds of sales transactions from Acquiring Banks or Financial Institutions to 

Merchants; or (d) processing chargebacks or returned remotely created payment orders, remotely 

created checks, or ACH checks. 

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

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

government or governmental subdivision or agency, or any other group or combination acting as 

an entity. 

16. “Settled Defendant(s)” means Apply Knowledge LLC; eVertex Solutions LLC; 

Supplier Source LLC; VI Education LLC; David Gregory Bevan; and Kenneth Sonnenberg. 

17. “Telemarketing” means a plan, program, or campaign which is conducted to induce the 

purchase of goods or services or a charitable contribution, by use of one or more telephones and 

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which involves more than one interstate telephone call. Provided, however, that with regard to 

Defendant Nicol, Telemarketing does not include such calls made for the purpose of offering 

home loans to the public. 

I. 

PROHIBITIONS RELATED TO THE SALE OF BUSINESS COACHING PROGRAMS 

AND INVESTMENT OPPORTUNITIES 

IT IS ORDERED that each Essent Defendant is hereby permanently restrained and 

enjoined from: 

A. Creating, advertising, marketing, promoting, offering for sale, or selling, or Assisting 

Others in creating, advertising, marketing, promoting, offering for sale, or selling any Business 

Coaching Program or any Investment Opportunity; 

B. Creating, advertising, marketing, promoting, offering for sale, or selling, or Assisting 

Others in creating, advertising, marketing, promoting, offering for sale, or selling Add-on 

Services in connection with a Business Coaching Program or an Investment Opportunity, such as 

website development and hosting products, social media promotion products, search engine 

optimization products, and business education, training, formation, and development products; 

C. Holding, directly or through a third-Person, any ownership or other financial interest in 

any business entity that is creating, advertising, marketing, promoting, offering for sale, or 

selling, or that Assists Others in creating, advertising, marketing, promoting, offering for sale, or 

selling any Business Coaching Program, any Investment Opportunity, any Add-on Services, or 

any product to assist in the creation or development of a Business Coaching Program or an 

Investment Opportunity. 

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II. 

PROHIBITION ON TELEMARKETING 

IT IS FURTHER ORDERED that each Essent Defendant is hereby permanently 

restrained and enjoined from Telemarketing or Assisting Others in Telemarketing. 

III. 

PROHIBITIONS RELATED TO MERCHANT ACCOUNTS 

IT IS FURTHER ORDERED that each Essent Defendant is hereby permanently 

restrained and enjoined from: 

A. Credit Card Laundering; 

B. Making, or Assisting Others in making, directly or by implication, any false or 

misleading statement in order to obtain Payment Processing services; and 

C. Engaging in any tactics to avoid fraud and risk monitoring programs established by any 

Financial Institution, Acquiring Bank, or the operators of any payment system, including tactics 

such as balancing or distributing sales transactions among multiple Merchant Accounts or 

merchant billing descriptors; splitting a single sales transaction into multiple smaller 

transactions; or using shell companies to apply for a Merchant Account. 

IV. 

MONETARY JUDGMENT 

A. Judgment in the amount of Nineteen Million, Two Hundred Fourteen Thousand, Nine 

Hundred Fifty Dollars and Forty Cents ($19,214,950.40) is entered in favor of the Commission 

against the Essent Defendants, jointly and severally as equitable monetary relief. 

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B. The Individual Defendants are ordered to make the following payments to the FTC by 

electronic fund transfer in accordance with instructions to be provided by a representative of the 

Commission: 

1. Defendants Jessica Bjarnson and Phillip Edward Gannuscia II shall, within seven (7) 

calendar days of entry of this Order, pay the Commission $354,200, and within thirty 

(30) calendar days of entry of this Order, pay the Commission an additional $250,000, 

and within sixty (60) calendar days of entry of this Order, pay the Commission an 

additional $250,000 for a total payment of $854,200. 

2. Defendant Richard Scott Nemrow shall pay the Commission $160,800 within seven (7) 

calendar days of entry of this Order. 

3. Defendant Thomas J. Riskas III shall pay the Commission $12,000 within seven (7) 

calendar days of entry of this Order. 

4. Defendant Jeffrey Nicol shall pay the Commission $2,000 within seven (7) calendar 

days of entry of this Order. 

C. In partial satisfaction of the judgment against the Essent Defendants: 

1. Bank of American Fork is ordered to transfer all funds held in account XXX , in 

the name of N.B. Real Estate Holdings LLC, to the Commission by electronic funds 

transfer in accordance with instructions provided by the Commission. The funds shall 

be transferred within seven (7) days of entry of this Order. 

2. Base Commerce LLC, d/b/a Phoenix Payments, is ordered to transfer all funds held in 

the accounts identified on Attachment A to this Order to the Commission by electronic 

funds transfer in accordance with instructions provided by the Commission. The funds 

shall be transferred within seven (7) days of entry of this Order. 

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3. Capital Community Bank is ordered to transfer all funds held in accounts XXXX 

and XXXX3191, in the name of Essent Media LLC, to the Commission by electronic 

funds transfer in accordance with instructions provided by the Commission. The funds 

shall be transferred within seven (7) days of entry of this Order. 

4. Evo Payments International, d/b/a EVO Merchant Services, LLC, is ordered to transfer 

all funds held in the accounts identified on Attachment B to this Order to the 

Commission by electronic funds transfer in accordance with instructions provided by 

the Commission. The funds shall be transferred within seven (7) days of entry of this 

Order. 

5. First Data Corporation is ordered to transfer all funds held in the accounts identified on 

Attachment C to this Order to the Commission by electronic funds transfer in 

accordance with instructions provided by the Commission. The funds shall be 

transferred within seven (7) days of entry of this Order. 

6. Global Merchant Advisors is ordered to transfer all funds held in the accounts identified 

on Attachment D to this Order to the Commission by electronic funds transfer in 

accordance with instructions provided by the Commission. The funds shall be 

transferred within seven (7) days of entry of this Order. 

7. Global Payments Direct is ordered to transfer all funds held in account number 

XXXXXXXXXXXX , in the name of Reveel International LLC, to the 

Commission by electronic funds transfer in accordance with instructions provided by 

the Commission. The funds shall be transferred within seven (7) days of entry of this 

Order. 

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8. Mountain America Credit Union is ordered to transfer all funds held in the accounts 

identified on Attachment E to this Order to the Commission by electronic funds transfer 

in accordance with instructions provided by the Commission. The funds shall be 

transferred within seven (7) days of entry of this Order. 

9. U.S. Bank is ordered to transfer all funds held in accounts XXXXXXXX and 

XXXXXXXX , in the name of At Home Business LLC, to the Commission by 

electronic funds transfer in accordance with instructions provided by the Commission. 

The funds shall be transferred within seven (7) days of entry of this Order. 

10. Utah Community Credit Union is ordered to transfer all funds held in the accounts 

identified on Attachment F to this Order to the Commission by electronic funds transfer 

in accordance with instructions provided by the Commission. The funds shall be 

transferred within seven (7) days of entry of this Order. 

11. Citibank, N.A. is ordered to transfer to the Commission all funds held in the accounts 

identified on Attachment G to this Order and all funds in any other accounts not listed 

on Attachment G that are currently frozen at Citibank in connection with this case. The 

funds shall be transferred by electronic funds transfer, in accordance with instructions 

provided by the Commission, within seven (7) days of entry of this Order. 

D. Upon the completion of all payments listed in subparagraphs B and C of this Section, the 

remainder of the judgment is suspended as to the Essent Defendants, subject to 

the Subsections below. 

E. The Commission’s agreement to this Order is expressly premised upon the promise by 

the Essent Defendants to make payments timely as described in Subsections B and C above. If, 

upon motion by the Commission, the Court finds that an Essent Defendant has defaulted on any 

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obligation to make a payment as required by this Order, then the judgment becomes immediately 

due as to that Defendant in the amount specified in Subsection A above, less any payment 

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

Order. 

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

premised upon the truthfulness, accuracy, and completeness of the Essent Defendants’ sworn 

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

to the Commission, namely: 

1. the Financial Statement of Individual Defendant Jessica Bjarnson, dated February 2, 

2018, including the attachments related to items 9, 12, 14, 19, and 23 of the Statement, 

the joint federal and state tax returns of Jessica Bjarnson and Phillip Edward Gannuscia II 

for 2015 and 2016, and all other documents that Ms. Bjarnson or Mr. Gannuscia 

produced to the Commission in February 2018; 

2. the Financial Statement of Individual Defendant Phillip Edward Gannuscia II, dated 

February 8, 2018, including the attachments related to items 9, 12, 14, 19, and 23 of the 

Statement, the joint federal and state tax returns of Jessica Bjarnson and Phillip Edward 

Gannuscia II for 2015 and 2016, and all other documents that Mr. Gannuscia or Ms. 

Bjarnson produced to the Commission in February 2018; 

3. the Financial Statement of Individual Defendant Richard Scott Nemrow, dated February 

20, 2018, a divorce decree concerning Mr. Nemrow dated October 26, 2015, documents 

related to the ownership of a Centurion boat disclosed on Mr. Nemrow’s Statement, and 

all other documents that Mr. Nemrow produced to the Commission in February 2018; 

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4. the Financial Statement of Individual Defendant Jeffrey Nicol, dated February 16, 2018, 

federal and state tax returns for Mr. Nicol for 2014 and 2015, and all other documents 

that Mr. Nicol produced to the Commission in February 2018; 

5. the Financial Statement of Individual Defendant Thomas J. Riskas III, dated February 2, 

2018, joint federal and state tax returns for Mr. Riskas and his wife for 2014, 2015, and 

2016, and all other documents that Mr. Riskas produced to the Commission in February 

2018; 

6. the Financial Statement of Corporate Defendant Dahm International LLC, dated February 

9, 2018; 

7. the Financial Statement of Corporate Defendant Dominion of Virgo Investments, Inc., 

dated February 7, 2018, and attachments thereto; 

8. the Financial Statement of Corporate Defendant Essent Media LLC, dated February 7, 

2018, and attachments thereto; 

9. the Financial Statement of Corporate Defendant EVI LLC, d/b/a Members Learning 

Center, dated February 12, 2018, and attachment thereto; 

10. the Financial Statement of Corporate Defendant Nemrow Consulting LLC, dated 

February 20, 2018; 

11. the Financial Statement of Corporate Defendant Novus North LLC, d/b/a MyMentoring, 

Yes International LLC, and Your eCommerce Support International LLC, dated February 

7, 2018; 

12. the Financial Statement of Corporate Defendant Purple Buffalo LLC, d/b/a/ 

NetMarketing, dated February 9, 2018, and attachment thereto; 

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13. the Financial Statement of Corporate Defendant 365DailyFit LLC, d/b/a Net Training, 

dated February 9, 2018; and 

14. the Financial Statement of Corporate Defendant Vensure International LLC, dated 

February 9, 2018, and attachments thereto. 

G. The suspension of the judgment will be lifted as to any Essent Defendant if, upon motion 

by the Commission, the Court finds that he or she 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. If the suspension of the judgment is lifted, the 

judgment becomes immediately due as to that Defendant in the amount specified in Subsection A 

above less any payment previously made pursuant to this Section, plus interest computed 

from the date of entry of this Order. 

H. The Essent Defendants relinquish 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. 

The Essent Defendants relinquish dominion and all legal and equitable right, title, and interest in 

all assets of eCommerce Support LLC, and may not seek the return of any such assets, including 

those held in accounts XXXX , XXXX , XXXX , and XXXX at U.S. Bank, 

those held in account XXXX at Wells Fargo Bank, and approximately $47,613 held in trust 

at Ray Quinney & Nebeker, counsel for the Essent Defendants. 

I. 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 Commission, including in a proceeding to 

enforce their rights to any payment or monetary judgment pursuant to this Order, such as a 

nondischargeability complaint in any bankruptcy case. 

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J. The facts alleged in the 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. 

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

K. The Essent Defendants acknowledge that their Taxpayer Identification Numbers 

(Social Security Numbers or Employer Identification Numbers), which the Essent Defendants 

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. 

L. All money paid to the FTC 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 funds for such other equitable relief (including consumer information remedies) as it 

determines to be reasonably related to the unlawful acts or practices alleged in the Complaint. 

Any money not used for such equitable relief is to be deposited to the U.S. Treasury as 

disgorgement. The Essent Defendants have no right to challenge any actions the Commission or 

its representatives may take pursuant to this Subsection. 

V. 

BAN ON USE OF CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that the Essent Defendants and their 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: 

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A. Failing to provide sufficient customer information to enable the Commission, or its 

designee, to efficiently administer consumer redress. If a representative of the Commission 

requests in writing any information related to redress, the Essent Defendants must provide it, in 

the form prescribed by the Commission, within fourteen (14) calendar days. 

B. Disclosing, using, or benefitting from customer information derived from the sale of a 

Business Coaching Program or an Investment Opportunity, including the name, address, 

telephone number, e-mail address, Social Security number, other identifying information, or any 

data that enables access to a consumer’s account (including a credit card, bank, or other financial 

account), or would otherwise allow assessment of a charge against a consumer’s account; and 

C. Failing to dispose of customer information, in all forms, related to the sale of a Business 

Coaching Program or an Investment Opportunity that is in the Essent Defendants’ possession, 

custody, or control within forty-five (45) calendar days after receipt of written direction to do so 

from a representative of the FTC. Disposal shall be by means that protect against unauthorized 

access to consumer information, such as by burning, pulverizing, or shredding any papers, and 

by erasing or destroying any electronic media, to ensure that consumer information cannot 

practicably be read or reconstructed. 

 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 a law, regulation, or 

court order. 

VI. 

ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that the Essent Defendants obtain acknowledgments of receipt of 

this Order: 

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A. Each Essent Defendant, within seven (7) calendar 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 five (5) years after entry of this Order, each Individual Defendant for any business 

that such defendant, individually or collectively with any other Essent Defendant, Settled 

Defendant, or eCommerce Support LLC, is the majority owner of or controls directly or 

indirectly, and each Corporate Defendant must deliver a copy of this Order to: (1) all principals, 

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

representatives who participate in conduct related to the subject matter of this Order; and (3) any 

business entity resulting from any change in structure as set forth in the Section of this Order 

titled Compliance Reporting. Delivery must occur within seven (7) calendar 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 an Essent Defendant delivered a copy of this 

Order, that defendant must obtain, within thirty (30) calendar days, a signed and dated 

acknowledgment of receipt of this Order. 

VII. 

COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that the Essent Defendants make timely submissions to 

the Commission: 

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

report, sworn under penalty of perjury: 

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1. Each Essent 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 Essent Media Defendant, Settled Defendant, or eCommerce 

Support LLC (which each Individual Defendant must describe if that defendant knows or 

should know of the involvement due to that defendant’s own involvement in the 

business); (d) describe in detail whether and how that 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 Commission. 

2. Additionally, each Individual Defendant must: (a) identify all telephone numbers 

and all physical, postal, email and internet addresses, including all residences; (b) identify 

all business activities, including any business for which that defendant performs services 

whether as an employee or otherwise and any entity in which that defendant has any 

ownership interest; and (c) describe in detail that defendant’s involvement in each such 

business, including defendant’s title, role, responsibilities, participation, authority, 

control, and any ownership. 

B. For ten (10) years after entry of this Order, each Essent Defendant must submit a 

compliance notice, sworn under penalty of perjury, within fourteen (14) calendar days of any 

change in the following: 

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1. Each Essent Defendant must report any change in: (a) any designated point of 

contact; or (b) the structure of any Corporate Defendant and any entity that any 

Individual 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, each Individual Defendant must report any change in: (a) name, 

including aliases or fictitious name, or residence address; or (b) title or role in any 

business activity, including any business for which the defendant performs services 

whether as an employee or otherwise and any entity in which the defendant has any 

ownership interest, and identify the name, physical address, and any internet address of 

the business or entity. 

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

bankruptcy petition, insolvency proceeding, or similar proceeding by or against that defendant 

within fourteen (14) calendar 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 representative of the Commission 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, 

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Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin: FTC v. Apply Knowledge LLC, et al— 

Essent Defendants, X-14-0018. 

VIII. 

RECORDKEEPING 

IT IS FURTHER ORDERED that each Essent Defendant must create certain records 

for ten (10) years after entry of this Order, and retain each such record for five (5) years. 

Specifically, each Essent Defendant, for any business in which that defendant, individually or 

collectively with any other Essent Defendant, Settled Defendant, or eCommerce Support LLC, is 

a majority owner or directly or indirectly controls, must create and retain the following records: 

A. Accounting records showing the revenues from all products sold, all costs incurred in 

generating those revenues, and the resulting net profit or loss; 

B. Personnel records showing, for each Person providing services, whether as an employee 

or otherwise, that Person’s: name, addresses, and telephone numbers; job title or position; dates 

of service; and (if applicable) the reason for termination; 

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 Commission; 

E. Non-duplicate copies of any advertisement or other marketing material, including web 

pages, pop ups, email advertisements, and any audio files related to them; 

F. Records regarding ownership and control of websites used in the advertising, marketing, 

promotion, offering for sale, or sale of products; 

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Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 20 of 43 

G. Records regarding contracts for the advertisement of products; 

H. Records regarding applications and contracts for Payment Processing services; and 

I. Customer files obtained after entry of this Order, including those recorded on a customer 

relationship management database, also known as a “CRM,” showing the names, addresses, 

telephone numbers, dollar amounts paid, and the quantity of products purchased, to the extent 

such information is obtained in the ordinary course of business. 

IX. 

COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that for the purpose of monitoring each Essent 

Defendant’s compliance with this Order, including the financial representations on which part of 

the judgment was suspended: 

A. Within fourteen (14) calendar days of receipt of a written request from a representative of 

the Commission, each Essent 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 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 Essent Defendant. Each defendant must permit representatives of the Commission to 

interview any employee or other Person affiliated with that 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 any Essent 

20 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 21 of 43 

Defendant, or any individual or entity affiliated with an Essent Defendant, without the 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; and 

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

agency must furnish consumer reports concerning any Individual Defendant, pursuant to Section 

604(1) of the Fair Credit Reporting Act, 15 U.S.C. § 1681(b)(1). 

X. 

RETENTION OF JURISDICTION 

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

purposes of construction, modification, and enforcement of this Order. 

SO ORDERED, this 26th day of April, 2018. 

___________________________________ 

HON. DEE BENSON 

UNITED STATES DISTRICT JUDGE 

[The parties’ signatures follow] 

21 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 22 of 43 

1T JS SO STIPULATED AND AGREED: 

en ?Dt · abm. ~:rnadona~ Uc 

~df:if'A 

Defendaat Dominion of Virgp Investments, lnc. · 

. Defendant Essent· Media tl,C 

Dtltendant EVI tLC, d/b/a.Memben .Leal'Dmg C.~r 

~~asJ.Riswtn::U ·. ·.· .. 

Defel)cbnt Nemrow Consulting LLC 

P.a.:, ;;.;~ f\_J, l 

.1\Qmas M;.Bf~ 

BCtl,jamin ~ Davidson 

Collot~\'d 

Jr~enil Triide: Commission 

6QO ~ylV$\i~ Avenue. 'NW, CC-8528 

W~hington, DC 20580 

~ ... 326-::2061 ~cnul!)'@.ftc.gov 202--326--~l ine~~&C v 

202--326-3055 bdavidson. · gov 20Z.326-3338 .o .grsv ·i:ax:202 .. 326-3 95 

C<IUmrelforPltdntljf. Federal Trade 

Commission. ·

22 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 23 of 43 

• Ve . . . N&VUS Nol'tb L.LC, d/b/a 

: · MY Mentoring, Yes lntematioaal LLC, and 

Your eComme;rce Support inten1atlom ' LLC 

~lif1ITi,-mwara ~scia u, t1t Direct(jrof 

D(lfldJdon of Vfr~ J~, inc., Muriber 

AND 

Defendant Purpl~ Btdfhl.o LLC, d!bJa Net 

Marketing 

Defen4ant 365DaiJy.Frt LLC; d/b/a Net 

Traitdaig . 

flfr,,,y~~ft 

Defendant Vemure lnemationalLLC 

· ~&tip mw;f<iamiuscfa ff. m :m;:ect<w ~, 

DDtiifnion qf Y.irgo Investments, Jnc.. Member 

AND 

By: R.ichird-""'ll·""'S,..to-tt~N""'·~~.""'· ··-,J'-.;Os""":Owr-n-e:r.~'/M~funh,..._,,e:rof 

• Nemrcw Co»sulting uC, Member 

· Jessica Bjarlison, indivi2ka1Jy -· 

·

23 
f 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 24 of 43 

L/~a__. ~~~~ 

24 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 25 of 43 

iT IS SO S-TIPL'l.ATE:D AXD AGREED: 

oaend1u-.(Dnh_m_ln,,_..,.te-m-.· ·a--il ... 0_11_:if,.,,_,..

By: __ ..,.... ______ _ 

Jcffo,-y Ni~ol, J/etub.;,r 

Ot..i'endant Domlnicm C)f Vkgo lnve1tmtnts1 

J.ut. 

.By: r.wm - ._,,,..'r,.'- ·•- Phihip ward (fonnuso1a u, 1 )irictot 

.Defendant t;ssent Media LLC' 

Defembmt EVI LL(\ dJb/a.Memberc3 

Le·arntng Center 

L...,.LC-=---~----~----------- --

.........,.... C~ ~---S.........i..- ' N_ \ ' P. _CQnndl Mc-Nulty 

Th~zis;M,. Bfosty BcllJaill!,n R. DaVJ.dson 

Collot Guerard ., Federal Tradt Commtssfon 

600 P~nnS¥1~nia.Awnuc, NW, CC-85.2S 

Washington, OC.20580 

202~3i&:l061. pi:\\t'nultY~ifb.gov 

.202--326-3043 tbic~@ftc.g9v 202-326-3055 b.davidso1l{a;ttc.gov 

202-329~3338 cguc.tar~fre.gov Fax:202~326-3395 

Couns11,{jor Plaimiff. Federal Trade 

Ccn11t11/ssion 

[ _______ ,....__ ____ .,_~ 

.22 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 26 of 43 

.t1fc11cfa11f No,11~ North LLC, d/b/n . . M)Menierinq, Y~~ Jntcrnntton11l U,C, and · Youi' eCom.tuer~e. Support Inrer.nati-Onul 

LLC 

:Killip Edward Gan111.1sda fl. as1ilreclor of 

Dominion of Virgo lhveJtnut;rt.~, J11e,, Ucmher 

AND 

~i1dw-of 

. I)efendapt Purple Buffalo LLC, d/h/a r-;ct 

Msrk.eilng 

Defen,d~nt 3(i!)Dallyf'it LLC~ d/b/~ Net 

Training · 

-

Vefendant VM.sure bernt\t:ional LLC 

By· ~ta il""' " ~.,.- Pbiltlj, w~ · <JatuniSCJaii.. <is Diri!ctcr of 

D?n1mirm of 1 Jrgo ll1i•tM.tinenf~•. b1c., Mrmnt:r .

--- ·------ ------- ' 

23 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 27 of 43 

- 1 

,_ 

~el fur t.lJ.e .1-ssei.tt Defend,a,l;c_.s ___

I 

__________ _ J 

24 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 28 of 43 

IT iS SO STIPULATED AND AGREED: 

Intemauo. 

By=.~=--~-=------ Jeifxey Nicol, Menibet 

Defendant DomiDlon ef Virgn Investments, 

Inc. 

B]_:_.,..,_ . · PbiuipEdwafc!_oixiniis_ ·_01a_' -n;-DfM ........ -a;;;,-

Br.. . . J:>hiUtp Edward mtim,da II; 'aH NreciJr <Jf DC1ff1.inion of Virgo Jnvestment.r, btc., Member 

4Nf)· 

Defendant EVJ ~ d/b/a Members · Ce.1na:m:--

~feB.dantNemrow Consulting LLC 

:sr.~ •~ ~ T • &;;;;G;; Bic.nara.: cott cmrow, Owner. . 

P . . G;-~A_]•\) 

Thomas M. Bicsty 

=~avidson 

FedenI Trade Commission 

600 P~fl A,vf;UU~NW. CC-8528 

Washington. DC 20.580 ·. 202-321>-2061 ~'fy@ftc;gov 202-~26-3043 iesty@~.g_ov 202--326--3055 bdavio.sOil@tW.gov 

202-326-33. 3& cgμerard(a)ftc.gov Fax: 2.02-326-3395 -

Cou:nselfor Plaintiff, Federal Trade 

Commission 

__ I __ _, 

22 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 29 of 43 

:~~~!!'O!:_aro_""" · ""'Gfuiii""" · -. -118- .Cla- 1 ·""'JI,_as_Dfr_e:ctor_wef 

Domrmon, uf Y-vgo Imesttnents, Jnc.. Mttriber 

AND 

Def'endJmt 36JJ>dY.Fit ..... LLC, d/b/a Net rr.,,.,.~f...,, --,,, . .. 

Defendant Vensure ID.ernationalLLC 

!:~~£:.~r

AND 

By: . . Richard Scott Nemrow, as OWner/Memher of 

Nemruw Conaulting LLC, Monber 

2S 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 30 of 43 

. ~ 1 ~ 

· .. ,-."l ... i ' .. ·, . ~:;,. ;~. -

-'· 

,J 

\, l - · .. . ~ .. .. - ~ :•; . .,.,.;,.. ... . . 

Biett . "' .1,.. ~ .t.0-.,.'Jln ·c&.!: -------

RAYOUlNNEY & NEBEKER . 36 Stroth State Street 

Suite 1400 

Salt Lake City, UT 84111 

801-532-tSOO~com 

F.": 801-532-7543 

Counsel or the '&sent De eJtdan(j 

.

.

·

·

24 

. . ___ ,...... --.. ------------- -- --·•-·-------I , .. 

' 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 31 of 43 

IT IS SO STIPU:i.,A'fEi> AND AGREED: 

Ji>e-fen®Jtt Dominion of Virgo Investment$, 

E.no. 

DefenJant Esscot Media LLC 

~tn#r\~ir&inusdaU; -~-.--==::::: :::> a.s mrectorQf 

Dominion ofYirgo lm-estmenls, Inc., Mmiber 

AND 

·Defen&mt EVl LLC, d/b/a Mcm~ 

Learning Center 

Defendant N~row Conwltjng LI.£ 

~-C--~, ~-\ P. Connell McNuJty Thomas M. Biesty Beniamin R. Davidson 

Coffot Gnerru-d 

:Feoe-:al 'lnde Commission 

600 Pennsylva.tda A venue, NW. CC4523 

Washington, DC 20580 

202-326-2061 pmcnu.lty@ftc.gov 202:-326-3043 tbi~~;g()V 202-326-3055 bdaviclson@ltc.gov 202-326-3338 cguerard~;gov Fax; 202-326-3395 · 

Counsel far Plai:ntiff, Fedel'Ol TradJJ 

C¢mmwion 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 32 of 43 

AND 

By:,..~~.":li ....... - . . --~-~ Rkmu:a -~ N~~ OJ vwner!. .:mber I of Ne.mrow Consulting LLC, Member 

Defendant Purple Buffalo LLC, d/bla Net 

Marketiag 

·-

!Se~dot 36SDJa:ly.Fi-t I.LC, d/b/a Net 

1:rabling · 

By: 

Jet'frej Nicol. Member 1 

fl i.l .1' · . • ·-· nmcia If;"as""Diredor of 

Do,mnion ofYtrgo Imestments, -Inc.> }.{ember 

AND 

By: . . 

Richard Scott Nemrow, as Owner/Member of 

Nel!11'Q.W Co11.f.U/ting LLC, J,,/e,nber 

23 
Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 33 of 43 

fiiomas J .. .RWm& m> Ji,mf; 

·' 

-·---------

24 
 

I 

A B C 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER

2 Base Commerce, d/b/a Phoenix Payments At Home Business XXXXXXXXXXXX 

Bull Mountain My Web

3 Base Commerce, d/b/a Phoenix Payments Mkting XXXXXXXXXXXX4 Base Commerce, d/b/a Phoenix Payments Dham International XXXXXXXXXXXX5 Base Commerce, d/b/a Phoenix Payments Ecommerce Ventures LLC XXXXXXXXXXXX6 Base Commerce, d/b/a Phoenix Payments Emblem 32 LLC XXXXXXXXXXXX7 Base Commerce, d/b/a Phoenix Pa

yments Global Mentors LLC XXXXXXXXXXXX

8 Base Commerce, d/b/a Phoenix Pa

yments Home Workin

g LLC XXXXXXXXXXXX

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 34 of 43 

Attachment A to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

A B C 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

Evo Payments International, dba EVO

2 Merchant Services LLC IWSOLUTIONS18887721321 XXXXXXXX

Evo Payments International, d/b/a EVO

3 Merchant Services LLC 

M

yMentor8552885894 XXXXXXXX

Evo Payments International, d/b/a EVO

4 Merchant Services LLC Purple Buffalo LLC XXXXXXXX

I 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 35 of 43 

Attachment B to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

I 

A B C 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER

2 First Data Corporation COPPER MOSAIC LLC XXXXXXXXXXX3 First Data Corporation GORILLA MASK LLC XXXXXXXXXXX4 First Data Corporation GREEN WHISPER LLC XXXXXXXXXXX5 First Data Corporation MUSTACHE SALAD LLC XXXXXXXXXXX6 First Data Corporation NEON SYMPHONY LLC XXXXXXXXXXX7 First Data Corporation ULTIMATE CHASTITY LLC XXXXXXXXXXX8 First Data Corporation YETI POINT LLC XXXXXXXXXXX9 First Data Corporation YUKON FLATS LLC XXXXXXXXXXX

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 36 of 43 

Attachment C to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

I 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 37 of 43 

A B C 

1 FINANCIAL INSTITUTION 

Global Merchant Advisors 

ACCOUNT NAME 

Online Endeavors LLC 

ACCOUNT NUMBER

XXXXXXXXXXXX

23 Global Merchant Advisors HOME WORKING LLC XXXXXXXXXXXX4 Global Merchant Advisors HOME WORKING LLC XXXXXXXXXXXX

Attachment D to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

I 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 38 of 43 

A B C 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

2 Mountain America Credit Union 

At Home Business, LLC XXX 

3 Mountain America Credit Union 

At Home Business, LLC XXX 

4 Mountain America Credit Union E-Comm Trainin

g Lab XXX 

5 Mountain America Credit Union E-Comm Trainin

g Lab XXX 

6 Mountain America Credit Union E-Comm Trainin

g Lab XXX 

7 Mountain America Credit Union Home Workin

g, LLC XXX 

8 Mountain America Credit Union Home Workin

g, LLC XXX 

9 Mountain America Credit Union Home Workin

g, LLC XXX 

10 Mountain America Credit Union Homebound Learnin

g, LLC XXX 

11 Mountain America Credit Union Homebound Learnin

g, LLC XXX 

12 Mountain America Credit Union Homebound Learnin

g, LLC XXX 

13 Mountain America Credit Union Purple Buffalo LLC XXX 14 Mountain America Credit Union Purple Buffalo LLC XXX 15 Mountain America Credit Union Purple Buffalo LLC XXX 

Rockie Mountain Solutions

16 Mountain America Credit Union LLC XXX 

Rocky Mountain Ecomm,

17 Mountain America Credit Union LLC XXX

Attachment E to Stipulated Order for Permanent Injunction and Monetary Judgment 

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

A B C 

Rocky Mountain Ecomm,

18 Mountain America Credit Union LLC XXX 

Rocky Mountain Ecomm,

19 Mountain America Credit Union LLC XXX

I 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 39 of 43 

Attachment E to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

A B C 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

2 Utah Communit

y Credit Union 365Dail

yFit (dba: Net Training) XXXXXXXX

3 Utah Communit

y Credit Union Bi

g Sk

y ECOMM LLC XXXXXXXX

4 Utah Communit

y Credit Union Dahm International LLC XXXXXXXX

5 Utah Communit

y Credit Union EARN MICROSOFT CASH LLC XXXXXXXX

6 Utah Communit

y Credit Union EVI, LLC XXXXXXXX

7 Utah Communit

y Credit Union Global Mentors LLC XXXXXXXX

8 Utah Communit

y Credit Union Goo

gle Fortune Profits XXXXXXXX

9 Utah Communit

y Credit Union MAKE GOOGLE CASH LLC XXXXXXXX

10 Utah Communit

y Credit Union NOVUS NORTH LLC XXXXXXXX

11 Utah Communit

y Credit Union ORANGE THUNDER XXXXXXXX

12 Utah Communit

y Credit Union REVEEL INTL., LLC XXXXXXXX 

Rockie Mountain Solutions LLC (My

13 Utah Communit

y Credit Union CEO Salary) XXXXXXXX

14 Utah Communit

y Credit Union VENSURE INTL. LLC XXXXXXXX

I 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 40 of 43 

Attachment F to Stipulated Order for Permanent Injunction and Monetary Judgment

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
A B C I 

1 FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

2 Citibank, N.A. Ecommerce Ventures LLC XXXXXX 

3 Citibank, N.A. Cardready LLC XXXXXX 

4 Citibank, N.A. Purple Buffalo XXXXXX 

5 Citibank, N.A. RAFIMO ONLINE XXXXXX 

6 Citibank, N.A. BRK PLUS LLC XXXXXX 

7 Citibank, N.A. BIG SKY ECOMM XXXXXX 

8 Citibank, N.A. BIZ RULEZ XXXXXX 

9 Citibank, N.A. BIZ RULEZ #2 XXXXXX 

10 Citibank, N.A. BLUE MAGICIAN XXXXXX 

11 Citibank, N.A. BRASS OYSTER XXXXXX 

12 Citibank, N.A. BULL MOUNTAIN 2 XXXXXX 

13 Citibank, N.A. CHARITY VINE 2 XXXXXX 

14 Citibank, N.A. CHOC STARFISH#2 XXXXXX 

15 Citibank, N.A. ECOMMERCE EDUCA XXXXXX 

16 Citibank, N.A. E-COMM TRAINING XXXXXX 

17 Citibank, N.A. FORTY BLUE 2 XXXXXX 

18 Citibank, N.A. FOUNTAIN SERV XXXXXX 

19 Citibank, N.A. FRIENDLY INS#2 XXXXXX 

20 Citibank, N.A. GENERATOR 47 #2 XXXXXX 

21 Citibank, N.A. GLOBAL MENTORS XXXXXX 

22 Citibank, N.A. HMK INTERNET XXXXXX 

23 Citibank, N.A. HMK INTERNET #2 XXXXXX 

24 Citibank, N.A. 1JEK #1 XXXXXX 

25 Citibank, N.A. J HUNTER XXXXXX 

26 Citibank, N.A. JASMIN WEB XXXXXX 

27 Citibank, N.A. KF ELITE XXXXXX 

28 Citibank, N.A. KARMA ACRE #2 XXXXXX 

29 Citibank, N.A. KARMA ACRE #4 XXXXXX 

30 Citibank, N.A. KINETIC WINGS#2 XXXXXX 

31 Citibank, N.A. KOHANOF GLOBAL XXXXXX 

32 Citibank, N.A. LATERAL BEACH 2 XXXXXX 

33 Citibank, N.A. LONDON NECTAR 2 XXXXXX 

34 Citibank, N.A. MAROON WISDOM#2 XXXXXX 

35 Citibank, N.A. MAROON WISDOM#4 XXXXXX 

36 Citibank, N.A. MARTINEZ WEB XXXXXX 

37 Citibank, N.A. METRO PATRIOT#2 XXXXXX 

38 Citibank, N.A. MONTANO WEB XXXXXX 

39 Citibank, N.A. OSCAL PRODUCTS XXXXXX 

40 Citibank, N.A. OUTFIT 7 #2 XXXXXX 

41 Citibank, N.A. PHOENIX ONLINE XXXXXX 

42 Citibank, N.A. PHOENIX #2 XXXXXX 

43 Citibank, N.A. PORCELAIN RYE XXXXXX 

44 Citibank, N.A. RJ ASH XXXXXX 

45 Citibank, N.A. RJ ASH #2 XXXXXX 

46 Citibank, N.A. RJ ASH #3 XXXXXX 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 41 of 43 

Attachment G to Stipulated Order for Permanent Injunction and Monetary Judgment 

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
 

I 

1 

A B C 

FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

Citibank, N.A. ROCKY MOUNTAIN XXXXXX 

Citibank, N.A. SAMA GROUP LLC XXXXXX 

Citibank, N.A. THIRD CAPTAIN XXXXXX 

Citibank, N.A. TOROS SERVICES XXXXXX 

Citibank, N.A. URBAN MATADOR#1 XXXXXX 

Citibank, N.A. URBAN MATADOR#2 XXXXXX 

Citibank, N.A. VANILLA TAXI XXXXXX 

Citibank, N.A. VANTAGE BUS #1 XXXXXX 

Citibank, N.A. 1JEK LLC XXXXXX 

Citibank, N.A. 1JEK LLC XXXXXX 

Citibank, N.A. 2012ROBLEDO XXXXXX 

Citibank, N.A. 2Cherish LLC XXXXXX 

Citibank, N.A. 2Cherish LLC XXXXXX 

Citibank, N.A. Award Web Services LLC XXXXXX 

Citibank, N.A. BJC Ventures LLC XXXXXX 

Citibank, N.A. BJC Ventures LLC XXXXXX 

Citibank, N.A. BRK Plus LLC XXXXXX 

Citibank, N.A. BRK Plus LLC XXXXXX 

Citibank, N.A. CGROVES LLC XXXXXX 

Citibank, N.A. CGROVES LLC XXXXXX 

Citibank, N.A. CGROVES LLC XXXXXX 

Citibank, N.A. CGROVES LLC XXXXXX 

Citibank, N.A. CHERISH LLC XXXXXX 

Citibank, N.A. CHERISH LLC XXXXXX 4 

Citibank, N.A. Copper Mosaic LLC XXXXXX 

Citibank, N.A. Crizaldo Net LLC XXXXXX 

Citibank, N.A. 

CULVER ONLINE 

TRAINING LLC XXXXXX 

Citibank, N.A. DE LA ROCA XXXXXX 

Citibank, N.A. DE LA ROCA XXXXXX 

Citibank, N.A. DE LA ROCA XXXXXX 

Citibank, N.A. DG Web Services LLC XXXXXX 

Citibank, N.A. DG Web Services LLC XXXXXX 

Citibank, N.A. Digital Zebra LLC XXXXXX 

Citibank, N.A. Double A LLC XXXXXX 

Citibank, N.A. Double A LLC XXXXXX 

Citibank, N.A. Double A LLC XXXXXX 

Citibank, N.A. Franklin Resources LLC XXXXXX 

Citibank, N.A. Franklin Resources LLC XXXXXX 

Citibank, N.A. Franklin Resources LLC XXXXXX 

Citibank, N.A. Greenfield Svcs LLC XXXXXX 

Citibank, N.A. Greenfield Svcs LLC XXXXXX 

Citibank, N.A. Greenfield Svcs LLC XXXXXX 

Citibank, N.A. GROSS NET LLC XXXXXX 

Citibank, N.A. GROSS NET LLC XXXXXX 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 42 of 43 

Attachment G to Stipulated Order for Permanent Injunction and Monetary Judgment 

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah) 
I 

1 

A B C 

FINANCIAL INSTITUTION ACCOUNT NAME ACCOUNT NUMBER 

91 

92 

93 

94 

95 

96 

97 

98 

99 

100 

101 

102 

103 

104 

105 

106 

107 

108 

109 

110 

111 

112 

113 

114 

115 

116 

117 

118 

119 

120 

121 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

Citibank, N.A. ISTANALONE LLC XXXXXX 

Citibank, N.A. 

Itay S. Sales & Consulting, 

Inc. XXXXXX 

Citibank, N.A. KAMLYNN LLC XXXXXX 

Citibank, N.A. Karmell LLC XXXXXX 

Citibank, N.A. Karmell LLC XXXXXX 

Citibank, N.A. KF ELITE LLC XXXXXX 

Citibank, N.A. Kinetic Wings LLC XXXXXX 

Citibank, N.A. LARIWEB LLC XXXXXX 

Citibank, N.A. LARIWEB LLC XXXXXX 

Citibank, N.A. LARIWEB LLC XXXXXX 

Citibank, N.A. LEMAY PRODUCTS XXXXXX 

Citibank, N.A. LEMAY PRODUCTS XXXXXX 

Citibank, N.A. Mustache Salad LLC XXXXXX 

Citibank, N.A. Nilbog LLC XXXXXX 

Citibank, N.A. Oscal Products LLC XXXXXX 

Citibank, N.A. Patel Marketing LLC XXXXXX 

Citibank, N.A. Phoenix Online LLC XXXXXX 

Citibank, N.A. PinaCare LLC XXXXXX 

Citibank, N.A. Plastic Pants LLC XXXXXX 

Citibank, N.A. Prime Project LLC XXXXXX 

Citibank, N.A. RAFIMO ONLINE XXXXXX 

Citibank, N.A. RJ ASH XXXXXX 

Citibank, N.A. Sama Group LLC XXXXXX 

Citibank, N.A. Samiy Solutions LLC XXXXXX 

Citibank, N.A. SEM PROCESSING LLC XXXXXX 

Citibank, N.A. SEM PROCESSING LLC XXXXXX 

Citibank, N.A. SEM PROCESSING LLC XXXXXX 

Citibank, N.A. Sevman Marketing LLC XXXXXX 

Citibank, N.A. Sevman Marketing LLC XXXXXX 

Citibank, N.A. Sevman Marketing LLC XXXXXX 

Citibank, N.A. SG Resources LLC XXXXXX 

Citibank, N.A. SG Resources LLC XXXXXX 

Citibank, N.A. Ultimate Chastity LLC XXXXXX 

Citibank, N.A. Velvet Window LLC XXXXXX 

Citibank, N.A. 

WEITZEL RESOURCES 

LLC XXXXXX 

Citibank, N.A. Yeti Point LLC XXXXXX 

Citibank, N.A. ADL LLC XXXXXX 

Citibank, N.A. RAFIMO ONLINE XXXXXX 

Citibank, N.A. SEM PROCESSING LLC XXXXXX 

Citibank, N.A. Cardready LLC XXXXXX 

Citibank, N.A. Cardready LLC XXXXXX 

Citibank, N.A. Tri Mi XXXXXX 

Citibank, N.A. Jasmine Harris XXXXXX 

Case 2:14-cv-00088-DB Document 387 Filed 04/27/18 Page 43 of 43 

Attachment G to Stipulated Order for Permanent Injunction and Monetary Judgment 

FTC v. Apply Knowledge LLC, et al., 2:14cv88 (D. Utah)