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ALAN PHELPS 

Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

POBox 386 .= ;::, 

Washington, DC 20044 -: 0} r--

\ Z~' f'0 Telephone: 202-307-6154 I .,-.~ .. -, <-

FacsImile: 202-514-8742 '. ~ ,- c:: l _.-- z 

,E-mail: alan.phelps@usdoj.gov t.:'.:'·· I 

- ~~ . -.J ~ , -", . .J • ANDRE BIROTTE, JR. 1 

1 -u 

United States AttorneIi I f"" , -:<i: 

i r~ ~ ...... 

Central District of Ca ifornia .:..,.": Ci '; ( ... ) 

LEE WEIDMAN, AUSA I ;.,.. ':/ 

\ 

w cc ~. 

Chi~Civil Division -r ,):..1 

WE Y WEISS, AUSA ,.-i 

Chief, Civil Frauds Section 

Central District of Cali fomi a 

California State Bar No. 181073 

Room 7516, Federal Building 

300 North Los An~eles Street 

Los Angeles, CA 0012 

Telephone: ~2131894-0444 FacsImile: 213 894-2380 

E-mail: wen y.weiss@usdoj.gov 

Attorneys for Plaintiff 

THE UNITED STATES OF AMERICA 

IN THE UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF CALIFORNIA 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

SPOKEO, INC., 

I' ,,1 #"\ tl~ -- ",4;;, 0' 1 cYeiN.f.' ''01 ~~, U ~,', UM 

STIPULATION FOR ENTRY 

OF CONSENT DECREE AND 

ORDER FOR CIVIL 

PENALTIES, INJUNCTION 

AND OTHER RELIEF 

24 Defendant. 

25 

26 The parties hereby stipulate to entry of the Consent Decree, lodged 

27 concurrently, a copy of which is attached hereto as Exhibit 1, without further 

28 notice or hearing. 

Stipulation for Entry 

-';" 

~--- , 

'71 

~.:J 
1 OF COUNSEL: 

FEDERAL TRADE COMMISSION 

2 

MONIQUE EINHORN 

3 Attorney 

600 Pennsylvania Avenue, NW 

4 Washington), DC 20580 

202-326-25/5 

5 

6 JAMIEHlNE 

Attorney 7 Federal Trade Commission 

600 Pennsylvania Avenue, NW 

8 Washington A DC 20580 

202-326-21<58 

9 

10 KATHERINE ARMSTRONG 

Attorney 

11 Federal Trade Commission 

600 Pennsylvania Avenue, NW 

12 Washington~ D.C. 20580 

202-326-32JO 

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FOR PLAINTIFF THE UNITED 

STATES OF AMERICA: 

STUART F. DELERY 

Acting Assistant Attorney General, 

Civil Division 

U.S. DEPARTMENT OF JUSTICE \ 

ANDRE BIROTTE, JR. 

g:\~~l ~i~~;i~~fC:llfQrni_a LEE.WEIDMAN, AUSA 

Chief, Civil Division 

/JJ,(jA .~ WENDY L. WEISS A~SA 

Chief, Civil Frauds Section 

Central District of California 

California State Bar No. 181073 

Room 7516, Federal Building 300 North Los Angeles Street 

Los Angeles, CA 90012 

Telephone: 213-894 ... 0444 

wendy. weiss@usdoj.gov 

MICHAEL S. BLUME 

Director 

Consumer Protection Branch 

({{;,~ N LPS '-3 ,tC{-Mt-~ Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

PO Box 386 

Washington, DC 20044-0386 

Telephone: 202-307-6154 

alan.phelps@usdoj.gov 

Stipulation for Entry Page 2 of A" 
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Stipulation for Ehtry 

FOR. DEFENbANTsportEOINC,~ .. .. ... .... .. ...., .. c.. 

EiARtUSON·· .. President . ~ .. (j'lnc . .. ~ . . 

. . 

.:: . . ....... ....:;.:. . :; .. " s 

. ". ",: ... ' ' .. :" .. 

.... ~~ A1'1PReWSE\WIN ..... 

~gf~J. ~StPtfaIrf£IN Attoffi¢Y$ .....•... 

Foley8ELardner >LLJ? ... . .. 

~2r.h·~~.~:~b.·.; .. ·~ .• ··.~~Q.o ... ~.Y~Y8~O Counsel for Spokeo, Inc. 

Pacre o 3 of . 4"" 
Exhibit 1 
1 

ALAN PHELPS 

2 Trial Attorney Consumer Protection Branch 

3 U.S. Dep'artment of Justice 

PO Box 386 . 4 Washington, PC 20044 

Teleph9ne: 202~307-6154 

5 FacsImIle: 202 ... 514-:-8742 

E-mail: alan.phelps@usdQj.gov 

ANDRE BIROTTE, JR. . 7 United States Attorney. Central District of California 

8 LEE WEIDMAN AUSA . 

6 

Chi~L Civil Division 

9 WEr·.juY WEISS, AUSA 

Chief, Civil Frauds Section 

10 Central District of California 

California State Bar No. 181073 

11 Room 7516, Federal Building 300 North Los Angeles Street 

12 Los Angeles, CA 90012 

Telephone: ~13) 894-0444 

13 FacsImile-: 13) 894-2380 

E-mail: wen y.weiss@usdoj.gov 14 

15 

Attorneys for Plaintiff . THE UNITED STATES OF AMERICA 

16 IN THE UNITED STATES DISTRICT COURT 

17 FOR THE CENTRAL DISTRICT OF CALIFORNIA 

18 Case No. --------" 

19 UNITED STATES OF AMERICA, 

20 

21 

22 

23 

24 

25 

v. 

SPOKEO, INC., 

Plaintiff, 

Defendant. 

CONSENT DECREE AND 

ORDER FOR CIVIL 

PENALTIES, ~NJUNCTION 

AND OTHER RELIEF 

26 Plaintiff, the United States of America, acting upon notification and 

27 authorization to the Attorney General by the Federal Trade Commission 

28 ("FTC" or "Commission"), is concurrently filing its Complaint herein, which 

Consent Decree Page 1 of 15 

EXHIBI -
1 alleges that Defendant Spokeo, Inc. ("Spokeo") has engaged in violations of 

2 the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681-1681x, and in 

3 unfair or deceptive acts or practices in violation of Section 5 of the Federal 

4 Trade Commission Act ("FTC Act"), 15 U.S.C. § 45(a). Defendant has been 

5 represented by the attorneys whose names appear hereafter. The parties have 

6 agreed to entry of this Stipulated Final JUdgment and Order for Civil Penalties, 

7 Permanent Injunction, and Other Equitable_Relief ("Oider") to resolve all 

8 matters in dispute in this action without trial or adjudication of any issue of law 

9 or fact herein and without Defendant admitting the truth of, or liability for, any 

-10 of the matters alleged in the Complaint. Defendant has waived service of the 

11 Summons and Complaint. 

12 THEREFORE, IT IS HEREBY ORDERED, ADJUDGED, AND 

13 DECREED as follows: 

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FINDINGS 

This Court has jurisdiction over the subject matter of this case and over 

the Parties. 

Venue in this district is proper under 28 U.S.C. §§ 1391(b) - (c), 28 

U.S.C. § 1395(a), and 15 U.S.C. § 53(b). 

The Complaint states claims upon which relief may be granted against 

Defendant under sections 5(a), 13(b), and 16(a) of the Federal Trade 

Commission Act, 15 U.S.C. §§ 45(a), 53(b), and 56(a); and under 

sections 604, 607(a), 607(d), and 621 of the Fair Credit Reporting Act, 

15 U.S.C. §§ 1681b, 1681e(a), 1681e(d), and 1681s. 

Defendant makes no admissions to the allegations in the Complaint, 

other than the jurisdictional facts. 

Defendant waives: (a) all rights to seek appellate review or otherwise 

challenge or contest the validity of this Order; (b) any claims Defendant 

may have against the Commission, its employees, representatives, or 

Consent Decree Page 2 of 15 

EXHIBr I. 
1 agents that relate to the matter stated herein; (c) all claims under the 

2 Equal Access to Justice Act, 28 U.S.C. § 2412, as amended by.Pub. L. 

3 104-121, 110 Stat. 847, 863-64 (1996); and (d) any rights to attorneys' 

4 fees that may arise under said provision of law. 

5 6. This action and the relief awarded herein are in addition to, and not in 

6 lieu of, other remedies as may be provided by law, including both civil 

T and criminal remedies. 

8 7. Entry of this Order is in the public interest. I 

9 8. F or the purpose of this Order: 

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a. 

b. 

c. 

d. 

e. 

f. 

"Defendant" means Spokeo, Inc., and its successors and assigns; 

"Permissible purpose" shall mean the circumstances under which a 

consumer report may be furnished as described in Section 604 of 

the Fair Credit Reporting Act, 15 U.S.C. § 1681b; 

The definitions set forth in the FCRA, 15 U.S.C. §§ 1681a, et seq., 

shall apply; 

"Material connection" shall mean any relationship that materially 

affects the weight or credibility of any endorsement and that 

would not be reasonably expected by consumers; 

"Endorsement" shall mean as defined in the Commission's Guides 

Concerning the Use of Endorsements and Testimonials in 

Advertising, 16 C.F.R. § 255.0; and 

"Clear and prominent" shall mean: 

1. In textual communications (e.g., printed pUblications or 

words displayed on the screen of a computer), the required 

disclosures are of a type, size, and location sufficiently 

noticeable for an ordinary consumer to read and 

comprehend them, in print that contrasts with the 

background on which they appear; 

Consent Decree Page 3 of 15 

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11. In communications disseminated orally or through audible 

means (e.g., radio or streaming audio), the required 

disclosures are delivered in a volume and cadence sufficient 

for an ordinary consumer to hear and comprehend them; 

111. In communications disseminated through video means (e~g., 

IV. 

v. 

television or streaming video), the required disclosures are 

in writing in a form consistent with subparagraph (i) of this. 

definition and shall appear on the screen for a duration 

sufficient for an ordinary consumer to read and comprehend 

them, and in the same language as the predominant 

language that is used in the communication; 

In communications made through interactive media, such as 

the Internet, online services, and software, the required 

disclosures are unavoidable and presented in a form 

consistent with subparagraph (i) of this definition, in 

addition to any audio or video presentation of them; and 

In all instances, the required disclosures are presen~ed iIi an 

understandable language and syntax, and with nothing 

19 contrary to, inconsistent with, or in mitigation of the 

20 disclosures used in any communication of them. 

21 ORDER 

22 I. CIVIL PENALTY 

23 IT IS ORDERED that: 

24 1. Judgment in the amount of eight hundred thousand dollars ($800,000) is 

25 hereby entered against Defendant, as a civil penalty for violations of the 

26 FCRA pursuant to section 621(a) of the Fair Credit Reporting Act, 15 

27 U.S.C. § 1681s(a). 

28 2. Defendant shall make this payment within seven (7) business days of the 

Consent Decree Page 4 of 15 

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date of service of this Order to the Treasurer of the United States by 

electronic fund transfer in accordance with instructions provided by the 

Consumer Protection Branch, Civil Division, U.S. Department of Justice, 

Washington, D.C. 20530, for appropriate disposition. 

In the. event of any default in payment,which default continues for ten . 

(10) days beyond the due date of payment, the entire unpaid penalty, 

together with interest, as computed pursuant to 28 U.S.C. § 1961 from 

the date of default to the date of payment, shall immediately become due 

and payable. 

Defendant relinquishes all dominion; control; and title to the funds paid 

to the fullest extent permitted by law. Defendant shall make no claim to 

or demand for return of the funds, directly or indirectly, through counsel 

or otherwise. 

Prior to or concurrently with Defendant's execution of this Order, 

Defendant shall turn over the full amount of the civil penalty, eight 

hundred thousand dollars ($800,000), to their attorneys, who shall hold 

the entire sum for no purpose other than payment to the Treasurer of the 

United States after entry of this Order by the Court. Within five (5) days 

of service of this Order, Defendant's attorneys shall transfer such civil 

penalty payment in the form of a wire transfer to the Treasurer of the 

United States. Written confirmation of the wire transfer shall be 

delivered in accordance with the procedures specified by the Consumer 

Protection Branch, Civil Division, U.S. Department of Justice, 

Washington, D.C. 20530. 

Defendant agrees that the facts as alleged in the Complaint filed in this 

action shall be taken as true, without further proof, in any subsequent 

civil litigation filed by or on behalf of the Commission to enforce its 

rights to any payment or money judgment pursuant to this Order. 

Consent Decree Page 5 of 15 

EXHIBI -
1 II. PROHIBITED BUSINESS ACTIVITIES - FCRA 

2 IT IS FURTHER ORDERED that Defendant, and all other persons or 

3 entities within the scope of Fed. R. Civ. P. 65, whether acting directly or 

4 through any/ sole proprietorship, partnership, limited liability company, 

5 corporation, subsidiary, branQh, division, device, or other business entity who 

6 receive actual notice of this Order by personal service or otherwise, are hereby 

7 permanently restrained and enjoined from violating the Fair Credit Reporting 

8 Act, 15 U.S.C. §§1681-1681x, in particular: 

9 1. Violating section 604 of the FCRA, 15 U.S.C. § 1681b, by furnishing a 

10 consumer report to any person-who does not have a permissible purpose 

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to receive the consumer report; 

Failing to maintain reasonable procedures designed to limit the 

furnishing of consumer reports to users that have a permissible purpose 

to receive them under section 604 of the FCRA, 15 U.S.C. § 1681b, as 

required by Section 607(a) of the FCRA, 15 U.S.C. § 1681e(a); 

Failing to maintain reasonable procedures to assure the maximum 

possible accuracy of the information concerning the individual about 

whom a consumer report relates, as required by section 607(b) of the 

FCRA, 15 U.S.C. § 1681e(b); and 

Failing to provide the "Notice to Users of Consumer Reports: 

Obligations of Users Under the FCRA" ("User Notice") required by 

section 607(d) of the FCRA, 15 U.S.C. § 1681e(d), to all users of 

Defendant's consumer reports. Provided,·however, that Defendant may 

provide an electronic copy of the User Notice to a user if: ( a) in the 

ordinary course of business, the user obtains consumer report 

information from Defendant in electronic form, and (b) the notice is clear 

and prominent. 

Consent Decree Page 6 of 15 

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III. PROHIBITED BUSINESS ACTIVITIES - SECTION 5 

(ENDORSEMENTS) 

IT IS FURTHER ORDERED that Defendant, and all other persons or 

entities within the sco:pe of Fed. R. Civ. P. 65, whether acting directly or 

through any sole proprietorship, partnership, limited liability company, . 

corporation, subsidiary, branch, division, device, or other business entity who - . 

receive. actual notice of this Order by personal service or otherwise, are hereby 

. permanently restrained and enjoined from: 

1. Misrepresenting, in any manner, expressly or by implication, the status 

of any user or endorser of a product or service, including, but not limited 

to, misrepresenting that the user or endorser is an independent user or 

ordinary consumer of the product or service; and 

2. Making any representation, in any manner, expressly or by implication, 

about any user or endorser of such product or service unless they 

disclose, clearly and prominently, a material connection, when one 

exists, between such user or endorser and the respondent or any other 

individual or entity manufacturing, advertising, labeling, promoting, 

offering for sale, selling, or distributing such product or service. 

Within seven (7) days of the date of service of this Order, Defendant shall take 

all reasonable steps to remove any product review or endorsement, currently 

viewable by the public, that does not comply with this Section. 

IV. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendant obtain acknowledgments 

of receipt of this Order: 

1. Defendant, within seven (7) days of entry of this Order, must submit to 

the Commission an acknowledgment of receipt of this Order sworn 

under penalty of perjury. 

2. For five (5) years after entry of this Order, Defendant must deliver a 

Consent Decree Page 7 of 15 

EXHIBIl -
1 copy of this Order to: (a) all principals, officers, directors, and managers; 

2 (b) all employees, agents, and representatives who participate in' conduct 

3 related to the subject matter of the Order; and (c) any business entity 

4 resulting from any change in structure as set forth in the Section titled 

5 Compliance Reporting. Delivery must occur within seven (7) daYB of 

6 entry of this Order fOr current pe.rsonneL To all others, delivery must 

1 occur before they assume their responsibilities. 

8 3. From each individual or entity to which Defendant delivered a copy of 

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

10 acknowledgment of receipt of this Order. 

11 V. COMPLIANCE REPORTING 

12 IT IS FURTHER ORDERED that Defendant make timely submissions 

13 to the Commission: 

14 1. One year after entry of this Order, Defendant must submit a compliance 

15 report, sworn under penalty of perjury. Defendant must: (a) designate at 

16 least one telephone number and an email, physical, and postal address as 

17 points of contact, which representatives of the Commission and Plaintiff 

18 may use to communicate with Defendant; (b) identify all of Defendant's 

19 businesses by all of their names, telephone numbers, and physical, 

20 postal, email, and Internet addresses; ( c) describe in detail whether and 

21 how Defendant is in compliance with each Section of this Order; and (d) 

22 provide a copy of each Order Acknowledgment obtained pursuant to this 

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24 2. 

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Order, unless previously submitted to the Commission; 

For 20 years following entry of this Order, Defendant must submit a 

compliance notice, sworn under penalty of perjury, within 14 days of any 

change in the following: ( a) any designated point of contact; or (b) the 

structure of any entity that Defendant has any ownership interest in or 

directly or indirectly controls that may affect compliance obligations 

Consent Decree Page 8 of 15 

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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. 

3. Defendant must submit to the Commission notice of the filing of any 

bankruptcy petition, insolvency proceeding, or any similar proceeding by 

or against Defendant within 14 days of its filing. 

4. 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 applicabl~)" and signature. 

5. 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. SpokeD, 

Inc. 

, VI.RECORDKEEPING, 

IT IS FURTHER ORDERED that Defendant must create certain 

records for 20 years after entry of the Order, and retain each such record for 

five (5) years. Specifically, Defendant must maintain the following records: 

1. Accounting records showing the revenues from all goods or services 

sold, all costs incurred in generating those revenues, and the resulting net 

profit or loss; 

2. Personnel records showing, for each person providing services, whether 

as an employee or otherwise, that person's: name, addresses, and 

Consent Decree Page 9 of 15 

EXHIBI 
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telephone numbers; job title or position; dates of service; and, if 

applicable, the reason for termination; 

Copies of all training materials that relate to the collection and sale of 

consumer report information; 

Copies of all training materials that relate to Defendant's activities as 

alleged in the Complaint and Defendant's compliance with the 

provisions Qfthis Order; 

8 5. All records and documents necessary to demonstrate full.compliance 

9 with each provision of this Order, including but not limited to, copies of 

-10 acknowledgments. of receipt of this Order, required by the Sections titled· 

11 "Distribution of Order" and "Acknowledgment of Receipt of Order" and 

12 all reports submitted to the FTC pursuant to the Section titled 

13 

14 6. 

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16 7. 

17 8. 

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"Compliance Reporting"; 

Complaints and refund requests, whether received directly or indirectly, 

such as through a third party, and any response; 

A copy of each advertisement or other marketing material; 

. If operating as a consumer reporting agency, files containing the names, 

addresses, telephone numbers, and permissible purpose of all entities to 

19 whom Spokeo supplies consumer reports and all materials considered by 

20 Defendant to ensure compliance with section 604 of the FCRA; 

21 9. If operating as a consumer reporting agency, files containing the names, 

22 addresses and telephone numbers of all users of consumer report 

23 information and the certifications made by the user pursuant to section 

24 607(a) of the FCRA, and all materials considered by Defendant in 

25 connection with its verification of the identity of the user and 

26 verification of the certifications made under section 607(a), to 

27 demonstrate Defendant's compliance with section 607(a) of the FCRA; 

28 and 

Consent Decree Page 10 of 15 

15 EXHIBI 
1 10. 

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3 

If operating as a consumer reporting agency, files containing the names, 

addresses, telephone numbers of all users of consumer report information 

that received the section 607( d) User Notice, and all materials considered 

4 by Defendant to demonstrate compliance with section 607(d) of the 

5 FCRA. 

6 VII. COMPLIANCE MONITORING 

7 IT IS FURTHER ORDERED that, for the purpose of monitoring 

8 Defendant's compliance with this Order, including any failure to transfer any 

9 assets as required by this Order: 

_ 10 1. Within 14 days of receipt of a written request from a representative of 

11 the Commission or Plaintiff, Defendant must: submit additional 

12 compliance reports or other requested information, which must be sworn 

13 under penalty of perjury; appear for depositions; and produce documents, 

14 for inspection and copying. The Commission and Plaintiff are also 

15 authorized to obtain discovery, without further leave of court, using any 

16 of the procedures prescribed by Federal Rules of Civil Procedure 29,30 

17 (including telephonic depositions), 31, 33, 34, 36, 45, and 69, provided 

18 that, Defendant, after attempting to resolve a dispute without court action 

19 and for good cause shown, may file a motion with this Court seeking an 

20 order including one or more of the protections set forth in Rule 26( c). 

21 2. 

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For matters'concerning this Order, the Commission and Plaintiff are 

authorized to communicate directly with Defendant. Defendant must 

permit representatives of the Commission and Plaintiff to interview any 

employee or other person affiliated with Defendant who has agreed to 

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

The Commission and Plaintiff may use all other lawful means, including 

posing, through its representatives, as consumers, suppliers, or other 

individuals or entities, to Defendant or any individual or entity affiliated 

Consent Decree Page 11 of 15 

l4 EXHIBI l 

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with 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-l. 

5 VIII. RETENTION OF JURISDICTION 

6 IT IS FURTHER ORDERED that this Court retains jurisdiction of this 

7 matter for. purposes of construction,_ modific~tion, and enforcement of this 

8 Order. 

9 IX. COSTS AND ATTORNEYS' FEES 

10 IT IS FURTHER ORDERED that each party shall bear its own costs 

11 and attorneys' fees incurred in connection with this action. 

12 The parties hereby stipulate to the entry of the foregoing Order, which 

13 shall constitute a final Order in this action. 

14 IT IS SO ORDERED: 

15 

16 Dated this ___ day of ________ , 2012 

17 

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20 

UNITED STATES DISTRICT JUDGE 

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Consent Decree Page 12 of 15 

EXHIBI -
1 FOR THE FEDERAL TRADE COMMISSION: 

·2 

3 wx--

4 MONIQUE EINHORN 

5 

6 

7 \ 

8 JAMIEHINE 

9 Attorney 

10 

12 

11 

KATHERINE 

(0{h~ ARMST;ONG 

13 Attorney 

14 

15 ~ 

16 MARK EICHORN 

11 Assistant Director 

18 

19 ~L~· 20 MANEESHA MITRAL 

21 Associate Director 

22 Division of Privacy and Identity Protection 

23 Federal Trade Commission 

24 600 Pennsylvania Avenue, NW 

25 Washington D.C. 20580 

26 Tel: (202) 326-2252 

27 Fax: (202) 326-3768 

28 

Consent Decree Page 13 of 15 EXHIBI 
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CJ::£!~ ANDREW SERWIN 

ROBERT H. GRIFFITH 

PETERF. MCLAUGHLIN 

Attorneys 

Foley & Lardner, LLP 

3000 K Street, N.W., Suite 600 

Washington, DC 20007-5109 

Counsel for Spokeo, Inc. 

Consent Decree Page 14 of 15 

II EXHIBIT ~ 
1 The parties, by their counsel, hereby consent to the terms and conditions 

2 of the Order as set forth above and consent to the entry thereof. 

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Consent Decree 

FOR PLAINTIFF 

THE UNITED STATES OF AMERICA: 

STUART F. DELERY 

Acting Assistant Attorney General, Civil Division 

U.S. DEPARTMENT-OF JUSTICE 

ANDRE BIROTTE JR. 

United States Attorney Central District of California 

LEE WEIDMAN, AUSA 

Chief, Civil Division 

Chief, 

~b~USA Ci~il J:rauds Se~tion. Central DIstnct of CalIfornIa 

California State Bar No. 181073 

Room 7516, Federal Building 300 North Los Angeles Stree1 

Los Angeles, CA 90012 

Telephone: (213) 894-0444 

E-mail: wendy.weiss@usdoj.gov 

MAAME EWUSI-MENSAH FRIMPONG 

Acting Deputy Assistant Attorney General 

MICHAEL S. BLUME 

Director 

Consumer Protection Branch 

~mJM~/~~ Trial Attorney Consumer Protection Branch 

U.S. DeRartment of Justice 

POBox 386 . Washington, DC 20044-0386 

Telephone: 202-307-6154 

alan. phelps@usdoj .gov 

Page 15 of 15 

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