UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

Office of the Chair

Statement of Chair Lina M. Khan 

In the Matter of R360 Network 

Commission File No. 1823171 

May 17, 2022 

Opioid addiction inflicts a devastating toll on families and communities, and the 

epidemic of addiction has only worsened during the pandemic.1 Opioid overdoses rose 15 

percent from 2020 to 2021, resulting in 80,000 deaths in 2021.2 Shamefully, some are seeking to 

exploit and profit from these families’ pain.3In 2018 Congress passed the Opioid Addiction 

Recovery Fraud Prevention Act, giving the FTC authority to hold accountable bad actors taking 

advantage of families seeking substance abuse treatment for loved ones. Today’s action marks 

the Commission’s first enforcement action under this authority.

The Commission has obtained an order against the promoter of an addiction treatment 

network who is charged with deceiving consumers about the quality and characteristics of the 

treatment centers offered in their network. To address these charges—and to deter other bad 

actors—the agency secured a $3.8 million civil penalty judgment against not only the company 

but also its owner, Steven Doumar. These defendants are also now barred from continuing to 

prey on struggling families. Today’s action should signal to individuals who break the law that 

they cannot evade accountability by hiding behind a corporate shield.

4

More broadly, today’s enforcement action underscores the importance of fully exercising 

the legal authorities that Congress has granted us. In the century since lawmakers created the 

FTC, Congress has charged us with enforcement or administrative responsibilities under more 

than 70 laws. Faithfully discharging our statutory duties requires that we deploy this full set of

tools. Accordingly, we are assertively harnessing our slate of authorities5—and should continue 

1 Meryl Kornfield, U.S. Surpasses Record 100,000 Overdose Deaths in 2021, WASH. POST (May 11, 2022), 

https://www.washingtonpost.com/health/2022/05/11/drug-overdose-deaths-cdc-numbers/.

2

Id.

3

Jan Hoffman, ‘You Murdered My Daughter’: Relatives of OxyContin Victims Confront the Sacklers, N.Y. TIMES

(Mar. 10, 2022), https://www.nytimes.com/2022/03/10/health/sacklers-opioids-victims.html. 

4 While investigating individual liability may require additional time and resources, it is critical in a matter as 

egregious as this one that the appropriate individuals are held accountable. I am confident that this is the case here.

5 Last year, for example, we finalized a rule regarding deceptive Made in America labels—authority that Congress 

granted the agency in 1994 but had been left dormant—and just last month we brought our first action under the 

rule, requiring a violator to pay a civil penalty of triple its profits. Last summer the Commission also put firms on 

notice that we will prioritize enforcement targeting unlawful repair restrictions, including through reviving

enforcement of the Magnuson-Moss Warranty Act, and in September we activated the Health Breach Notification 

Rule, noting that it also covers data breaches involving health apps and connected devices. The Commission has also 

made quick use of the COVID-19 Consumer Protection Act, filing several major actions against companies making 

false claims relating to the pandemic and, where appropriate, naming individual defendants. See Press Release, Fed. 

Trade Comm’n, FTC Issues Rule to Deter Rampant Made in USA Fraud (July 1, 2021), https://www.ftc.gov/newsevents/press-releases/2021/07/ftc-issues-rule-deter-rampant-made-usa-fraud; Press Release, Fed. Trade Comm’n, 

FTC Enforces New Made in USA Rule against Lithionics and Owner Steven Tartaglia for Falsely Labeling ForeignMade Batteries as American (Apr. 13, 2022), https://www.ftc.gov/news-events/news/press-releases/2022/04/ftcenforces-new-made-usa-rule-against-lithionics-owner-steven-tartaglia-falsely-labeling-foreign; Press Release, Fed. 
doing so.

6 The Opioid Addiction Recovery Fraud Prevention Act is one of these key tools, and 

we will deploy it aggressively to protect families and communities suffering from the pain and

toll of addiction. 

***

Trade Comm’n, FTC to Ramp Up Law Enforcement Against Illegal Repair Restrictions (July 21, 2021), 

https://www.ftc.gov/news-events/news/press-releases/2021/07/ftc-ramp-law-enforcement-against-illegal-repairrestrictions; Fed. Trade Comm’n, Statement of the Commission on Breaches by Health Apps and Other Connected 

Devices (Sept. 15, 2021), https://www.ftc.gov/legal-library/browse/statement-commission-breaches-health-appsother-connected-devices; Compl., United States v. B4B Earth Tea LLC, No. 22-cv-1159 (E.D.N.Y. Mar. 3, 2022), 

https://www.ftc.gov/system/files/ftc_gov/pdf/us_v._b4b_earth_tea_complaint_22cv1159.pdf (allegedly claimed tea 

was clinically proven to treat, cure, and prevent COVID-19); Compl., United States v. Xlear, Inc., No. 2:21-cv00640 (D. Utah Oct. 28, 2021), 

https://www.ftc.gov/system/files/documents/cases/filed_complaint_xlear_v_jones_v.1.pdf (allegedly claimed nasal 

spray provided four-hour protection against coronavirus); Compl., United States v. Nepute, No. 4:21-cv-00437 (E.D. 

Mo. Apr. 15, 2021), https://www.ftc.gov/system/files/documents/cases/2023188eneputecomplaint_0.pdf (allegedly 

claimed that vitamin supplement was more effective than vaccines); Compl., FTC v. Frank Romero d/b/a Trend 

Deploy, No. 5:21-cv-00343 (M.D. Fla. June 29, 2021), 

https://www.ftc.gov/system/files/documents/cases/complaint_-_trend_deploy.pdf (online marketer that allegedly 

failed to deliver PPE within promised timeframes and falsely claimed that consumers would receive N95 respirators 

certified by the FDA or NIOSH while providing inferior, cloth facemasks).

6 One particular tool that the Commission has recently revived is its Penalty Offense Authority, which gives the FTC 

the power to seek civil penalties if an entity engages in conduct similar to conduct that the Commission has 

previously found unfair or deceptive. Since last summer, we have sent more than 1,870 letters putting firms on 

notice that certain unlawful conduct could subject them to civil penalties. In April 2022, the FTC used our Penalty 

Offense Authority to seek $5.5 million in civil penalties against Kohl’s, Inc. and Walmart, Inc., alleging that the 

companies falsely marketed products as being environmentally friendly. See Press Release, Fed. Trade Comm’n, 

FTC Puts Businesses on Notice that False Money-Making Claims Could Lead to Big Penalties (Oct. 26, 2021), 

https://www.ftc.gov/news-events/press-releases/2021/10/ftc-puts-businesses-notice-false-money-making-claimscould-lead; Press Release, Fed. Trade Comm’n, FTC Targets False Claims by For-Profit Colleges (Oct. 6, 2021), 

https://www.ftc.gov/news-events/news/press-releases/2021/10/ftc-targets-false-claims-profit-colleges; Press 

Release, Fed. Trade Comm’n, FTC Puts Hundreds of Businesses on Notice about Fake Reviews and Other 

Misleading Endorsements (Oct. 13, 2021), https://www.ftc.gov/news-events/news/press-releases/2021/10/ftc-putshundreds-businesses-notice-about-fake-reviews-other-misleading-endorsements; Press Release, Fed. Trade 

Comm’n, FTC Uses Penalty Offense Authority to Seek Largest-Ever Civil Penalty for Bogus Bamboo Marketing 

from Kohl’s and Walmart (Apr. 8, 2022), https://www.ftc.gov/news-events/news/press-releases/2022/04/ftc-usespenalty-offense-authority-seek-largest-ever-civil-penalty-bogus-bamboo-marketing-kohls.