UNITED STA TES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

vs. 

BENEFY1T TECHNOLOGIES, INC., f/k/a 

HEAL TH INSURANCE INNOVATIONS, 

INC., a Delaware corporation~· 

HEAL TH PLAN INTERMEDIARIES 

HOLDINGS, LLC, a Delaware limited 

liability company; 

HEAL THPOCKET, INC., d/b/a 

AGILEHEALTHINSURANCE, a Delaware 

corporation; 

GA VIN D. SOUTHWELL, individually and 

as a former officer:t director, and manager of 

Benefytt Technologies, Inc., Health Plan 

Intermediaries Holdings, LLC, and 

HealthPocket, Inc.; and · 

AMYE. BRADY, individually and as a 

former vice president and manager of 

Benefytt Technologies, Inc. and Health Plan 

Intennediaries Holdings, LLC. 

Defendants. 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION 

AND OTHER RELIEF 

AGAINST DEFENDANT AMY 

E.BRADY 

Plaintiff, the Federal Trade Commission {"Commission" or "FTC")1 filed its 

Complaint for Permanent Injunction, Monetary Relief, and Other Relief 

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("Complaint") in this matter, pursuant to Sections 13(b) and 19 of the Federal Trade 

Commission Act ("FTC Act")1 15 U.S.C. §§ 53(b), 57b, the Telemarketing and 

Consumer Fraud and Abuse Act ("Telemarketing Act,,), lS U.S.C. §§ 6 101-6108, 

and Section 5 of the Restore Online Shoppers' Confidence Act ("ROSCA,,), 15 

U.S.C. § 8404. The Commission and Defendant Arny E. Brady ("Settling 

Individual Defendant") stipulate to the entry of this Stipulated Order for Permanent 

Injunction and Other Relief ('tOrder") 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, unfair, and 

abusive acts or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, 

the FTC's Telemarketing Sales Rule ("TSR''), 16 C.F.R. Part 310, as amended, and 

Section 4 of ROSCA, 15 U.S.C. § 8403, in connection with the advertising, 

marketing, telemarketin& promoting, offering for sale, or sale of association 

memberships and related health products, including short-term medical plans, 

limited benefit plans, and medical discount plans. 

3. Settling Individual Defendant neither admits nor denies any of the allegations 

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

this action, Settling Individual Defendant admits the facts necessary to establish 

jurisdiction. 

4. Settling Individual Defendant waives any claim that she may have under the 

Equal Access to Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this 

action through the date of this Order, and agrees to bear her own costs and attorney 

fees. 

5. Settling Individual Defendant waives an 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. "ACA" means the Patient Protection and Affordable Care Act of 2010, 

Pub. L. No 111~ 148, 124 Stat. 119. 

B. 1~Billing Information" means any data that enables any person to 

access a customer's accoun4 such as a credit card, checking, savings, share or 

similar account, utility bill, mortgage loan account, or debit card. 

C. "Charge," "Charged," or "Cha.rging"' means any attempt to collect 

money or other consideration from a consumer~ including causing Billing 

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Information to be submitted for payment, including against the consumer• s credit 

cardt debit card~ bank account, telephone bill, or other account. 

D. "Clear(ly) and Coospicuous(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: 

I . In any communication that is solely visua] or solely audible, the 

disclosure must be made through the same means through which the 

communication is presented. In any communication 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 easi1y 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. 

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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 ancl face-toface 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 tenninally m, ''ordinary oonsumersn 

includes reasonable members of that group. 

E. "Defendants" means Individual Defendants and Corporate 

Defendants, individually; collectively, or in any combination. 

1. "Corporate 'Defendants" means Benefytt Technologies, Inc., 

f/k/a Health Insurance Innovations, Inc .• Health P]an Intermediaries Holdings" LLC, 

HealthPocket, Inc. d/b/a AgileHealthinsurance, and their successors and assigns. 

2. "Individual Defendants" means Gavin D. Southwell and Amy 

E. Brady. 

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F. "Healthcare-Related Product" means any program, plan, 

membership, card, product, insurance policy, or other good or service~ that offers. 

or purports to offer, health insurance, discounts, savings, or benefits on healthcare, 

or access to such health insurance, discounts, savings, or benefits. 

G. "Negative Option Feature" means, in an offer or agreement. to sell or 

provide any good or service~ a provision under which the consumer's silence or 

failure to take affirmative action to reject a good or service or to cancel the 

agreement is interpreted by the seller or provider as acceptance or continuing 

acceptance of the offer~ 

H. "Settling Individual Defendant" means Arny E. Brady. 

I. "Telemarketingn 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 which involves more than one interstate 

telephone call, whether or not covered by the Telemarketing Sales Rule. 

ORDER 

I. BAN ON HEALTHCARE-RELATED PRODUCTS 

IT IS THEREFORE ORDERED that Settling Individual Defendant is 

permanently restrained and enjoined from advertising, marketing, promoting, 

offering for sale, or selling, or assisting in the .advertising~ marketing, promoting, 

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offering for sale, or selling, of any Healthcare-Related Product. 

JI. BAN ON TELEMARKETING 

IT IS FURTHER ORDERED that Settling Individual Defendant is 

permanently restrained and enjoined from participating in Telemarketing~ whether 

directly or through an intermediary, including by consu1ting, brokering, planning, 

investing, or advising. 

III. PROHIBITED BUSINESS PRACTICES 

IT IS FURTHER ORDERED that Settling Individual Defendant, Settling 

Individual Defendant's officers, agentst employees, and attorneys1 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 

advertising, marketing, promoting, or offering for sale any good or service, are 

permanently restrained and enjoined from: 

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

implication: 

1. any cost to the consumer to purchase, receivet use, or return the 

good or service; 

2. that any good or service is included at no additional cost with 

the purchase of another good or service; 

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3. that any good or service is a qualified health plan under the 

ACA or is "Obamacare''; 

4. that any good or service provides benefits equivalent to a 

qualified health plan under the ACA; 

5. that any good or service is comprehensive health insurance or 

major medical insurance, or provides benefits equivalent to such 

insurance; or 

6. any other fact material to consumers concerning any good or 

service, such as: the total costs; any .material restrictions, limitations, 

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

nature, or central ,characteristics; 

B. Making any representation, or assisting others in making any 

representation, expressly or by. implication, unless the representation is 

non-misleadin~ and, at the time such representation is made~ Settling Individual 

Defendant possesses and relies upon competent and reliable evidence that is 

sufficient in quality and quantity to substantiate that the representation is true, 

regarding any good or service; 

C. Failing to disclose, or assisting others in failing to disclose, Clearly and 

Conspicuously, before requesting any Billing Information from a consumer: 

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1. the complete name of each good or service to be purchased, the 

name of the seller or provider of each good or service to be purchase~ 

and, if the name of the seller or provid.er will not appear on billing 

statements, the billing descriptor that will appear on such statements; 

2. a description of each good or service; 

3. all costs and fees, itemized by each good or service to be 

purchased; 

4. an applicable exclusions, limitations, or waiting periods related 

to the use of any good or service; 

5. the tenns of any refund, cancellation, exchange, or repurchase 

policy for any good or service, including the extent to which the 

consumer must take affirmative action to avoid any Charges; and 

6. the simple cancellation method to stop any recurring Charges, as 

required by Subsection III.G; 

D. Causing any consumer to be billed for any good or service without 

having previously obtained the •consumer's express informed consent; 

E. Failing to send the consumer: 

1. Immediately after the consumer's submission of an online order, 

written confirmation of the transaction by email if Settling Individual 

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Defendant is in possession of the consumer's email address. The 

email must Clearly and Conspicuously disclose all the information 

required by Subsection Ill.C, and contain a subject line reading uorder 

Confirmation" alqng with the name of the good(s) or service{s), and no 

additional information. [f Settling Individual Defendant is not in 

possession of the ,consumer's email address, such Defendant must 

provide confirmation to online purchasers or cancel the transaction as 

set forth in Subsection III.E.2; or 

2. Within 2 days after receipt of the consumer's order by mail or 

telephone, or where a consumer who submitted an order online did not 

provide Settling Individual Defendant with an email addresst a written 

confirmation .of the transaction, either by email or first class mail 

The email or letter must Clearly and Conspicuously disclose all the 

information required by Subsection III.C. The subject line of the 

email must Clearly and Conspicuously state "Order Confinnation,, 

along with the nrune ofthe good(s) or service{s), and nothing else. 

The outside of the envelope must Clearly and Conspicuously state 

"Order Confinnationn along with "Important Infonnation About Your 

Recent Purchase and Enrollment," and. no additional information other 

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than the consumer's address, the sending Defendant's return address, 

and postage. Provided, however, that if Settling Individual Defendant 

is not in possession of either an email address or a physical address for 

a consumer and cannot obtain such information and send confinnation 

of the purchase within 2 days after receipt of an order pursuant to this 

Subsection. such Defendant must immediately cancel the consumer's 

purchase and refund all charges; 

F. Representing directly or indirectly t expressly or by impHcation, that 

any good or service that includes a Negative Option Feature is being offered on a 

free, trial, no obligation, reduced, or discounted basis, without disclosing Clearly 

and Conspicuously: 

1. The extent to which the consumer must take any affirmative 

action to avoid any Charges: a) for the offered good or service, b) of an 

increased amount after the trial or promotional period endst and c) on a 

recurring basis; 

2. The total cost (or range of costs) the consumer will be Charged 

and, if applicable, the frequency of such Charges unless the consumer 

timely takes steps to prevent or stop such Charges; and 

3. The deadline(s) (by date or frequency) by which the consumer 

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must affinnatively act in order to stop all recurring Charges. 

G. Failing to provide a simple and easy-to-use method by which 

consumers can cancel the Charge for any good or service; such method must not be 

difficult. costly, confusing, or time consuming, and must be at least as simple as the 

method the consumer used to initiate the Charge(s); 

H. Failing to promptly cancel a consumer's purchase of any good or 

service after receiving the consumees cancellation request; or 

I. Causing a consumer, after the consumer requests to cancel any good or 

service, to continue being bil1e.d for any other good or service without obtaining that 

consumer's express informed consent. 

IV. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Settling Individual Defendant is 

permanently restrained and enjoined from directly or indirectly disclosing, using, or 

benefitting from customer information that any Defendant obtained prior to entry of 

this Order, provided that Settling Individual Defendant may use such information to 

otherwise comply with the tenns of this Order. Such customer information 

includes the name, address, telephone number, email address, Social Security 

number, other identifying information, sensitive health information, or any data that 

enables access to a customer's a¢count (including a credit card, bank account, or 

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other financial account), 

V. COOPERATION 

IT IS FURTHER ORDERED that Settling Individual Defendant must fully 

cooperate with representatives of the Commission in this case and in any 

investigation related to or associated with the transactions or the occurrences that 

are the subject of the Complaint. Settling Individual Defendant must provide 

truthful and complete information, evidence, and testimony. Settling Individual 

Defendant must appear for interviews, discovery, hearings, trials, and any other 

proceedings that a Commission representative may reasonably request upon 5 days 

written notice, or other reasonable notice, at such places and times as a Commission 

representative may designate, without the service of a subpoena. Nothing in this 

Section precludes or prevents the Settling Individual Defendant from invoking any 

valid Fifth Amendment privilege against self-incrimination. 

VI. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Settling Individual Defendant obtain 

acknowledgments of receipt of this Order: 

A. Settling Individual Defendant, within 7 days of entry of this Order, 

must submit to the Commission an acknowledgment of receipt of this Order sworn 

under penalty of perjury. 

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B. For 20 years after entry of this Order, Settling Individual Defendant for 

any business that such Defendant, individually or collectively with any other 

Defendantt is the majority owner or controls directly or indirectly, 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 subj,ect 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 otherst delivery must occur before they assume their 

responsibilities, 

C. From each individual or entity to which Settling Individual Defendant 

delivered a copy of this Order, Settling Individual Defendant must obtaint within 30 

days~ a signed and dated acknoyvledgment of receipt of this Order. 

vn. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Settling Individual Defendant make timely 

submissions to the Commission~ 

A. One year after entry of this Order, Settling Individual Defendant must 

submit a compliance report, sworn under penalty of pei:iury: 

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1. Settling Individual 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 

SettHng Individual Defendant; (b) identify all of Settling Individual 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 salest and the 

involvement of any other Defendant (which Settling Individual Defendant must 

describe if she knows or should know due to her own involvement); (d) describe in 

detail whether and how Settling Individual 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, Settling Individual Defendant must~ (a) identify 

all telephone numbers and ail physical, postal, email and Internet addresses, 

including aU residences; (b) identify all business activities, including any business 

for which Settling Individual Defendant performs services whether as an employee 

or otherwise and any entity in which Settling Individual Defendant has any 

ownership interest; and ( c) describe in detail Settling Individual Defendant's 

involvement in each such business, including title,. role, responsibilities, 

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participation, authority, control, and any ownership. 

B. For 20 years after entry of this Order, Settling lndividual Defendant 

must submit a compliance notice, sworn under penalty of perjury, within 14 days of 

any change in the following: 

l. Settling Individual Defendant must report any change in: (a) 

any designated point of contact; or (b) the structure of any entity that Settling 

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 dis.solution of the entity or any subsidiary, parent, or 

affiliate that engages in any acts or practices subject to this Order. 

2. AdditionaUy, Settling 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 Settling 

Individual Defendant performs services whether as an employee or otherwise and 

any entity in which Settling Individual Defendant has any ownership interest, and 

identify the name, physical address, and any Internet address of the business or 

entity. 

C. Settling Individual Defendant must submit to the Commission notice 

of the filing of any bankruptcy_petition~ insolvency proceeding, or similar 

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proceeding by or against her within 14 days ofits 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: . ''l 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 otheiwise 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. Benefytt Technologies, Inc., Matter No. 1923141. 

VIII. RECORDKEEPING 

IT IS FURTHER ORDERED that Settling 1ndividua1 Defendant must create 

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

5 years. Specifically, Settling Individual Defendant for any business that she, 

individually or collectively with any other Defendan1⁄2 is a majority owner or 

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

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

sold; 

B. personnel records showing, for each person providing services, 

whether as an employee or otherwise, that person,s: name; addresses; te]ephone 

numbers; job title or position~ dates of service; and (if applicable) the reason for 

termination; 

C. records of all consumer complaints concerning the subject matter of 

the Order and refund requests, whether received directly or indirectly, such as 

through a third party, and any response; 

D. all records rtecessary to demonstrate full compliance with each 

provision of this Order, including; 

E. for express, informed consent obtained in writing, documentation that 

shows such consent, including the date and the consumer's name, telephone 

number, and Billing Infonnation; 

F. for express, informed consent obtained orally, an unedited voice 

recording that contains such consent, retrievable by date; and 

G. a copy of all advertisements or other marketing material related to any 

good or service sold. 

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IX. COMPLIANCE MONITORING 

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

Individual Defendant's compliance with this Order and any failure to transfer any 

assets as required by this Order: 

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

the Commission, Settling Individual Defendant must: submit additional 

compliance reports or other requested infonnation, 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 Settling Individual Defendant. Settling Individual 

Defendant must permit representatives of the Commission to interview any 

employee or other person affili_ated with Settling Individual 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, 

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to Settling Individual Defendant1 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 Settling 

Individual Defendant, pursuant to Section 604(1) of the Fair Credit Reporting Act, 

15 u.s.c. §1681b(a)(l). 

X~ 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. 

SOORDEREDthis llf11 . dayof A\/%1]~-b , 2022. 

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SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

Isl Matthew G. Schiltz 

Matthew G. SchiUz 

Claire E. W. Stewart 

Elizabeth C. Scott 

Federal Trade Commission, Midwest Region 

230 S. Dearborn Street, Suite 3030 

Chicago, Illinois 60604 

312.960.5619 

Date: 8/8/2022 

mschiltz@ftc.gov; cstewart@ftc.gov; escott@ftc.gov 

Attorneys/or Plaintiff 

Federal Trade Commission 

FOR SETTLING INDIVIDUAL DEFENDANT: 

Jared Lopez 

Maria D. Neyra 

Raymie Walsh 

Black Srebnick, P.A. 

201 Biscayne Blvd., Suite 1300 

Miami, Florida 33131 

(305) 371-6421 

j lopez@royblack.com 

mneyra@royblack.com 

rwalsh@royblack.com 

Attorneys for Defendant Amy E. Brady 

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Date: July 21, 2022 

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SETTLING INDIVIDUAL DEFENDANT: 

Date: 7 / ').. I 

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