Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 1 of 25 PageID 79 

UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, 

 Plaintiff,

 v. 

TEAMI, LLC, a limited liability company, 

ADI HALEVY, a/k/a Adi Arezzini, individually and

as an officer of TEAMI, LLC, and 

YOGEV MALUL, individually and as an officer of 

TEAMI, LLC, 

 Defendants. 

Case No. ____________ 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION AND 

MONETARY JUDGMENT 

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

For Permanent Injunction And Other Equitable Relief (“Complaint”), for a permanent injunction, 

and other equitable relief in this matter, pursuant to Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b). The Commission and Defendants stipulate to 

the entry of this Stipulated Order for Permanent Injunction and Monetary Judgment (“Order”) to 

resolve all matters in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

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

violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52, in connection with the 

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labeling, advertising, marketing, distribution, and sale of Teami brand tea products that 

purportedly provide various health benefits and Teami brand skincare products. 

3. 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. 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. Defendants waive all rights to appeal or otherwise challenge or contest the validity of this 

Order. 

DEFINITIONS 

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

A. “Defendants” means the Individual Defendants and the Corporate Defendant, 

individually, collectively, or in any combination. 

1. “Corporate Defendant” means Teami, LLC and its successors and assigns. 

2. “Individual Defendants” means Adi Halevy, also known as Adi Arezzini, and Yogev 

Malul. 

B. “Clear(ly) And Conspicuous(ly)” means that a required disclosure is difficult to miss 

(i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of the 

following ways: 

1. In any communication that is solely visual or solely audible, the disclosure must be made 

through the same means through which the communication is presented. In any communication 

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made through both visual and audible means, such as a television advertisement, the disclosure 

must be presented simultaneously in both the visual and audible portions of the communication 

even if the representation requiring the disclosure is made in only one means. 

2. A visual disclosure, by its size, contrast, location, the length of time it appears, and other 

characteristics, must stand out from any accompanying text or other visual elements so that it is 

easily noticed, read, and understood. 

3. An audible disclosure, including by telephone or streaming video, must be delivered in a 

volume, speed, and cadence sufficient for ordinary consumers to easily hear and understand it. 

4. In any communication using an interactive electronic medium, such as the Internet or 

software, the disclosure must be unavoidable. 

5. The disclosure must use diction and syntax understandable to ordinary consumers and 

must appear in each language in which the representation that requires the disclosure appears. 

6. The disclosure must comply with these requirements in each medium through which it is 

received, including all electronic devices and face-to-face communications. 

7. The disclosure must not be contradicted or mitigated by, or inconsistent with, anything 

else in the communication. 

8. When the representation or sales practice targets a specific audience, such as children, the 

elderly, or the terminally ill, “ordinary consumers” includes reasonable members of that group. 

C. “Close Proximity” means that the disclosure is very near the triggering representation. 

For example, a disclosure made through a hyperlink, pop-up, interstitial, or other similar 

technique is not in Close Proximity to the triggering representation. 

D. “Covered Product” means any Dietary Supplement, Food, or Drug, including Teami 

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Profit tea, Teami Alive tea, Teami Relax tea, Teami Skinny tea, Teami Colon tea, and the Teami 

30 Day Detox Pack. 

E. “Dietary Supplement” means: (1) any product labeled as a dietary supplement or 

otherwise represented as a dietary supplement; or (2) any pill, tablet, capsule, powder, softgel, 

gelcap, liquid, or other similar form containing one or more ingredients that are a vitamin, 

mineral, herb or other botanical, amino acid, probiotic, or other dietary substance for use by 

humans to supplement the diet by increasing the total dietary intake, or a concentrate, metabolite, 

constituent, extract, or combination of any ingredient described above, that is intended to be 

ingested, and is not represented to be used as a conventional food or as a sole item of a meal or 

the diet. 

F. “Drug” means: (1) articles recognized in the official United States Pharmacopoeia, 

official Homoeopathic Pharmacopoeia of the United States, or official National Formulary, or any 

supplement to any of them; (2) articles intended for use in the diagnosis, cure, mitigation, 

treatment, or prevention of disease in humans or other animals; (3) articles (other than food) 

intended to affect the structure or any function of the body of humans or other animals; and (4) 

articles intended for use as a component of any article specified in (1), (2), or (3); but does not 

include devices or their components, parts, or accessories. 

G. “Essentially Equivalent Product” means a product that contains the identical ingredients, 

except for inactive ingredients (e.g., binders, colors, fillers, excipients) in the same form and 

dosage, and with the same route of administration (e.g., orally, sublingually), as the Covered 

Product; provided that the Covered Product may contain additional ingredients if reliable 

scientific evidence generally accepted by experts in the field indicates that the amount and 

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combination of additional ingredients is unlikely to impede or inhibit the effectiveness of the 

ingredients in the Essentially Equivalent Product. 

H. “Food” means: (1) any article used for food or drink for humans or other animals; (2) 

chewing gum; and (3) any article used for components of any such article. 

I. “Unexpected Material Connection” means any relationship that might materially affect 

the weight or credibility of an endorsement and that would not reasonably be expected by 

consumers. 

ORDER 

I. PROHIBITED DISEASE AND WEIGHT-LOSS CLAIMS 

IT IS ORDERED that Defendants, Defendants’ 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 labeling, advertising, 

promotion, offering for sale, sale, or distribution of any Covered Product, are permanently 

restrained and enjoined from making, or assisting others in making, expressly or by implication, 

including through the use of a product name, endorsement, depiction, or illustration, any 

representation that such product: 

A. treats cancer; 

B. treats, prevents, or reduces the risk of heart disease, including by decreasing arterial 

plaque or improving blood flow to the heart; 

C. lowers cholesterol or blood pressure; 

D. treats, prevents, or reduces the risk of migraines; 

E. treats, prevents, or reduces the risk of colds, flus, or other illnesses; 

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F. causes or helps cause weight loss or any specific amount of weight loss; 

G. causes or helps cause rapid weight loss; 

H. causes weight loss by boosting or increasing metabolism; 

I. causes or helps cause fat loss or any specific amount of fat loss; or 

J. cures, mitigates, or treats any disease, 

unless the representation is non-misleading, and, at the time of making such representation, they 

possess and rely upon competent and reliable scientific evidence substantiating that the 

representation is true. For purposes of this Section, competent and reliable scientific evidence 

shall consist of human clinical testing of the Covered Product, or of an Essentially Equivalent 

Product, that is sufficient in quality and quantity based on standards generally accepted by experts 

in the relevant disease, condition, or function to which the representation relates, when considered 

in light of the entire body of relevant and reliable scientific evidence, to substantiate that the 

representation is true. Such testing must be: (1) randomized, double-blind, and 

placebo-controlled; and (2) conducted by researchers qualified by training and experience to 

conduct such testing. In addition, all underlying or supporting data and documents generally 

accepted by experts in the field as relevant to an assessment of such testing as described in the 

Section entitled Preservation of Records Relating to Competent and Reliable Human Clinical 

Tests or Studies must be available for inspection and production to the Commission. Persons 

covered by this Section have the burden of proving that a product satisfies the definition of 

Essentially Equivalent Product. 

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II. OTHER PROHIBITED HEALTH-RELATED CLAIMS 

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 

labeling, advertising, promotion, offering for sale, sale, or distribution of any Covered Product, 

are permanently restrained and enjoined from making, or assisting others in making, expressly or 

by implication, including through the use of a product name, endorsement, depiction, or 

illustration, any representation, other than representations covered under the Section of this Order 

entitled Prohibited Disease and Weight-Loss Claims, about the health benefits, performance, 

efficacy, safety, or side effects of any Covered Product unless the representation is 

non-misleading, and, at the time of making such representation, they possess and rely upon 

competent and reliable scientific evidence that is sufficient in quality and quantity based on 

standards generally accepted by experts in the relevant disease, condition, or function to which 

the representation relates, when considered in light of the entire body of relevant and reliable 

scientific evidence, to substantiate that the representation is true. 

For purposes of this Section, competent and reliable scientific evidence means tests, 

analyses, research, or studies (1) that have been conducted and evaluated in an objective manner 

by experts in the relevant disease, condition, or function to which the representation relates; (2) 

that are generally accepted by such experts to yield accurate and reliable results; and (3) that are 

randomized, double-blind, and placebo-controlled human clinical testing of the Covered Product, 

or of an Essentially Equivalent Product, when such experts would generally require such human 

clinical testing to substantiate that the representation is true. In addition, when such tests or 

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studies are human clinical tests or studies, all underlying or supporting data and documents 

generally accepted by experts in the field as relevant to an assessment of such testing as set forth 

in the Section entitled Preservation of Records Relating to Competent and Reliable Human 

Clinical Tests or Studies must be available for inspection and production to the Commission. 

Persons covered by this Section have the burden of proving that a product satisfies the definition 

of Essentially Equivalent Product. 

III. PRESERVATION OF RECORDS RELATING TO COMPETENT 

AND RELIABLE HUMAN CLINICAL TESTS OR STUDIES 

IT IS FURTHER ORDERED that, with regard to any human clinical test or study (“test”) 

upon which Defendants rely to substantiate any claim covered by this Order, Defendants shall 

secure and preserve all underlying or supporting data and documents generally accepted by 

experts in the field as relevant to an assessment of the test, including: 

A. All protocols and protocol amendments, reports, articles, write-ups, or other accounts of 

the results of the test, and drafts of such documents reviewed by the test sponsor or any other 

person not employed by the research entity; 

B. All documents referring or relating to recruitment; randomization; instructions, including 

oral instructions, to participants; and participant compliance; 

C. Documents sufficient to identify all test participants, including any participants who did 

not complete the test, and all communications with any participants relating to the test; all raw 

data collected from participants enrolled in the test, including any participants who did not 

complete the test; source documents for such data; any data dictionaries; and any case report 

forms; 

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D. All documents referring or relating to any statistical analysis of any test data, including 

any pretest analysis, intent-to-treat analysis, or between-group analysis performed on any test 

data; and 

E. All documents referring or relating to the sponsorship of the test, including all 

communications and contracts between any sponsor and the test’s researchers. 

Provided, however, the preceding preservation requirement does not apply to a reliably 

reported test, unless the test was conducted, controlled, or sponsored, in whole or in part by: (1) 

any Defendant; (2) any Defendant’s officers, agents, representatives, or employees; (3) any other 

person or entity in active concert or participation with any Defendant; (4) any person or entity 

affiliated with or acting on behalf of any Defendant; (5) any supplier of any ingredient contained 

in the product at issue to any of the foregoing or to the product’s manufacturer; or (6) the supplier 

or manufacturer of such product. 

For purposes of this Section, “reliably reported test” means a report of the test has been 

published in a peer-reviewed journal, and such published report provides sufficient information 

about the test for experts in the relevant field to assess the reliability of the results. 

For any test conducted, controlled, or sponsored, in whole or in part, by Defendants, 

Defendants must establish and maintain reasonable procedures to protect the confidentiality, 

security, and integrity of any personal information collected from or about participants. These 

procedures must be documented in writing and must contain administrative, technical, and 

physical safeguards appropriate to Corporate Defendant’s size and complexity, the nature and 

scope of Defendants’ activities, and the sensitivity of the personal information collected from or 

about the participants. 

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IV. FDA-APPROVED CLAIMS 

IT IS FURTHER ORDERED that nothing in this Order prohibits Defendants, Defendants’ 

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

with any of them from: 

A. For any drug, making a representation that is approved in labeling for such drug under any 

tentative final or final monograph promulgated by the Food and Drug Administration, or under 

any new drug application approved by the Food and Drug Administration; and 

B. For any product, making a representation that is specifically authorized for use in labeling 

for such product by regulations promulgated by the Food and Drug Administration pursuant to the 

Nutrition Labeling and Education Act of 1990 or permitted under Sections 303-304 of the Food 

and Drug Administration Modernization Act of 1997. 

V. PROHIBITED REPRESENTATIONS REGARDING ENDORSEMENTS 

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 

labeling, advertising, promotion, offering for sale, sale, or distribution of any product are 

permanently restrained and enjoined from making, or assisting others in making, any 

misrepresentation, expressly or by implication, about the status of any endorser or person 

providing a review of the product, including a misrepresentation that the endorser or reviewer is 

an independent or ordinary user of a product. 

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VI. REQUIRED DISCLOSURES OF MATERIAL CONNECTIONS 

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 

labeling, advertising, promotion, offering for sale, sale, or distribution of any product are 

permanently restrained and enjoined from making, or assisting others in making, any 

representation, expressly or by implication, about any endorser of such product without 

disclosing, Clearly and Conspicuously, and in Close Proximity to that representation, any 

Unexpected Material Connection between such endorser and (1) any Defendant; or (2) any other 

individual or entity affiliated with the product. 

VII. MONITORING OF ENDORSERS 

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 

labeling, advertising, promotion, offering for sale, sale, or distribution of any product by means of 

an endorsement by an endorser with a material connection to (1) any Defendant, or (2) any other 

individual or entity affiliated with the product, must take sufficient steps designed to ensure 

compliance with the Sections of this Order entitled Prohibited Representations Regarding 

Endorsements and Required Disclosures of Material Connections. Such steps must include, at a 

minimum: 

A. Providing each such endorser with a clear statement of his or her responsibilities to 

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disclose (“Statement of Disclosure Responsibilities”) Clearly And Conspicuously, and in Close 

Proximity to the endorsement, in any online video, social media posting, or other communication 

endorsing the product, the endorser’s Unexpected Material Connection to any Defendant or any 

other individual or entity affiliated with the product, and obtaining from each such endorser a 

signed and dated statement acknowledging receipt of that statement and expressly agreeing to 

comply with it; 

Provided, however, in the case of endorsers participating in a program through which they only 

receive free or discounted products sold by Defendants or referral payments not to exceed $20 per 

month, it will be sufficient to 1) provide them with a Clear and Conspicuous Statement of 

Disclosure Responsibilities either a) as part on an online sign-up process to participate in the 

program or b) for those who are already participating in the program as of entry of this Order, by 

electronic mail; and 2) obtain their electronic signature acknowledging their receipt of the 

statement and agreement to comply with it. 

B. Establishing, implementing, and thereafter maintaining a system to monitor and review the 

representations and disclosures of endorsers with material connections to any Defendant or any 

other individual or entity affiliated with the product sufficiently designed to ensure compliance 

with the Sections of this Order entitled Prohibited Representations Regarding Endorsements and 

Required Disclosures of Material Connections, including reviewing each specifically contracted 

online video and social media posting promptly after publication; 

Provided, however, in the case of endorsers participating in a program through which they only 

receive free or discounted products sold by Defendants or referral payments not to exceed $20 per 

month, it will be sufficient to conduct monthly reviews of the fifty endorsers generating the 

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highest levels of product sales, in dollars, in the prior month. 

C. Immediately terminating and ceasing payment to any endorser with a material connection 

to any Defendant, or any other individual or entity affiliated with the product, who Defendants 

reasonably conclude: 

1. Has misrepresented, in any manner, his or her independence or impartiality; or 

2. Has failed to disclose, Clearly And Conspicuously, and in Close Proximity to the 

endorsement, an Unexpected Material Connection between such endorser and any Defendant or 

any other individual or entity affiliated with the product. 

Provided, however, that Defendants may provide an endorser with notice of failure to adequately 

disclose and an opportunity to cure the disclosure prior to terminating the endorser if Defendants 

reasonably conclude that the failure to adequately disclose was inadvertent. Defendants shall 

inform any endorser to whom they have provided a notice of a failure to adequately disclose an 

Unexpected Material Connection that any subsequent failure to adequately disclose will result in 

immediate termination; and 

D. Creating reports showing the results of the monitoring required by sub-section B of this 

Section of the Order. 

VIII. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of $15,209,452 is entered in favor of the Commission against 

Individual Defendants and Corporate Defendant, jointly and severally, as equitable monetary 

relief. 

B. Defendants are ordered to pay to the Commission $1,000,000 as follows: 

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1. Within 7 days of entry of this Order, Defendants are ordered to pay $500,000 to the 

Commission, which, as Defendants stipulate, their undersigned counsel holds in escrow for no 

purpose other than payment to the Commission. Defendants shall wire by electronic funds 

transfer these funds to the Commission in accordance with instructions previously provided by a 

representative of the Commission; 

2. Within 180 days of entry of this Order, Defendants shall wire by electronic fund transfer 

the sum of $250,000 to the Commission, in accordance with instructions provided by a 

representative of the Commission; 

3. Within 1 year of entry of this Order, Defendants shall wire by electronic fund transfer the 

sum of $250,000 to the Commission, in accordance with instructions provided by a representative 

of the Commission; 

4. Upon completion of the payments described above in Subsection VIII.B. of this Order, the 

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

C. To secure the payment obligations under Subsections VIII.B.2 and 3 of this Order, 

Defendants grant the Commission liens on and security interests in certain property (“Collateral”), 

as set forth below. These interests are incorporated by reference as if fully set forth verbatim and 

grant a security interest in the following Collateral: 

1. Individual Defendant Adi Halevy hereby grants to the Commission, pursuant to 

Deeds of Trust, liens on and security interests in the real properties located at: 4840 NE 99th 

Avenue, Portland, OR 97220; 4915 SE 111th Avenue, Portland, OR 97266; and 6850 NE 

Emerson Street, Portland, OR 97218. Individual Defendant Halevy shall submit to the clerk’s 

office for recording, at her expense, all security documents necessary to perfect the Commission’s 

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liens on the properties within 14 days after entry of this Order, and shall deliver to the 

Commission copies of such officially recorded documents within 7 days after receipt of such 

documents; and 

2. Individual Defendant Yogev Malul hereby grants to the Commission, pursuant to a 

Mortgage, a lien on and security interest in the real property located at 18800 NE 29th Avenue, 

Unit 123, Aventura, FL 33180. Individual Defendant Malul shall submit to the clerk’s office for 

recording, at his expense, all security documents necessary to perfect the Commission’s lien on 

the property within 14 days after entry of this Order, and shall deliver to the Commission copies 

of such officially recorded documents within 7 days after receipt of such documents. 

D. In the event that Defendants fail to make a required payment when due under Subsection 

VIII.B. of this Order, or if Individual Defendants fail to comply with the terms of a Deed of Trust 

or Mortgage and such failure is not timely cured, the entire judgment amount, less any amount 

previously paid, shall immediately become due and payable by all Defendants. Interest 

computed at the rate prescribed under 28 U.S.C. § 1961, as amended, shall immediately begin to 

accrue on the unpaid balance. Time is of the essence for the payments specified in this 

Subsection. 

E. Upon full payment of Defendants’ obligations under Subsections VIII.B.1 and 2 of this 

Order, the Commission agrees to release the security interests granted in the real properties 

referenced in Subsection VIII.C.1 of this Order. Upon full payment of Defendants’ obligations 

under Subsection VIII.B. of this Order, the Commission agrees to release the remaining security 

interests granted herein. Individual Defendants Halevy and Malul shall be responsible for 

preparing and filing (at their expense) any termination or other statements reasonably required in 

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connection therewith. The Commission shall also promptly release or subordinate such liens, 

security interests, and other protections granted herein to the extent necessary to permit the sale or 

encumbrance of part or all of the Collateral if the proceeds of such sale or encumbrance are 

remitted directly to the Commission in partial or complete satisfaction of this Order. Individual 

Defendants Halevy and Malul shall pay all fees and costs related to such release or subordination, 

including filing fees. 

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

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

statements and related documents (collectively, “Financial Representations”) submitted to the 

Commission, namely: 

1. the Financial Statement of Individual Defendant Adi Halevy signed on August 29, 2019, 

including the attachments; 

2. the Financial Statement of Individual Defendant Yogev Malul signed on September 3, 

2019, including the attachments; 

3. the Financial Statement of Corporate Defendant Teami LLC signed on August 29, 2019, 

including the attachments; and 

4. the representations and additional documentation submitted by Defendants’ counsel Ricky 

Huff to Commission counsel Michael Ostheimer and Christine DeLorme dated September 23, 

2019 (two emails, one of which attaches tax returns and a letter from counsel); September 24, 

2019; October 10, 2019; and December 2, 2019 (attaching a deed). 

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

Commission, the Court finds that Defendant failed to disclose any material asset, materially 

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misstated the value of any asset, or made any other material misstatement or omission in the 

Financial Representations identified above. 

H. If the suspension of the judgment is lifted, the judgment becomes immediately due as to 

that Defendant in the amount specified in Subsection VIII.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. 

IX. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

A. 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. 

B. 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 its rights to any payment or monetary judgment pursuant to this Order, such as a 

nondischargeability complaint in any bankruptcy case. 

C. The facts alleged in the 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. 

D. Defendants acknowledge that their Taxpayer Identification Numbers (Social Security 

Numbers or Employer Identification Numbers), which 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. 

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E. All money paid to the Commission 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 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. 

Defendants have no right to challenge any actions the Commission or its representatives may take 

pursuant to this Subsection. 

X. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendants, Defendants’ 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 are permanently restrained and enjoined from directly or 

indirectly failing to provide sufficient customer information to enable the Commission to 

efficiently administer consumer redress. If a representative of the Commission requests in 

writing any information related to redress, Defendants must provide it, in the form prescribed by 

the Commission, within 14 days. 

XI. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of this 

Order: 

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

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

B. For 5 years after entry of this Order, each Individual Defendant for any business that 

such Defendant, individually or collectively with any other Defendants, is the majority owner or 

controls directly or indirectly, and Corporate 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 a Defendant delivered a copy of this Order, that 

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this 

Order. 

XII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

A. Ninety days after entry of this Order, each Defendant must submit a compliance report, 

sworn under penalty of perjury: 

1. Each 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 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 

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activities of each business, including the goods and services offered, the means of advertising, 

marketing, and sales, and the involvement of any other Defendant (which Individual Defendants 

must describe if they know or should know due to their own involvement); (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 such Defendant performs services whether as an 

employee or otherwise and any entity in which such Defendant has any ownership interest; and 

(c) describe in detail such Defendant’s involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership. 

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

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

1. Each Defendant must report any change in: (a) any designated point of contact; or (b) the 

structure of any Corporate Defendant or any entity that 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 such Defendant performs services whether as an employee or 

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Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 21 of 25 PageID 99 

otherwise and any entity in which such Defendant has any ownership interest, and identify the 

name, physical address, and any Internet address of the business or entity. 

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

petition, insolvency proceeding, or similar proceeding by or against such Defendant within 14 

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 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. Teami, LLC. 

XIII. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 10 years 

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

Defendant in connection with any activity subject to this Order and each Individual Defendant for 

any business that such Defendant, individually or collectively with any other Defendants, is a 

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

A. accounting records showing the revenues from all goods or services sold; 

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Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 22 of 25 PageID 100 

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; 

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; and 

E. a copy of each unique advertisement or other marketing material, except social media 

posts by endorsers participating in a program through which they only receive free or discounted 

products sold by Defendants or referral payments not to exceed $20 per month. 

XIV. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’ compliance 

with this Order, including any failure to transfer any assets as required by this Order: 

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

each 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 Defendant. Defendant must permit representatives of the Commission to interview 

any employee or other person affiliated with any Defendant who has agreed to such an interview. 

Page 22 of 25 
 

_______________________________ 

Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 23 of 25 PageID 101 

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 Defendants or any 

individual or entity affiliated with Defendants, 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. 

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

agency must furnish consumer reports concerning Individual Defendants, pursuant to Section 

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

XV. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for purposes 

of construction, modification, and enforcement of this Order. 

SO ORDERED this day of , . 

UNITED STATES DISTRICT JUDGE 

SO STIPULATED AND AGREED: 

Page 23 of 25 
FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

MICHAEL 

wu~

OSTHEIMER 

Federal Trade C.ommission 

600 Pennsylvania Avenue, NW 

Washington, D.C. 20580 

Tel.: 202-326-2699 

Fax: 202-326-3259 EmaJIJ~ 

cHrusnNE 'nELuRMi 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, D.C. 20580 

Tel.: 202-326-2095 

Fax: 202-326-3259 

Email: cdelorme@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

Page 24 of25 

Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 24 of 25 PageID 102 
FOR DEFENDANTS! 

Date: /z- 2-<J -1 i 

Provicfmce Law Gnap 

1744 N. Belcher Road. Suite 150 

Clearwater. FL 33765 

Tel.: 727-726-1514 

Fax: 727-726-9044 

muff@provlawgroup.COOl 

Counsel for Teami, LLC, Adi Halevy, and Yogev Malul 

DEFENDANTS: Teami, LLC, Adi Halevy, ud Yogev Malul 

Adi Halevy, Indivi 

and as an Officer of T 

Y ogev Malul, Individually 

and as BD Officer ofTeami, LLC 

Date: l?-\ 20\ 1C, 

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Case 8:20-cv-00518 Document 3-1 Filed 03/05/20 Page 25 of 25 PageID 103