PROTECTING OLDER

CONSUMERS

2019 — 2020

A Report of the Federal Trade Commission

Federal Trade Commission | Report to Congress

October 18, 2020
PROTECTING OLDER

CONSUMERS

2019 — 2020

A Report of the Federal Trade Commission to Congress

October 18, 2020

FEDERAL TRADE COMMISSION

Joseph J. Simons, Chairman

Noah Joshua Phillips, Commissioner

Rohit Chopra, Commissioner

Rebecca Kelly Slaughter, Commissioner

Christine S. Wilson, Commissioner
Contents

I. Introduction ............................................................................................................................. 1

II. Developing Effective Strategies to Protect Older Consumers............................................. 2

A. Research and Data Analysis................................................................................................. 2

1. Consumer Sentinel Reports from Older Adults................................................................... 3

2. Alerting the Public to Consumer Reporting Trends .......................................................... 13

3. Hearing Directly from Older Consumers About FTC Imposters....................................... 14

B. Coordinated Efforts to Protect Older Consumers.............................................................. 15

III. FTC Enforcement Activities Affecting Older Consumers................................................. 16

A. Credit Card Interest Rate Reduction Scheme .................................................................... 17

B. Deceptive Publications and Government Check Program................................................. 17

C. Business Opportunities, Pyramids, and Money-Making Schemes.................................... 18

D. Assisting and Facilitating Payments.................................................................................. 21

E. Unsubstantiated Health Claims.......................................................................................... 22

F. Other Enforcement Highlights........................................................................................... 29

1. Warning Letters ................................................................................................................. 29

2. Case Resolutions................................................................................................................ 32

3. Consumer Monetary Relief................................................................................................ 34

4. Criminal Liaison Unit ........................................................................................................ 35

IV. Outreach and Education Activities.................................................................................... 36

A. Pass It On Education Campaign ........................................................................................ 36

B. Communicating through Video.......................................................................................... 37

C. Common Ground Events.................................................................................................... 38

D. Other Outreach Relating to Older Adults .......................................................................... 38

E. Coronavirus Education and Outreach to Older Adults...................................................... 39

V. Conclusion ......................................................................................................................... 41

Appendix A................................................................................................................................... 42
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I. Introduction

As the nation’s primary consumer protection agency, the Federal Trade Commission 

(“FTC” or “Commission”) has a broad mandate to protect consumers from unfair or deceptive

acts or practices in the marketplace.1 It does this by, among other things, filing law enforcement 

actions to stop unlawful practices and, when possible, returning money to consumers. The FTC 

also protects the public through education and outreach on consumer protection issues. Through 

research and collaboration with federal, state, international, and private sector partners, the FTC 

strategically targets its efforts to achieve the maximum benefits for consumers, including older 

adults.2

Protecting older consumers in the marketplace is one of the FTC’s top priorities.

3

Unfortunately, in numerous FTC cases, older adults have been targeted or disproportionately 

affected. For example, as discussed below, the FTC has brought ten new enforcement actions 

this year to stop unsubstantiated claims for products that purport to treat various illnesses and 

conditions affecting older consumers. As the population of older adults grows, the FTC’s 

aggressive efforts to bring law enforcement actions against scams that affect them, as well as 

provide useful consumer advice, become increasingly important.

4

The FTC submits this third annual report to the Committees on the Judiciary of the 

United States Senate and the United States House of Representatives to fulfill the reporting 

requirements of Section 101(c)(2) of the Elder Abuse Prevention and Prosecution Act of 2017.5

The law requires the FTC Chairman to file a report listing the FTC’s enforcement actions “over 

the preceding fiscal year in each case in which not less than one victim was an elder or that 

involved a financial scheme or scam that was either targeted directly toward or largely affected 

elders.” Given the large number of consumers affected in FTC actions, this list, found in 

 

1 The FTC has wide-ranging law enforcement responsibilities under the Federal Trade Commission Act, 15 U.S.C. 

§ 41 et seq. and enforces a variety of other laws ranging from the Telemarketing and Consumer Fraud and Abuse 

Prevention Act to the Fair Credit Reporting Act. In total, the Commission has enforcement or administrative 

responsibilities under more than 70 laws. See http://www.ftc.gov/ogc/stats.shtm. 2 This report focuses on the Bureau of Consumer Protection’s work to protect older adults. The FTC’s Bureau of 

Competition also serves older adults through its work in various sectors of the economy, such as health care, 

consumer products and services, technology, manufacturing, and energy.

3 This report refers to persons 60 and older when using the terms “older adults” or “older consumers” to be 

consistent with the requirements in Section 2(1) of the Elder Abuse Prevention and Prosecution Act, which 

references Section 2011 of the Social Security Act (42 U.S.C. 1397j(5)) (defining “elder” as an individual age 60 or 

older).

4 According to U.S. Census Bureau projections, by 2030 all baby boomers will be older than 65 and “one in every 

five Americans is projected to be [at] retirement age.” See Jonathan Vespa, Lauren Medina, and David M. 

Armstrong, U.S. Dep’t of Commerce, U.S. Census Bureau, Demographic Turning Points for the United States: 

Population Projections for 2020 to 2060, (Mar. 2018, Rev. Feb. 2020), at 1, available at

https://www.census.gov/content/dam/Census/library/publications/2020/demo/p25-1144.pdf. 5 Public Law 115–70, 115th C. 9-45ongress (enacted Oct. 18, 2017).
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Appendix A, includes every administrative and federal district court action filed in the one-year 

period. In addition, the FTC files this report to provide detail on the agency’s efforts to protect 

older consumers, including its research and strategic initiatives, its law enforcement actions that 

impacted older adults, and its targeted consumer education and outreach.

II. Developing Effective Strategies to Protect Older Consumers

The FTC conducts research and analysis, publishes information about patterns and trends, 

and engages in coordinated efforts to protect older adults from financial loss and assist them with 

other consumer issues such as identity theft protection. The agency also works closely with 

stakeholders to learn about the top issues concerning older adults. The FTC can then use its 

limited resources strategically to respond to the needs of older consumers through enforcement, 

policy, education, and other initiatives.

A. Research and Data Analysis

The FTC’s most recent fraud survey released in October 2019 found that 15.9 percent of 

survey participants—representing 40 million U.S. adults—were victims of one or more of the 

frauds included in the survey.6 That same research demonstrated that, contrary to popular 

thinking, older Americans are not necessarily defrauded at higher rates than younger consumers 

for the surveyed frauds.7 Nevertheless, certain types of scams are more likely to affect certain 

groups. For example, older adults in the survey (ranging in age from 55 to 74) were more likely 

to be victims of fraudulent computer repair (“tech support”) schemes than were younger 

consumers.8 

The FTC collects and analyzes consumer report information through its Consumer 

Sentinel Network (“Sentinel”) to inform its consumer protection mission. Sentinel is an online 

database that provides federal, state, and local law enforcement agencies with secure access to 

reports from consumers about the fraud and other consumer problems they have experienced. 

Law enforcement agencies and other organizations9 contribute consumer reports to the database, 

which is searchable by criteria such as the type of fraud and the name, address, and telephone 

number of the reported entity. Using Sentinel, the FTC and its law enforcement partners can 

analyze reports filed by older adults to look for patterns and trends, identify problematic business 

practices and enforcement targets, and develop cases against targets under investigation.

 

6 FTC Bureau of Economics Staff Report, Mass-Market Consumer Fraud in the United States: A 2017 Update, at 

23-24 (Oct. 2019), available at https://www.ftc.gov/system/files/documents/reports/mass-market-consumer-fraudunited-states-2017-update/p105502massmarketconsumerfraud2017report.pdf (hereinafter “FTC Fraud Survey”). 7 Id at 76. 8 Id at 76-77, 79. 9 A list of Sentinel data contributors, including the U.S. Senate Special Committee on Aging and the AARP Fraud 

Watch Network, is located at https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors. 
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1. Consumer Sen�nel Reports from Older Adults

During calendar year 2019, Sentinel took in more than 3.2 million reports from 

consumers directly and through its data contributors. Of that number, 1.7 million reports were 

about fraud, 650,547 were about identity theft, and another 907,521 were about other consumer 

problems.

10 Consumers reported losing over $1.8 billion to fraud in 2019. About half of fraud 

reports filed in 2019 included consumer age information. Consumers who said they were 60 and 

older (older adults) filed 318,850 fraud reports with reported losses of more than $440 million. 

Key findings from the 2019 Sentinel data are:

• Older adults (ages 60 and over) were still the least likely of any age group to report 

losing money to fraud.

• Older consumers continued to report higher individual median dollar losses than 

younger adults (ages 20-59). The disparity in reported losses was particularly large 

among people 80 and over compared to younger adults.

• Older adults continued to be much more likely than younger consumers to report 

losing money on tech support scams, prize, sweepstakes and lottery scams, and 

family and friend impersonation. 

• Online shopping was the most commonly reported category of fraud in which people 

of all ages indicated they lost money, but older adults were less likely to report losing 

money to online shopping fraud than younger adults. 

• Romance scams, government imposter scams, and prize, sweepstakes and lottery 

scams caused the highest aggregate reported losses for older adults.

• When comparing contact methods, phone scams continued to result in the highest 

aggregate reported losses by older adults, particularly those 80 and older.

• Gift cards were still the overall payment method of choice for scammers, but wire 

transfer payments reportedly took the most dollars from older adults.

These findings, explored more fully below, help inform the FTC’s consumer education and law 

enforcement mission.

 

10 See generally FTC, FTC Consumer Sentinel Network (July 8, 2020), available at

https://public.tableau.com/profile/federal.trade.commission. These figures do not include reports about unwanted 

calls. Consumer Sentinel data is self-reported and not a survey. As such, individuals decide whether to file a report

and decide what information, if any, to provide. As noted below, not all consumers who file a report provide their 

age, payment method, amount of dollar loss, etc.
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a) Most Older Consumers Who Filed Fraud Reports Avoided Losing Any Money

As in 2017 and 2018, the overwhelming majority of Sentinel fraud reports filed in 2019 

by consumers 60 or older did not indicate any monetary loss. Figure 1, which controls for 

population size,11 shows that older adults were 64% more likely to file these no-loss reports 

about fraud they had spotted or encountered – but avoided losing money on – than consumers 

ages 20-59.

Moreover, it remained true in 2019 that older adults were less likely than younger 

consumers to report losing any money to fraud. Figure 1 shows that, after controlling for 

population size, older adults were 21% less likely to report losing money to fraud than 

consumers ages 20-59. This suggests that older adults may be more likely to avoid losing money 

when exposed to fraud, more inclined to report fraud when no loss has occurred, or a 

combination of these or other factors. As mentioned, the FTC fraud survey also found that the 

rates of victimization for the various categories of frauds included in the survey were generally 

lower for those 65 and older than for younger consumers.12

 

11 The comparison of older adults and younger consumers is normalized against the population size of each age 

group. The analysis is based on U.S. Census Bureau data for population by age. See U.S. Census Bureau, Annual 

Estimates of the Resident Population for Selected Age Groups by Sex for the United States (June 2020), available at 

https://www.census.gov/data/tables/time-series/demo/popest/2010s-national-detail.html. 12 See FTC Fraud Survey at 76-79.
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b) Older Adults Reported Higher Median Individual Dollar Losses than Younger Consumers

In 2019, the broad trend from prior years held: younger consumers were more likely to 

report losing money to fraud than older consumers, but older consumers who did report losing 

money reported much higher individual losses. Consumers 80 and over reported the largest 

median losses of $1,600. The median individual dollar loss for this 80 and over age group was 

about two to four times the median loss amounts reported by other age groups. These overall 

findings were about the same as those reported in 2018, with the median loss for those 80 and 

over decreasing slightly from $1,700 in 2018 to $1,600 in 2019.13

A closer look at the data shows a trend toward significatly lower median losses for older 

adults than appears at first glance. Higher reported median individual dollar losses in 2018 as 

compared to 2017 were due in large part to a surge in reports by older adults of losses to 

scammers posing as the Social Security Administration (SSA).14 Reports by older adults of SSA 

imposters continued to climb through the first quarter of 2019, when the median dollar loss 

reported by older adults reached $801, the highest on record.15 However, the numbers declined 

in subsequent quarters, a trend that has continued in 2020. By the second quarter of 2020, the 

median individual dollar loss reported by older adults fell to $419, about half the high reached 

 

13 See FTC Report to Congress, Protecting Older Consumers 2018-2019, at 4-5 (Oct. 18, 2019), available at

https://www.ftc.gov/system/files/documents/reports/protecting-older-consumers-2018-2019-report-federal-tradecommission/p144401_protecting_older_consumers_2019_1.pdf. 14 Id. 15 The median individual dollar loss reported in Q1 of 2019 by age group was $700 (60-69), $900 (70-79), and 

$2,000 (80 and over).
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just over a year earlier.16 The marked decline in median losses during this period can be 

explained, in part, by changes in the types of frauds in which older adults most often reported 

losing money and a decline in reports of phone fraud, as discussed below. 

Additional insights can be found by looking at the Sentinel reports filed on behalf of 

older consumers by adult children, spouses, caretakers, or others. In 2019, about 18% of reports 

for people 80 and over indicated they were submitted by a person on behalf of the consumer, 

compared to about 5% for people 70-79 and less than 3% for all other age groups.17 Notably, 

reported losses were higher for all reports submitted by third parties, but the median dollar loss 

for reports filed on behalf of adults 80 and over, at $3,800, was much higher than other reports.18

Also of note, nearly 90% of reports filed on behalf of people 80 and over were about a scam that 

started with a phone call. This suggests that third party interventions can be very helpful for 

recognizing and reporting fraud, especially where higher individual dollar losses occur. 

c) Some Types of Fraud Affected Older Consumers Differently from Younger Consumers

To identify the top scams that had a financial effect on consumers, Figure 3 displays the 

top fraud categories reported by older consumers in which they indicated they lost any money.

The dark teal bars show the number of loss reports submitted by older adults (age 60 and over), 

and the light green lines show the number of loss reports filed by younger people (ages 20 to 59) 

for each category of fraud. As shown in Figure 3, controlling for population size, older adults 

were more likely than younger consumers to report financial losses to certain types of frauds, but 

less likely to file loss reports on many other frauds. Three categories of fraud stand out. Older 

adults were: 1) nearly six times, or 474%, more likely than younger consumers to report losing 

money on a tech support scam; 2) three times more likely to report a loss on prize, sweepstakes 

or lottery scam; and 3) more than twice as likely to report a loss on a family or friend imposter 

scam. 

 

16 The median individual dollar loss reported in Q2 of 2020 by age group was $300 (60-69), $500 (70-79), and 

$1,000 (80 and over). These figures represent the lowest quarterly median dollar losses on record for adults 60-69

and 70-79, and a three-year low for adults 80 and over. 17 The percentage of reports submitted by another person on behalf of a consumer are as follows: 17.6% (80 and 

over), 5.2% (70-79), 2.5% (60-69), 1.9% (50-59), 1.4% (40-49), 1.3% (30-39), 1.7% (20-29). These figures exclude 

reports provided by Sentinel data contributors.

18 The reported median individual dollar loss on all fraud reports directly to the FTC in 2019 was $420, compared to 

$1,250 on fraud reports submitted directly to the FTC by another party on behalf of the consumer. The reported 

median individual dollar losses by age for this subset of reports were as follows: $3,800 (80 and over), $2,000 (70-

79), $1,300 (60-69), $1,000 (50-59), $1,000 (40-49), $700 (30-39), $892 (20-29). These figures exclude reports 

provided by Sentinel data contributors.
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Although older adults continued to be less likely than younger consumers to report losing

money to online shopping fraud, this fraud nonetheless surpassed tech support scams to become 

the top fraud type older adults reported losing money on in 2019.19 The number of reports of 

losses to online shopping by adults 60 and over more than doubled from the first quarter to the 

last quarter of 2019.20 This upward trend accelerated dramatically in the second quarter of 2020, 

with a rise in reports about online shopping problems related to the COVID-19 pandemic.21

However, the reported median individual dollar loss to online shopping fraud by older adults in 

2019 was relatively small at $129. Nevertheless, the increasing number of adults of all ages who 

have reported a loss to online shopping is significant.

 

19 Older adults filed 9,532 reports indicating a loss on online shopping fraud in 2019 compared to 5,548 such reports 

on tech support scams, the second highest category.

20 Older adults filed 1,499 reports indicating a loss on online shopping fraud in Q1 2019 compared to 3,174 such 

reports in Q4 2019.

21 Older adults filed 6,228 reports indicating a loss on online shopping fraud in Q2 2020. See FTC Consumer 

Protection Data Spotlight, Pandemic purchases lead to record reports of unreceived goods (July 1, 2020), available 

at https://www.ftc.gov/news-events/blogs/data-spotlight/2020/07/pandemic-purchases-lead-record-reportsunreceived-goods.
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Analysis of total dollars reported lost by older adults, by fraud type, as seen in Figure 4, 

highlights the devastating effects of romance scams, government imposter scams, and prize, 

sweepstakes, and lottery scams on older adults. The highest aggregate dollar losses reported in 

2019 by those 60 and older were again in the romance scam category. Older adults reported 

aggregate losses of nearly $84 million on romance scams in 2019. Adults 60-69 and 70-79 

reported over $80 million of these losses, making romance scams the category of highest 

reported losses for both of these age groups.22 Government imposter scams ranked next, taking

$61 million from adults 60 and over in 2019. The prize, sweepstakes, and lottery category ranked 

third for adults 60 and over, with $51 million in aggregate dollar losses reported. Note that 

almost half (over $22 million) of the losses reported by older adults on prize, sweepstakes, and 

lottery scams were reported by adults 80 and over, making that category of fraud the highest on 

total dollars reported lost for adults 80 and over.

 

22 For adults 80 and over, romance scams ranked sixth on aggregate reported dollar losses, with those adult reporting

$3.3 million in aggregate losses on romance scams in 2019. Sentinel fraud types classified as “unspecified” are 

excluded from fraud type ranking.
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Scammers posing as the Social Security Administration pushed reports of losses on 

government imposter scams by older adults to the highest level on record in 2019, more than 

30% higher than the 2018 number.23 Reported aggregate losses on government imposter scams 

by older adults also reached a record high. The number of loss reports on these scams began to 

decline in the last quarter of 2019, coinciding with a decline in reports of unwanted phone calls 

more generally.24 Scammers posing as government officials have been a menace to consumers of 

all ages for many years. Using low-cost VOIP phone services and robocall technology, they have 

reached millions of households posing as virtually every government agency, including the FTC. 

While a period of decline in government imposter reports is encouraging, the numbers of 

complaints about unwanted calls has been creeping up again. Monitoring of Sentinel reports will 

be essential to alert the public to new variations of these scams.25

d) Phone Scams Again Caused Large Losses, Particularly for Those 80 and Older

Phone scams continued to be a tremendous problem for older adults in 2019. Controlling 

for population size, older adults reported disproportionate aggregate losses on phone scams 

compared to younger consumers, as well as higher median individual losses.26 Median losses 

reported on phone fraud by older adults were far higher than on any other method of contact with 

the exception of mail fraud, which was much less frequently reported (see Figure 5). Phone 

scams were particularly costly to adults 80 and over. This age group reported median individual 

losses from phone scams of $3,500, and these losses were at a rate nearly four times that reported 

by adults 20-59. The data also suggest that attempted phone fraud is a tremendous concern for 

older adults. Over 70% of fraud reports to Sentinel by adults 60 and over in 2019 were about 

phone contacts with no reported dollar loss.

 

23 Older adults filed 5,015 reports indicating a loss on government imposter scams in 2019, compared to 3,809 

reports in 2018. 

24 See FTC Consumer Alert, The FTC keeps attacking robocalls, (Apr. 3, 2020) available at:

https://www.consumer.ftc.gov/blog/2020/04/ftc-keeps-attacking-robocalls; FTC Consumer Alert, Robocall reports 

still down, FTC still fighting, (June 15, 2020) available at: https://www.consumer.ftc.gov/blog/2020/06/robocallreports-still-down-ftc-still-fighting. 25 Survey research found that respondents who had heard about the specific scam before being targeted were 

significantly less likely to lose money. See FINRA Investor Education Foundation, BBB Institute for Marketplace 

Trust, & Stanford Center on Longevity, Exposed to Scams: What Separates Victims from Non-Victims? at 11 (Sept. 

2019) available at https://www.finrafoundation.org/sites/finrafoundation/files/exposed-to-scams-what-separatesvictims-from-non-victims_0_0.pdf. 26 In 2019, the median individual dollar losses reported by older adults to phone fraud were $1,100 (age 60-69), 

$1,625 (age 70-79), and $3,500 (age 80 and over), compared to $998 by consumers age 20-59. Reported losses to 

phone fraud per million population by age were $2.0 million (age 60-69), $2.7 million (age 70-79), and $3.8 million 

(age 80 and over), compared to $1.0 million by adults 20-59. 
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With respect to scams that started with a phone call, people 80 and over submitted more 

loss reports about prizes, sweepstakes, and lottery scams as well as family and friend imposters, 

while people 60-79 most often reported losing money on phone calls from government and 

business impersonators. Tech support scams, while no longer in the top spot, continued to be in 

the top four on phone fraud loss reports for both the 60-79 and 80 and over age groups.

Reports to Sentinel suggest that email and other online contact methods, including social 

media, are increasingly used to defraud older adults (see Figure 6).27 By the third quarter of 

2019, the combined number of loss reports by older adults that indicated the scam started online 

or with an email surpassed those that started with a phone call.28 That trend became more 

pronounced with the COVID-19 pandemic. In the second quarter of 2020, the tremendous 

volume of loss reports made by older adults about online shopping caused loss reports about 

online fraud to eclipse phone fraud loss reports.

29 Notably, reports by adults in their 60s and 70s 

drove this trend. This did not hold true for people 80 and over, as this population continued to 

report losses on phone frauds in numbers exceeding any other method of contact.30 

 

27 The number of loss reports by older adults indicating social media as the contact method increased from 289 in 

Q1 2019 to 967 in Q2 2020. These reports are included in the online data category displayed in Figure 6. 28 In the Q3 of 2019, the methods of contacts reported by older adults indicating a dollar loss were phone (39%), 

online (29%), consumer initiated contact (16%), email (10%), other (4%), mail (2%).

29 In the Q2 of 2020, the methods of contacts reported by older adults indicating a dollar loss were phone (24%), 

online (34%), consumer initiated contact (20%), email (16%), other (3%), mail (2%).

30 In the Q2 of 2020, the methods of contacts reported by adults 80 and over indicating a dollar loss were phone 

(50%), online (22%), consumer initiated contact (13%), email (10%), other (3%), mail (3%).
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e) Gift Cards Became the Payment Method of Choice for Scammers, but Wire Transfers Persist 

in the Top Spot for Total Dollars Paid 

Consumers reporting fraud frequently indicate what payment method they used, and this 

information helps the FTC identify opportunities for enforcement and consumer education. The 

first column in Figure 7 shows that older adults most often reported paying fraudsters with a gift 

card, reload card, or credit card in 2019. The second column in Figure 7 shows the aggregate 

dollar losses that older adults reported for the payment methods shown. 
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Beginning in 2018, the number of older adults who said they paid with gift cards or 

reload cards increased dramatically. This upward trend continued in the first half of 2019, 

peaking in the second quarter of 2019 before beginning a steady decline that has continued in 

2020.31 Over the same period, credit cards payments by older adults increased. Older adults also 

increasingly reported using internet or mobile payment services such as PayPal. The growth in 

reports of payments made by credit card and payment services can be attributed, in large part, to 

the increase in online shopping reports that came into Sentinel. Gift cards and reload cards 

continue to be the top payment method reported by older adults on many scams, including 

government and business imposter scams, tech support scams, family and friend emergency 

scams, and sweepstakes, prize, and lottery scams. 

In 2019, older adults again reported sending more money to fraudsters by wire transfer 

than by any other method. The median individual loss reported on wire transfers was $6,000, 

higher than on any other payment method.32 Wire transfers sent in connection with romance 

scams accounted for about $46 million, nearly a third of the dollars older adults reported wiring 

to scammers. In fact, the vast majority of the dollars reported lost on romance scams by older 

adults were sent by wire transfer, with a reported median individual dollar loss of $18,000.33

The FTC monitors Sentinel data for these and other important trends to inform its 

strategies for protecting older adults. Significant improvements to the Sentinel system have 

contributed to the agency’s efforts to identify enforcement targets strategically and enhance the 

agency’s education messages. Outreach efforts with stakeholders, described below, further 

improve the system by increasing the number of reports from consumers. The FTC has also 

worked to increase the number of data contributors providing reports to Sentinel, and was 

 

31 In Q2 2019, adults 60 and over filed 2,611 reports directly with the FTC indicating payment by gift card or reload 

card. By Q2 2020, that number had dropped to 1,853. These figures exclude reports classified as online shopping 

fraud. The FTC has tracked the gift card brands that are most often mentioned in fraud reports, and has initiated 

discussions with top brands regarding fraud prevention measures. FTC Consumer Protection Data Spotlight,

Scammers increasingly demand payment by gift card (Oct. 16, 2018), available at https://www.ftc.gov/news-events/blogs/dataspotlight/2018/10/scammers-increasingly-demand-payment-gift-card. Currently, eBay is the most frequently reported gift 

card brand. 32 In 2019, reported median dollar losses by older adults for the payment methods included in Figure 7 were as 

follows: wire transfer ($6,000), cash or cash advance ($5,500), check ($1,500), gift\reload cards ($1,000), internet or 

mobile ($250), credit cards ($220), bank account debit ($199). Median dollar losses are based on the total loss 

amount indicated in each individual report, which can include more than one financial transaction. Wire transfer 

companies MoneyGram International and Western Union, and reload card provider Green Dot, contribute a 

significant number of reports to Sentinel each year. As noted in Figure 7, to avoid distorting the number of reports 

indicating certain payment methods, data provided by data contributors are excluded. 33 In 2019, 68% of the dollars reported lost on romance scams by older adults were sent by wire transfer. The 

median dollar loss figure of $18,000 is based on the total loss amount indicated in each romance scam report, which 

will often include more than one wire transfer transaction. As in the previous footnote, data provided by data 

contributors are again excluded.
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pleased to welcome Utilities United Against Scams in 2019, adding thousands of reports about 

utility company impersonators to the Sentinel database.

2. Aler�ng the Public to Consumer Repor�ng Trends

The FTC makes aggregate consumer reporting data accessible by publishing Sentinel 

data on a quarterly basis in interactive online dashboards available at www.ftc.gov/exploredata. 

The dashboards include both quarterly and annual report information by age and fraud type.34

Image A – Portion of the Explore Age & Fraud Losses interactive infographic

In 2020, in response to the pandemic, the FTC launched interactive dashboards providing 

aggregate data about the reports of frauds associated with COVID-19 and related stimulus 

money offers. The dashboards show trends about the reports by age, type of fraud, and 

geographical location.

35 These dashboards are updated daily, providing the media, consumer 

groups, and other government agencies with the most current data available to respond to 

consumer protection problems related to the pandemic. These and other interactive dashboards 

help users understand and visualize consumer reporting trends.

 

34 In 2019, the FTC added new dashboards pertaining to age. The new Explore Age & Fraud Losses interactive 

infographic is available at 

https://public.tableau.com/profile/federal.trade.commission#!/vizhome/AgeandFraud/Infographic, and the new Age 

Details interactive dashboard is available at

https://public.tableau.com/profile/federal.trade.commission#!/vizhome/FraudReports/AgeDetails. 35 FTC COVID-19 and Stimulus Reports interactive dashboards are available at 

https://public.tableau.com/profile/federal.trade.commission#!/vizhome/COVID-19andStimulusReports/Map.
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Image B – FTC COVID-19 and Stimulus Reports Interactive Dashboard

3. Hearing Directly from Older Consumers About FTC Imposters

The FTC continued a pilot program this year that directly engages with older consumers 

who reported losing money to scammers pretending to be FTC staff.36 Between July 1, 2019 and 

June 30, 2020, more than 100 consumers age 60 and over reported to the FTC that they lost more 

than $1,000 to FTC impersonators. Most of these people reported that the scammers told them 

they had won prizes, money, cars, or boats, and the FTC would distribute the benefits once the 

consumers paid fees. Some of the FTC imposter reports described identity theft and malware 

schemes. FTC staff spoke to the majority of people who filed these reports to explain that the 

FTC does not distribute prizes, money or grants, and provided additional information to the 

consumers as needed. 

Scammers used the government’s name to generate immediate trust, and built on that 

relationship by collecting personal details that helped create anticipation over time. A perceived 

connection with the government made the consumers more willing to believe the caller and more 

likely to send funds. The older adults who described the sweepstakes and prize scams provided 

details of long, drawn out schemes in which the scammers built relationships with the older 

adults to gain their trust. The scammers kept track of details in the consumer’s life, asked about 

the consumer’s family and health, and presented themselves as friends. The scammers often 

asked for smaller amounts of money several times instead of asking for one large payment. They 

 

36 See, e.g., FTC Consumer Alert, Scammers impersonate the FTC, too (July 14, 2020) available at 

https://www.consumer.ftc.gov/blog/2020/07/scammers-impersonate-ftc-too.
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FEDERAL TRADE COMMISSION FTC.GOV 15

gave detailed instructions on how these payments were to be made and checked back to see that 

the payments had been sent. The scammers maintained excitement and reinforced secrecy by

making their calls into a daily “update” for an event that will change the consumer’s life, and that 

only they know about. One older adult was told that he was under a “gag” order and that if he 

told anyone of his prize or the fees he was paying that it would immediately be forfeited. 

These scams take a significant emotional toll. Once they accept that they have been 

speaking to impostors and that they have sent away large sums of money that they are not likely 

to recover, many of these older adults expressed feelings of profound shame and embarrassment. 

Some have sent much of their savings in the hope that the prize winnings would be their legacy 

to their children and grandchildren. All of the older adults are deeply affected by having been 

lied to and having believed those lies long enough to give away a great deal of money. In 

addition to providing important information to these older adults, these conversations provide 

valuable insights to inform how the FTC works to combat government imposter fraud.

B. Coordinated Efforts to Protect Older Consumers

The FTC’s Every Community Initiative leads the agency’s strategic planning for the 

protection of older consumers. Understanding that different types of frauds affect different 

groups of consumers, the Initiative examines the impact of various schemes on distinct groups, 

including older adults, military service members and veterans, Black Americans, Latinos, Asian 

Americans, Native Americans, and other groups. The Initiative includes staff throughout the 

Bureau of Consumer Protection and the FTC’s regional offices who use research and input from 

stakeholders in communities to develop strategies to prevent fraud, inform the agency’s law 

enforcement program, and expand outreach. As discussed further in Section IV, these 

partnerships across the country have been extremely valuable as the FTC identifies potential 

cases and further develops strategies to protect older adults in a wide range of communities from 

financial loss.

The FTC continues to coordinate with federal, state, local, and international law 

enforcement agencies, including those with criminal authority, leveraging resources to track 

down fraudsters and build actions to stop them. With the Department of Justice (“DOJ”), the 

FTC organizes and participates in the International Mass Marketing Fraud Working Group, a 

multilateral network of agencies that enforces laws prohibiting mass marketing fraud. The 

Working Group has been pivotal in enforcement actions against entities that have defrauded 

millions of older consumers.

Further, the FTC has continued to be an active member of the Elder Justice 

Coordinating Council, a multi-agency federal entity charged with identifying and proposing 

solutions to elder abuse, neglect, and financial exploitation. Part of the Council’s mission is to 
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develop recommendations to the Secretary of the Department of Health and Human Services 

(“HHS”) for the coordination of relevant activities.37 The FTC’s Elder Justice Coordinator 

presented information about the FTC’s enforcement, data analysis, and outreach materials at the 

December 2019 and June 2020 EJCC meetings.38 This work connects the agency with other 

federal government offices that are working to combat elder abuse and facilitates valuable 

information sharing and coordination. 

III. FTC Enforcement Activities Affecting Older Consumers

Aggressive law enforcement is a key component in the FTC’s efforts to protect older 

consumers.39 Congress has directed the FTC to list “each case in which not less than one victim 

was an elder or that involved a financial scheme or scam that was either targeted directly toward 

or largely affected elders.”40 Most FTC enforcement actions involve numerous consumers of all 

ages, but the actual ages of consumers affected in a given case are not typically known. Based 

upon our law enforcement experience, the Commission is of the view that people ages 60 or 

older are in the groups of affected consumers in every consumer protection case filed this past 

year. Therefore, Appendix A to this report lists all new enforcement actions brought by the FTC 

(or by the DOJ on the FTC’s behalf) between October 1, 2019, and September 30, 2020. The 

cases listed in Appendix A involve a wide range of matters, including alleged business 

opportunity and money-making schemes, unsubstantiated product claims, privacy and security 

issues, credit or debt relief schemes, and more.41

To provide a better description of the FTC’s work to protect older consumers, the next 

section summarizes nineteen enforcement actions filed within the last fiscal year where the 

Commission notes a significant impact on older consumers. Also listed are additional agency 

 

37 HHS convened the Elder Justice Coordinating Council in accordance with the Elder Justice Act of 2009. The 

Council consists of heads of federal departments and other government entities, including the FTC, identified as 

having responsibilities, or administering programs, relating to elder abuse, neglect, and exploitation. See HHS, What 

is the Elder Justice Coordinating Council? (last modified Aug. 26, 2020), available at 

https://www.acl.gov/programs/elder-justice/elder-justice-coordinating-council-ejcc. 38 Recordings of the EJCC’s meetings are available at https://acl.gov/programs/elder-justice/fall-2019-ejcc-meeting

and https://acl.gov/programs/elder-justice/spring-2020-ejcc-meeting. 39 When staff identifies unfair or deceptive acts or practices that harm consumers, the FTC often sues the fraudsters 

in federal district court, seeking injunctive relief to stop illegal business practices as well as monetary relief in the 

form of redress for consumers or disgorgement of ill-gotten gains. The agency can also bring cases through 

administrative process. In some circumstances, the DOJ files cases on the FTC’s behalf for rule violations or to 

secure civil penalties for violations of FTC administrative orders.

40 The Elder Abuse Prevention and Prosecution Act, Public Law 115–70, Oct. 18, 2017. Sec. 101(c)(2). 41 This list includes cases involving student loan debt relief schemes and violations of children’s privacy laws. The 

perpetrators of such schemes may not typically target older adults, but the cases are listed because they involve large 

and diverse groups of consumers. The affected consumers may include an older adult paying off student debt for 

him or herself or for an adult child, or an older parent or grandparent caring for children who go online and wish to 

protect their privacy.
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actions that affected older consumers, including final resolutions and settlements in prior actions, 

warning letters, issuance of consumer refunds, and subsequent criminal action by other agencies 

relating to FTC matters. These actions illustrate many of the key consumer issues that 

disproportionately affect older adults.

A. Credit Card Interest Rate Reduc�on Scheme

In GDP Network LLC, the FTC and the Florida Attorney General’s Office alleged that 

the defendants ran a sham credit card interest rate reduction operation that often targeted 

financially distressed consumers and older adults.42 The defendants allegedly blasted consumers 

with telemarketing cold calls promising to permanently and substantially reduce their credit card 

interest rates. After convincing consumers they were affiliated with the consumers’ existing 

credit card companies or well-known credit card networks such as MasterCard or Visa, the 

defendants allegedly promised to save them thousands of dollars in credit card interest and 

enable them to pay off their credit card debt three to five times faster. The complaint states that 

the defendants charged upfront fees of as much as $3,995 for their bogus services and that many 

consumers who paid the fees received no permanent debt reduction and were left with more debt 

and worse credit. A federal court temporarily halted the operation, froze the defendants’ assets, 

and appointed a receiver over the businesses. Litigation is ongoing. 

B. Decep�ve Publica�ons and Government Check Program

In Agora Financial, LLC, the FTC alleged that the defendants tricked older adults into 

buying books, newsletters, and other publications that falsely promised a cure for type 2 diabetes 

or promoted a phony plan to help get money from a government-affiliated check program.43 The 

defendants allegedly made several baseless claims and told consumers that type 2 diabetes could 

be cured in 28 days with a combination of hard-to-find natural ingredients. In reality, the FTC 

alleged, their claims were unsubstantiated, and the defendants’ purported treatment consisted of 

common, widely available supplements. The FTC also alleged that the defendants marketed

additional publications falsely promising to show how to claim hundreds to thousands of dollars

every month from a “Congressional” check program and that consumers who bought the

publications found that they merely described an investment strategy focused on stocks that pay 

dividends, requiring consumers to risk thousands of dollars to obtain the promised amounts. This 

litigation is ongoing.

 

42 FTC v. GDP Network LLC, No. 6:20-cv-1192-Orl-78DCI (M.D. Fla. filed Jul. 6, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/192-3137/gdp-network-llc-et-al-ftc-v-yf-solutions. 43FTC v. Agora Financial, LLC, No. 1:19-03100 (D. MD filed Oct. 24, 2019), available at 

https://www.ftc.gov/enforcement/cases-proceedings/182-3116/agora-financial-llc.
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Image C – Online Advertisement from Agora Financial, LLC

C. Business Opportuni�es, Pyramids, and Money-Making Schemes

In OTA Franchise Corp., the FTC alleged that the defendants used false or 

unsubstantiated earnings claims, often targeted at older consumers, to sell “training programs” 

costing as much as $50,000.44 The FTC also alleged that the defendants misrepresented that the 

company had a patented “strategy” that anyone could use to generate substantial income from 

trading in the financial markets. Evidence obtained by the FTC indicated that many of the 

defendants’ customers did not make any money, and many lost money on top of the money they 

paid the defendants. Evidence obtained by the FTC also indicated that instructors’ claims of 

amassing wealth were false or unsubstantiated. A federal court has granted the FTC’s request for 

a preliminary injunction. In September 2020, the defendants agreed to a settlement order that 

among other things prohibits them from making claims about potential earnings unless the 

claims are truthful and they have written documentation to support them. The defendants will be 

required to offer debt forgiveness to thousands of consumers who purchased its “training 

programs,” while the company’s founder and other individuals will together pay between $5 and 

$9.1 million and turn over assets under the terms of a settlement that is expected to result in more 

than $10 million to benefit consumers.

45

In Nudge LLC, the FTC and the Utah Division of Consumer Protection alleged that the 

defendants made empty promises about earning money by “flipping” houses, to convince 

 

44 FTC v. OTA Franchise Corp., 8:20-cv-00287-JVS-KES (C.D. Cal. filed Feb. 12, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/1823175/online-trading-academy. 45 Press Release, FTC, FTC Settlement Requires Online Trading Academy to Forgive Consumer Debt, and 

Principals to Turn Over Millions in Cash and Assets (Sept. 15, 2020), available at https://www.ftc.gov/newsevents/press-releases/2020/09/ftc-settlement-requires-online-trading-academy-forgive-consumer. 
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consumers to buy real estate training packages that cost thousands of dollars.46 The complaint 

states that the defendants marketed training through real estate celebrities who promised to 

reveal strategies for making “amazing profits” at seminars included in the packages but that in 

truth, the seminars were mostly designed to sell additional training, not to help consumers make 

money. The FTC also alleged the defendants encouraged consumers to incur significant debt to 

purchase defendants’ purported training programs. Consumers victimized by this scheme 

included those on limited fixed incomes and retirees. The parties reached a stipulated preliminary 

injunction in December 2019. In August 2020, the FTC filed a motion to amend the complaint to 

add two celebrities that the defendants used to promote their real estate training programs.47 This 

litigation is ongoing.

In Neora LLC (formerly Nerium International, LLC) the FTC alleged the defendants 

operated as an illegal pyramid scheme and falsely promised recruits they would achieve financial 

independence if they joined.

48 The company sold supplements, skin creams, and other products 

through a network of “brand partners.” The FTC alleged the company pushed distributors or 

brand partners to focus on recruiting new distributors, rather than retail sales to customers. The 

defendants allegedly incentivized recruits to make a substantial upfront investment in products 

and then commit to additional product purchases each month. The FTC also alleged that the 

defendants deceptively promoted one of its products, “EHT” supplements, as an antidote to 

concussions and chronic traumatic encephalopathy caused by repetitive brain trauma, as well as 

Alzheimer’s disease and Parkinson’s disease. Without having a scientific basis for the claims, the 

defendants’ website allegedly highlighted the benefits for individuals facing memory loss, 

cognitive decline, and other ailments associated with aging. The FTC settled with two of the 

defendants and those defendants are barred from making baseless claims about EHT or other 

supplements. Litigation is ongoing with the remaining defendants.

 

46 FTC v. Nudge, LLC, No. 2:19-cv-00867-RJS (D. Utah filed Nov. 5, 2019), available at 

https://www.ftc.gov/enforcement/cases-proceedings/182-3016/nudge-llc. 47 Press Release, FTC, FTC Seeks to Add Real Estate Investment Celebrities Dean Graziosi and Scott Yancey as 

Defendants in Real Estate Training Case (Aug. 31, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/08/ftc-seeks-add-real-estate-investment-celebrities-dean-graziosi. 48 FTC v. Neora, LLC, formerly known as Nerium International, LLC, et al., No. 3:19-cv-19699 (D.N.J. filed Nov. 1, 

2011), available at https://www.ftc.gov/enforcement/cases-proceedings/162-3099/nerium-international-llc.
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FEDERAL TRADE COMMISSION FTC.GOV 20

Image D – Advertising Image from Neora, LLC

In two additional cases, Giannulis49 and Bransfield,

50 the FTC sued a group of affiliate 

marketers who lured consumers into a business coaching and investment scheme known as My 

Online Business Education (MOBE), which the agency sued in 2018.

51 The FTC alleged that

these affiliates made millions of dollars in commissions by enticing thousands of consumers to 

pay as much as $60,000 for MOBE “mentoring” services, using false claims and misleading 

testimonials about how much money they could make. The defendants advertised on social 

media, YouTube, online news sites, and at live events, specifically targeting teenagers, students, 

and older consumers. The FTC alleged that ultimately, most people who bought into the MOBE

program were unable to recoup their costs, and many experienced crippling losses or mounting 

debts. The FTC further alleged that one set of defendants started another deceptive coaching 

scheme, called “My Ecom Club,” after MOBE was shut down. The matters settled with orders 

permanently banning the defendants from selling or marketing any business coaching program or 

money-making method. One of the settlement orders requires one of the defendants to pay $3.3 

million. The other orders impose monetary judgments of $1.8 to $31.6 million, which are 

 

49 FTC v. Giannulis, No. 6:20-cv-00371-CEM-GJK (M.D. Fla. filed Mar. 3, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/192-3089/michael-giannulis-ftc-v. 50 FTC v. Bransfield, No. 6:20-cv-00372-CEM-GJK (M.D. Fla. filed Mar. 3, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/steven-j-bransfield. 51 FTC v. MOBE, Ltd., No. 6:18-cv-862-ORL-37DCI (M.D. Fla. filed June 4, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3072/mobe-ltd-et-al.
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suspended due to the defendants’ inability to pay, with some of the defendants paying partial 

amounts.52

D. Assis�ng and Facilita�ng Payments

In Qualpay Inc., the FTC alleged the company processed payments for years for MOBE, 

the online coaching and investment scheme mentioned above that targeted U.S. consumers, 

including service members, veterans, and older adults.

53 Qualpay allegedly processed tens of 

millions of dollars in consumer payments for MOBE’s worthless coaching products, ignoring 

clear warning signs that its client operated an unlawful scheme. The FTC alleged Qualpay did 

not follow its own internal policies when failing to review MOBE’s business practices in detail

because such review would have revealed numerous elements that should have eliminated 

MOBE as a client. The parties agreed to a settlement order that prohibits Qualpay from 

processing payments for business coaching companies or other merchants designated as highrisk. The settlement also prohibits Qualpay from making, or assisting merchants in making, 

deceptive statements to consumers or working to avoid fraud or risk monitoring programs, and 

requires the company to engage in careful screening and monitoring of card-not-present 

merchants. The settlement imposes a monetary judgment over $46 million, which is suspended 

due to Qualpay’s inability to pay.

In RevenueWire, Inc., the FTC alleged the defendants laundered credit card payments 

for, and assisted and facilitated, two tech support scams previously sued by the FTC.54 The 

FTC’s complaint states that RevenueWire entered into contracts with payment processors to 

obtain merchant accounts to process credit card charges for its own sales of eBooks and 

software, and that the contracts prohibited RevenueWire from submitting third-party sales 

through its merchant accounts. However, the FTC alleged that RevenueWire used its accounts to 

process credit card charges and collect payments from consumers on behalf of two companies 

that tricked consumers, many of whom were older adults, out of millions of dollars through tech 

support schemes. In the previous lawsuits against Inbound Call Experts, Inc.55 and Boost 

 

52 Press Release, FTC, Affiliate Marketers to Pay More Than $4 Million to Settle Charges that They Promoted a Fraudulent 

Business Coaching and Investment Scheme (Mar. 5, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/03/affiliate-marketers-pay-more-4-million-settle-charges-they. 53 FTC v. Qualpay, Inc., No. 6:20-cv-00945 (M.D. Fla. filed June 1, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/192-3103/qualpay-inc; see also FTC v. MOBE, Ltd., No. 6:18-

cv-862-ORL-37DCI (M.D. Fla. filed June 4, 2018), available at https://www.ftc.gov/enforcement/casesproceedings/172-3072/mobe-ltd-et-al. 54 FTC v. RevenueWire, Inc., No. 1:20-cv-01032 (D.D.C. filed Apr. 20, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/162-3087/revenuewire-inc. 55 FTC v. Inbound Call Experts, LLC, No. 9:14-cv-81395-KAM (S.D. Fla. filed Nov. 10, 2014), available at 

https://www.ftc.gov/enforcement/cases-proceedings/132-3135/inbound-call-experts-llc.
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FEDERAL TRADE COMMISSION FTC.GOV 22

Software, Inc.,

56 the FTC alleged the companies deceptively represented that consumers’ devices 

had viruses or performance problems and needed to be repaired at a cost of hundreds of dollars. 

RevenueWire also allegedly processed charges for lead generators that directed consumers to call 

the deceptive computer repair companies. The defendants agreed to an order requiring them to 

pay $6.75 million and permanently banning them from any further payment laundering. They are 

also required to screen and monitor high-risk clients to ensure those clients are not misleading 

consumers.

E. Unsubstan�ated Health Claims

The FTC filed ten new actions this year against entities for deceptively pitching products 

that would purportedly treat or cure medical concerns that disproportionately affect older adults. 

In all of the complaints, the FTC alleged that the defendants could not substantiate their claims.

In NatureCity, LLC, the FTC alleged the defendants deceived consumers with false and 

unsupported claims that two products, TrueAloe and AloeCran, were effective treatments for a 

range of conditions affecting older adults, including chronic pain, ulcerative colitis, diabetes, and

acid reflux.57 The parties agreed to a settlement order that bars the defendants from making false 

and unsubstantiated health claims and requires them to pay $537,500. In May 2020, the FTC sent 

over 22,000 checks totaling over $470,000 to consumers who purchased the defendants’ 

products.

58

 

56 FTC v. Boost Software, Inc., No. 14-cv-81397 (klr) (S.D. Fla. filed Nov. 10, 2014), available at 

https://www.ftc.gov/enforcement/cases-proceedings/132-3283-x150040/boost-software-inc. 57 FTC v. NatureCity, LLC, No. 9:19-81387 (S.D. Fla. filed Oct. 10, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3153/naturecity-llc. 58 Press Release, FTC, FTC Sending Refund Checks Totaling More Than $470,000 to Consumers Defrauded by 

Misleading Health Claims for TrueAloe and AloeCran Supplements (May 26, 2020), available at

https://www.ftc.gov/news-events/press-releases/2020/05/ftc-sending-refund-checks-totaling-more-470000-

consumers. 
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Image E – Advertisement for AloeCran in Nature City, LLC

In A.S. Research LLC, the FTC alleged the defendants used deceptive tactics to mislead 

consumers into thinking their dietary supplement called Synovia could treat arthritis and alleviate 

joint pain.59 The defendants allegedly featured consumer testimonials that were often phony, 

including one showing a user who purportedly “gave away his walker” after using Synovia. The 

complaint further alleged that the defendants falsely claimed that consumers needed to pay extra 

for a version of Synovia containing an added ingredient to increase pain relief and speed joint 

repair, when in fact all purchasers received that product. The defendants agreed to a settlement 

that bars them from making deceptive claims, prohibits them from misrepresenting the results of 

any scientific study or endorsement, and requires them to disclose any material connections they 

have with endorsers. It imposes a judgment of more than $4.1 million, which will be partially 

suspended after they pay $821,000.

In Quantum Wellness Botanical Institute, LLC, the FTC alleged the defendants

deceptively claimed that their product, a pill called ReJuvenation containing amino acids and 

 

59 FTC v. A.S. Research LLC, No. 1:19-cv-03423 (D. Col. filed Dec. 5, 2019), available at 

https://www.ftc.gov/enforcement/cases-proceedings/182-3126/research-llc-synovia.
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FEDERAL TRADE COMMISSION FTC.GOV 24

herbal extracts, was a virtual cure-all for age-related ailments — including cell damage, heart 

attack damage, brain damage, blindness, and deafness — and even aging itself. 60 According to 

the defendants’ ads, ReJuvenation could reverse the aging process and repair age-related damage 

to the body by increasing human growth hormone and the number of stem cells in the body. The 

ads also claimed users would see the reduced appearance of wrinkles and significant 

improvements in their memory and cognitive functioning. In addition, the defendants claimed 

that ReJuvenation could repair the damage from or reverse a number of ailments, including 

Alzheimer’s disease, Parkinson’s disease, and Crohn’s disease. The FTC charged these claims 

were misleading or lacked substantiation. The orders settling the FTC’s complaint prohibit the 

defendants from making such claims unless they are true and supported by scientific evidence. 

The orders also require disgorgement of $660,000. As of June 2020, the FTC has sent full 

refunds to 1,310 consumers who bought ReJuvenation.

61

Image F – Advertising Mailer from Quantum Wellness Botanical Institute, LLC

 

60 FTC v. Quantum Wellness Botanical Institute, LLC, No. 2:20-cv-00244-SMB (D. Ariz. filed Feb. 3, 2020),

available at https://www.ftc.gov/enforcement/cases-proceedings/172-3131/quantum-wellness-botanical-institute-llc. 61 Press Release, FTC, FTC Sending Refund Checks Totaling Almost $149,000 to Consumers Who Bought 

ReJuvenation “Anti-Aging” Pill (June 1, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/06/ftc-sending-refund-checks-totaling-almost-149000-consumers-who.
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FEDERAL TRADE COMMISSION FTC.GOV 25

In ZyCal Bioceuticals Healthcare Company, Inc., the FTC alleged the defendants falsely 

claimed their products could grow bone and cartilage, and thereby relieve joint pain.62 The 

complaint alleged that the claims were not supported by scientific evidence, and that the 

defendants used deceptive testimonials to sell the products. Two of the defendants, Excellent 

Marketing Results and its president, agreed to settle the case as to claims for their product 

StimTein. They are prohibited from making health-related product claims without competent and 

reliable scientific evidence and from using deceptive testimonials. The $3.6 million StimTein 

judgment was partially suspended upon payment of $145,000. In September 2020, the FTC sent 

over 12,000 checks totaling more than $110,000 to StimTein consumers.63 Litigation continues 

against the Zycal defendants.

In Neurometrix, Inc., the FTC alleged the defendants deceptively claimed their product, 

Quell, an electrical nerve stimulation device, would treat pain throughout the body when placed 

below the knee.

64 The FTC alleged that the defendants lacked scientific evidence to support 

widespread chronic pain relief claims and that their claims about clinical proof and the scope of 

clearance by the U.S. Food and Drug Administration (FDA) were false. The order settling the 

case bars the defendants from making pain-relief claims unless they are true, not misleading, and 

supported by competent and reliable scientific evidence; prohibits misrepresentations about 

clinical proof or the scope of FDA clearance; and requires them to pay redress. The order 

imposes a $4 million judgment and requires the defendants to turn over up to an additional $4.5 

million in future foreign licensing payments. In September 2020, the FTC returned almost $3.9 

million to consumers in this case.

65

In Health Center Inc., the FTC alleged the defendants deceptively advertised and sold 

three “cure-all” health and wellness products that targeted older consumers.66 The defendants 

advertised that these products, Rejuvi-Cell, Rejuvi-Sea, and Rejuvi-Stem, could treat or cure a 

wide range of serious diseases and health conditions, including cancer, diabetes, Alzheimer’s 

disease, heart disease, obesity, rheumatoid arthritis, and depression, without having the scientific 

evidence to back up their claims. The defendants also falsely claimed that Rejuvi-Cell contained 

 

62 FTC v. ZyCal Bioceuticals Healthcare Company, Inc., No. 1:20-cv-10249-TSH (D. Mass. filed Feb. 20, 2020),

available at https://www.ftc.gov/enforcement/cases-proceedings/182-3133/zycal-bioceuticals-healthcare-companyinc-et-al. 63 Press Release, FTC, FTC Refunds More Than $110,000 to Consumers Who Bought StimTein Joint Pain Relief 

Pills (Sept. 17, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/09/ftc-refunds-more110000-consumers-who-bought-stimtein-joint-pain. 64 FTC v. Neurometrix, Inc., No. 1:20-cv-10428 (D. Mass. filed Mar. 3, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/1723130/neurometrix-inc. 65 Press Release, FTC, FTC Refunds Almost $3.9 Million to Purchasers of Deceptively Advertised Quell Wearable 

Pain-Relief Device (Sept. 8, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/09/ftcrefunds-almost-39-million-purchasers-deceptively-advertised. 66 FTC v. Health Center Inc., No. 2:20-cv-547 (D. Nev. filed Mar. 19, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/182-3002/health-center-inc.
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FEDERAL TRADE COMMISSION FTC.GOV 26

human growth hormone, when it actually only contained pig growth hormone. Further, the FTC 

alleged the advertisements contained fake consumer testimonials in which the company’s 

employees provided positive product reviews. The defendants agreed to a settlement order 

prohibiting them from engaging in the alleged deceptive conduct and imposing an $8.62 million 

judgment, which will be partially suspended after they pay the FTC $5,000.

Image G – Excerpt from the Rejuvi-Sea Website, www.healthcenterinc.net

In Renaissance Health Publishing, the FTC alleged the defendants promoted their

Isoprex supplement, mostly herbs and spices, to older adults as a miracle cure for pain and joint 

inflammation.67 The defendants falsely claimed to have tests and studies to back up their product 

claims. The FTC also alleged the defendants failed to disclose that the endorsers appearing in 

their Isoprex ads either were compensated for their testimonials, or were company employees or 

their relatives. The defendants agreed to an order prohibiting them from making further unproven 

claims and from misrepresenting the results of scientific tests, studies, or research, including 

those regarding pain relief and inflammation. The order requires the defendants to disclose any 

material connections with their product endorsers, and it imposes a judgment of $3.93 million, 

which will be partially suspended due to an inability to pay, after the defendants pay $100,000.

In September, the FTC sent over 4,700 checks totaling more than $76,000 to consumers who 

bought Isoprex.68

 

67 FTC v. Renaissance Health Publishing, LLC, No. 9:20-cv-80640-DMM (S.D. Fla. filed Apr. 15, 2020), available 

at https://www.ftc.gov/enforcement/cases-proceedings/renaissance-health-matter. 

68 Press Release, FTC, FTC Refunds More Than $76,000 to Consumers Who Bought Deceptively Marketed 

“Miracle” Pain Cure for Older Adults (Sept. 24, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/09/ftc-refunds-more-76000-consumers-who-bought-deceptively-marketed.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 27

Image H – Advertisement from Renaissance Health Publishing

In Mile High Madison Group, Inc., the FTC alleged the marketers of three supplements 

called Neurocet, Regenify, and Resetigen-D deceptively promoted their products to older 

Americans through direct mailing and online using false claims that their products could stop 

pain and treat age-related ailments.69 The defendants claimed their products were anti-aging 

cure-alls that could repair cells and were clinically proven to treat multiple ailments. The FTC

alleged the defendants also deceptively advertised through fake doctor endorsements and 

consumer testimonials. The defendants agreed to a settlement order barring them from making 

any claims about the health benefits of their products unless they are true and supported by 

scientific evidence. The order also imposed a judgment of more than $38.1 million, which will 

be partially suspended due to an inability to pay, after the defendants pay $1.3 million.

 

69 FTC v. Mile High Madison Group, Inc., No. 1:20-cv-21622-FAM (S.D. Fla. filed Apr. 17, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3132-172-3143/nordic-clinical-inc-encore-plus-solutionsinc.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 28

Image I – Portion of Mailer in Mile High Madison Group, Inc.

In Physician’s Technology LLC, the FTC alleged the defendants deceptively claimed 

their light therapy device called Willow Curve could treat chronic, severe pain and associated 

inflammation.70 They also allegedly misrepresented that Willow Curve was approved by the 

FDA to diagnose and treat chronic, severe pain and reduce inflammation. In addition, the FTC 

alleged that the defendants’ marketing campaign included the use of deceptive “native” ads, 

which were commercial content disguised as independent journalistic content. Further, the 

complaint states that defendants deceptively claimed Willow Curve came with a “risk free 

money back” guarantee, whereas, in reality, consumers who returned the device had to pay 

shipping and handling costs and often did not receive a refund at all or had to wait more than a 

year for it. The defendants agreed to a settlement order prohibiting the deceptive health claims, 

barring the deceptive refund and native advertising practices, and prohibiting them from 

providing others with the means to engage in the same illegal conduct. The order imposes a $22 

million judgment, which will be partially suspended after two of the defendants each pay 

$200,000, based on their ability to pay.

 

70 FTC v. Physician’s Technology LLC, No. 2:20-cv-11694-NGE-RSW (E.D. Mich. filed June 25, 2020), available 

at https://www.ftc.gov/enforcement/cases-proceedings/172-3129/physicians-technology-llc.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 29

Image J - Advertisement for Willow Curve from Physician’s Technologies

In Golden Sunrise Nutraceutical, Inc., the FTC alleged the defendants deceptively 

advertised a group of dietary supplements as a safe and effective treatment for COVID-19, the 

disease caused by coronavirus.71 The defendants began marketing their “Emergency D-Virus 

plan” as a treatment for COVID-19 in March 2020, falsely claiming that the company’s 

supplements—ImunStem, Aktiffvate, and AnterFeerons— were “uniquely qualified to treat and 

modify the course of the coronavirus epidemic in CHINA and other countries,” and that users 

could expect the “disappearance of viral symptoms within two to four days.” The FTC sent a 

letter to the company in April 2020, warning that it should immediately remove all advertising 

claims that the products could prevent, treat, or cure COVID-19. Yet the defendants continued to 

market the plan as a COVID-19 treatment. The FTC also alleged that the defendants have 

promoted and sold dietary supplements as treatments for cancer and Parkinson’s disease, as well 

as many other serious health conditions and diseases. Some of the defendants’ treatments cost as 

much as $170,000 to $200,000. In reality, the FTC alleged, the defendants’ supplements are 

composed of mainly various herbs and spices, and the health claims are unsubstantiated. The 

complaint also alleged that the defendants falsely claimed their products and treatment plans 

have been reviewed, accepted by, and deemed safe and effective by the FDA. This litigation is 

ongoing.

F. Other Enforcement Highlights

During Fiscal Year 2020, the FTC announced additional developments in prior 

enforcement actions affecting older consumers.

1. Warning Leters

During the pandemic, the FTC has seen a wide range of false treatment claims related to 

COVID-19 and scams related to the financial effects of the pandemic. The FTC determined that 

 

71 FTC v. Golden Sunrise Nutraceutical, Inc., No. 1:20-cv-01060-DAD-SKO (E.D. Cal. filed July 30, 2020),

available at https://www.ftc.gov/enforcement/cases-proceedings/202-3146/golden-sunrise-nutraceutical-inc.
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FEDERAL TRADE COMMISSION FTC.GOV 30

the fastest way to get some of these false claims and deceptive marketing taken down is to 

pursue a rigorous warning letter program. To accomplish this, the FTC sends warning letters to 

companies and individuals warning them that their conduct is likely unlawful, and they can face

serious legal consequences, such as a federal lawsuit, if they do not immediately stop. Since 

March 2020, the FTC has sent more than 330 warning letters to a range of companies and 

individuals about potentially false or misleading advertising or marketing related to the 

coronavirus pandemic, providing an opportunity to rectify their practices.72 Overwhelmingly, 

companies that have received FTC warning letters these past several months have taken quick 

steps to correct their problematic claims. As a result, warning letters are frequently the most 

rapid and efficient means to address the problem. However, when a warning letter does not work, 

or is not appropriate given the conduct at issue, the FTC has pursued law enforcement.

The vast majority of the warning letters went to companies allegedly selling products that 

may violate the law by making deceptive or scientifically unsupported claims about their ability 

to treat or cure coronavirus, COVID-19.73 Some of these warning letters were jointly issued with 

the FDA. Although COVID-19 affects people of all ages, some of the letters included example 

representations relating to older adults in the companies’ marketing.

74

 

72 A full list of all of the warning letters sent during the pandemic is available at 

https://www.ftc.gov/coronavirus/enforcement/warning-letters. 73 Press Release, FTC, FTC, FDA Send Warning Letters to Seven Companies about Unsupported Claims that 

Products Can Treat or Prevent Coronavirus (Mar. 9, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/03/ftc-fda-send-warning-letters-seven-companies-about-unsupported; Press Release, FTC, FTC 

Announces Latest Round of Letters Warning Companies to Cease Unsupported Claims that Their Products Can 

Treat or Prevent Coronavirus (Apr. 14, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/04/letters-warning-companies-cease-unsupported-coronavirus-claims; Press Release, FTC, FTC Sends 

45 More Letters Warning Marketers to Stop Making Unsupported Claims That Their Products and Therapies Can 

Effectively Prevent or Treat COVID-19 (May 7, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/05/ftc-sends-45-more-letters-warning-marketers-stop-making; Press Release, FTC, FTC Sends 

Letters Warning 35 More Marketers to Stop Making Unsupported Claims That Their Products and Therapies Can 

Effectively Prevent or Treat COVID-19 (June 4, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/06/ftc-sends-letters-warning-35-more-marketers-stop-making; Press Release, FTC, FTC Sends Letters 

Warning 20 More Marketers to Stop Making Unsupported COVID-19 Treatment (Aug. 14, 2020), available at 

https://www.ftc.gov/news-events/press-releases/2020/08/ftc-letters-warning-20-more-marketers-stop-making-covid19-claims. 74 The FTC also sent warning letters to sixteen multi-level marketers to address claims that they or their participants 

were making about their products’ ability to treat or prevent coronavirus disease or about the earnings people who 

have recently lost income can make, or both. See Press Release, FTC, FTC Sends Warning Letters to Multi-Level 

Marketers Regarding Health and Earnings Claims They or Their Participants are Making Related to Coronavirus

(Apr. 24, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/04/ftc-sends-warning-lettersmulti-level-marketers-regarding-health; Press Release, FTC, FTC Sends Second Round of Warning Letters to MultiLevel Marketers Regarding Coronavirus Related Health and Earnings Claims (June 5, 2020), available at

https://www.ftc.gov/news-events/press-releases/2020/06/second-round-warning-letters-to-mlms-regardingcoronavirus.
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FEDERAL TRADE COMMISSION FTC.GOV 31

• In April 2020, the FTC and FDA sent a warning letter to Genesis II Church of 

Health and Healing.

75 Their marketing material allegedly contained a story about an 

85-year-old patient who purportedly recovered from the coronavirus with the help of 

their product, a liquid additive to water. 

• In April 2020, the FTC sent American Medical Aesthetics a warning letter citing 

advertising that, among other things, claimed the stem cell treatments they sold could 

successfully treat and reverse COVID-19, and even prevent death, in the elderly 

(especially men) with compromised health.

76

• In June 2020, the FTC sent a warning letter to BioXcellerator citing its marketing of 

its stem cell treatments claiming they were a “safe and effective approach for treating 

patients with COVID-19 pneumonia, including elderly patients with severe cases of 

pneumonia.” 77

• In July 2020, the FTC sent a warning letter to Gesundheit! Nutrition Center for 

claiming its oils and products could treat COVID-19.78 On its website, it allegedly

promoted its eucalyptus oil as “A wonderful option for the elderly who suffer from, 

or worry about, COVID-19.”

• In August 2020, the FTC and FDA sent a warning letter to Living Senior, LLC for 

claiming its NAC (n-acetyl cysteine), CBD (cannabidiol), and other products could 

treat or prevent COVID-19 in seniors.79

The FTC also sent warning letters to three companies that allegedly advertised they could 

provide government stimulus money to customers to purchase their hearing aids. The State of 

Wisconsin also sent a letter to one of the companies80 and the Office of the Missouri Attorney 

 

75 See FTC & FDA letter to Genesis II Church of Health and Healing (Apr. 8, 2020), available at

https://www.ftc.gov/system/files/warning-letters/fda-covid-19-letter-genesis_ii_church_of_health_and_healing.pdf. 76 See FTC letter to American Medical Aesthetics (Apr. 17, 2020), available at 

https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_american-medical-aesthetics.pdf. 77 See FTC letter to Bioxcellerator (June 5, 2020), available at https://www.ftc.gov/system/files/warningletters/covid-19-letter_to_bioxcellerator.pdf. 78 See FTC letter to Gesundheit Nutrition Center (July 7, 2020), available at 

https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_gesundheit_nutrition_center.pdf. 79 See FTC & FDA letter to Living Senior, LLC (Aug. 19, 2020) available at

https://www.ftc.gov/system/files/warning-letters/fda-covid-19-letter_living_senior_llc.pdf. 80 Press Release, FTC, FTC and State of Wisconsin Warn Hearing Aid Sellers About Deceptive Stimulus Payment 

Claims (Aug. 21, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/08/ftc-state-wisconsinwarn-hearing-aid-sellers-about-deceptive.
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FEDERAL TRADE COMMISSION FTC.GOV 32

General sent letters to two of the companies.81 The letters highlighted the following claims from 

the companies’ advertisements:

• “COVID-19 HEALTHCARE STIMULUS PROGRAM” and “Receive up to $3000 

through our HEALTHCARE STIMULUS PROGRAM. Must register by July 31.” 

• “Call Today to Secure Your Stimulus Money. For Stimulus Voucher Appointments, 

Call Today!” and “CORONA-VIRUS (sic) PANDEMIC HEARING AID 

STIMULUS PACKAGE ANNOUNCED FOR MISSOURI.”

2. Case Resolu�ons

The FTC has also reached resolutions in six prior pending cases that impacted older 

consumers. 

In December 2019, a federal court ruled in the FTC’s favor granting summary judgment 

in Apartment Hunters, Inc. The court issued a final order resolving allegations that the 

defendants made false and unsubstantiated claims on their WeTakeSection8.com website 

targeting low-income, disabled, and older adults.82 The court ordered the defendants to pay more 

than $6 million and permanently banned them from offering rental listing services.

In August 2020, a federal court ruled in the FTC’s favor after trial in In Re Sanctuary 

Belize Litigation.

83 The defendants operated a massive overseas real estate scam that took in 

more than $100 million, marketing lots in what supposedly would become a luxury development 

in Central America. They targeted small business owners and couples nearing retirement. The 

court granted the FTC’s request for a permanent injunction in the matter and imposed a $120 

million judgment.

In December 2019, the FTC settled charges against Elite IT Partners, Inc., resolving 

allegations that the defendants deceived consumers, many of whom were elderly, into believing 

their computers were infected with viruses in order to sell them costly computer repair 

 

81 Press Release, FTC, FTC and Missouri Attorney General Warn Hearing Aid Sellers About Deceptive Stimulus Payment 

Claims (July 21, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/07/ftc-missouri-attorneygeneral-warn-hearing-aid-sellers-about. 82 Press Release, FTC, Court Orders Operators of Deceptive Rental Listing Websites to Pay $6 Million, 

Permanently Bans Them from Offering Rental Listings (Dec. 16, 2019), available at https://www.ftc.gov/newsevents/press-releases/2019/12/court-orders-operators-deceptive-rental-listing-websites-pay-6. 83 Press Release, FTC, Statement of FTC Bureau of Consumer Protection Director Andrew Smith on the 

Memorandum Opinion Issued by U.S. District Court Judge Peter J. Messitte in the Matter of In re Sanctuary Belize 

Litigation (Sept. 1, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/09/bureau-consumerprotection-director-on-sanctuary-belize-opinion.
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FEDERAL TRADE COMMISSION FTC.GOV 33

services.84 The settlement order permanently bans the defendants from offering tech support 

products and services to consumers. It also prohibits the defendants from falsely claiming an 

affiliation with another company or that a consumer’s product is infected with a computer virus. 

The order also imposes a $13.5 million judgment against the defendants, which will be 

suspended upon payment of $173,000 and the turnover of other assets due to inability to pay.

In May 2020, the FTC settled charges in AH Media Group, Inc.,resolving allegations 

that the defendants operated a scheme that deceived consumers with supposedly “free trial” 

offers for cosmetics and dietary supplements with claims that they promote younger-looking skin 

or weight loss, and then enrolled consumers in subscriptions and billed them without their 

consent.85 The court orders ban the defendants from negative option marketing and requires they

get consumers’ consent before billing them. The order imposes a $74.5 million judgment against 

one set of defendants and a $67 million judgment against the other set of defendants. The 

monetary judgments are partially suspended based on inability to pay, after the defendants turn 

over approximately $4.3 million.

In July 2020, the FTC settled charges against First Choice Horizon, resolving allegations 

that the defendants defrauded financially distressed consumers, many of whom were older adults,

with deceptive robocalls claiming they could save them money by reducing the interest rates on 

their credit cards.

86 The order permanently bans the defendants from: 1) any involvement in the 

sale of debt-relief products or services; 2) all telemarketing; 3) applying for any product or 

service on behalf of a consumer without their knowledge and consent or if the defendants know 

or have reason to believe any of the information on the application is false or misleading; 4) 

obtaining a cash advance on a consumer’s credit card or submitting billing information for 

payment without prior approval; and 5) using or benefitting from any consumer information 

collected through the scheme. The order also imposes a judgment of almost $13.9 million, which 

will be partially suspended based on the defendants’ inability to pay.

In February 2020, the FTC settled with the two key perpetrators of MOBE, settling 

charges that the defendants deceptively lured consumers, including older adults and retirees, to 

join their online coaching program by promising a pathway to online entrepreneurship and 

significant income, but then charged consumers tens of thousands of dollars for worthless 

 

84 Press Release, FTC, Operators of Tech Support Scam Settle FTC Allegations they Tricked Consumers into Buying 

Computer Repair Services (Dec. 10, 2019), available at https://www.ftc.gov/news-events/pressreleases/2019/12/operators-tech-support-scam-settle-ftc-allegations-they-tricked. 85 Press Release, FTC, FTC Halts Online Subscription Scheme, that Deceived People with Free Trials (May 8, 

2020), available at https://www.ftc.gov/news-events/press-releases/2020/05/ftc-halts-online-subscription-schemedeceived-people-free-trial. 86 Press Release, FTC, Scammers Who Used Robocalls to Target Cash-Strapped Consumers Banned from Selling 

Debt Relief Services and Telemarketing (July 24, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/07/scammers-who-used-robocalls-target-cash-strapped-consumers-banned.
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FEDERAL TRADE COMMISSION FTC.GOV 34

program membership upgrades.87 The defendants have agreed to pay more than $17 million as 

part of the settlements. The stipulated order permanently bans one of the defendants from selling 

business coaching programs and investment opportunities. The estate of the other defendant, now 

deceased, agreed to surrender more than $1.3 million. The FTC previously announced a 

settlement with one other defendant in 2018 and is seeking default judgments against the 

remaining defendants.

3. Consumer Monetary Relief

FTC law enforcement actions resulted in over $642.5 million88 in refunds to consumers 

of all ages in Fiscal Year 2020.89 These payments provide consumers some recompense for the 

losses that occurred due to a specific incident. 

In addition to Nature City, Quantum, Neurometrix, and ZyCal Bioceuticals, mentioned 

above, multiple other distributions were made in FTC cases that had an impact on older 

consumers:

• In October 2019, the FTC sent approximately $2.7 million in redress to over 

8,000 consumers allegedly defrauded by a timeshare resale scheme in J. William 

Enterprises, LLC.90

• In February 2020, the FTC sent over $551,000 in refunds to more than 27,000

consumers who purchased purported “cognitive improvement” supplements in 

Global Community Innovations LLC.

91

• In March 2020 and September 2020, approximately $300 million was mailed to 

142,000 consumers in refunds in the actions filed by the FTC, the DOJ, and the 

U.S. Postal Inspection Services against the Western Union Company.

92

 

87 Press Release, FTC, Defendants Responsible for International Business Coaching Operation to Pay More Than 

$17 Million in FTC Settlements (Feb. 13, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/02/defendants-responsible-international-business-coaching-operation. 88 Yearly information about refunds to consumers resulting from FTC cases is available at 

https://public.tableau.com/profile/federal.trade.commission#!/vizhome/Refunds_15797958402020/RefundsbyDate. 89 Typically, the FTC sends refunds directly to consumers. In some cases, the refunds are provided by defendants or 

sent by another federal agency that partnered with the FTC on a case. See https://www.ftc.gov/enforcement/casesproceedings/refunds/how-ftc-provides-refunds. 90 Press Release, FTC, FTC Sending Refund Checks for Nearly $2.7 Million to Consumers Defrauded in Timeshare 

Resale Scheme (Oct. 10, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/10/ftc-sendingrefund-checks-nearly-27-million-consumers-defrauded. 91 Press Release, FTC, FTC Refunding Consumers Defrauded by Cognitive Improvement Claims (Feb. 25, 2020), 

available at https://www.ftc.gov/news-events/press-releases/2020/02/ftc-refunding-consumers-defrauded-cognitiveimprovement-claims. 
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• In June 2020, the FTC sent over $8.7 million in refunds to almost 190,000 

consumers allegedly tricked by the “risk-free” trial offers in Triangle Media 

Corporation.

93

• In June 2020, the FTC issued a second round of payments totaling over $1.87 

million to more than 7,000 consumers allegedly defrauded in a business 

opportunity scheme in Advertising Strategies, LLC.

94

• In July 2020, the FTC sent more than $16 million to more than 27,000 individuals 

who lost money to a debt relief scheme in Jeremy Lee Marcus that allegedly took 

tens of millions of dollars from financially strapped consumers, including the 

elderly and disabled.95

4. Criminal Liaison Unit

The FTC’s Criminal Liaison Unit works with federal and state criminal prosecutors to 

better address consumer fraud.96 Many of these prosecutors have brought criminal cases that 

built on facts exposed as the FTC developed evidence in support of its civil law enforcement 

actions. For example, in October 2019, the Maricopa County Attorney’s Office in Arizona 

charged former FTC defendant Susan Rodriguez and others for operating a telemarketing scheme 

that targeted older adults and other consumers.97 The FTC previously sued Rodriguez and others 

responsible for this operation, who tricked consumers into purchasing ecommerce websites 

through false promises of substantial income and a money-back guarantee.98 The FTC obtained 

 

92 Press Release, FTC, First Round of Refunds Totaling $153 Million Sent to Consumers As a Result of Multi-Agency Case 

Against Western Union (Mar. 10, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/03/firstround-refunds-totaling-153-million-sent-consumers-result; Press Release, FTC, Second Round of Refunds, Totaling 

$147 Million, Sent to Consumers As a Result of Multi-Agency Case Against Western Union (Sept. 23, 2020); 

available at https://www.ftc.gov/news-events/press-releases/2020/09/second-round-refunds-totaling-147-millionsent-consumers-result. 93 Press Release, FTC, FTC Sending Refund Checks Totaling More Than $8.7 Million to Consumers Defrauded by 

Deceptively Marketed Online “Risk-Free Trial” Offers (June 22, 2020), available at https://www.ftc.gov/newsevents/press-releases/2020/06/ftc-sending-refund-checks-totaling-more-87-million-consumers. 94 Information about the two rounds of refunds issued in this case can be found at 

https://www.ftc.gov/enforcement/cases-proceedings/refunds/advertising-strategies-refunds. 95 Press Release, FTC, FTC Sends More Than $16 Million in Refunds to Victims of Bogus Debt Relief Operation 

(July 14, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/07/ftc-sends-more-16-millionrefunds-victims-bogus-debt-relief. 96 Information about the FTC’s Criminal Liaison Unit is available at https://www.ftc.gov/enforcement/criminalliaison-unit. 97 Sharon Hess, 13 Arrested In $40 Million National Telemarketing Fraud Sting, Patch (Oct. 2, 2019), available at

https://patch.com/arizona/phoenix/13-arrested-40-million-phoenix-telemarketing-fraud-sting. 98 Press Release, FTC, Business Opportunity Scheme Operators Banned from Telemarketing and Selling Investment 

Opportunities; Will Return Millions to Consumers (Mar. 13, 2017), available at https://www.ftc.gov/newsevents/press-releases/2017/03/business-opportunity-scheme-operators-banned-telemarketing. 
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FEDERAL TRADE COMMISSION FTC.GOV 36

more than $7 million in redress for consumers through the civil case,99 and the criminal case is 

ongoing. 

In November 2019, the DOJ announced charges against former FTC defendant Shane 

Hanna and others for allegedly running a telemarketing operation that sold purported business 

development services to older adults and other consumers.100 The indictment charged that 

despite promises to the contrary, consumers were not able to earn any money from these services 

and ended up heavily in debt. The DOJ alleged that when the defendants exhausted consumers’ 

available credit or ran out of products to sell, they then unrelentingly tricked consumers into 

paying additional fees up-front by falsely promising to settle or refinance their debts.101 The 

criminal case is ongoing.

Following extradition and after pleading guilty in November 2019, Canadian nationals 

Mark El Bernachawy and Clifford Kirstein were sentenced to a total of 82 months (almost seven 

years) in prison in March 2020 for running a grandparent scam targeting older adults in the 

United States.102 The scammers contacted their elderly victims by telephone and fraudulently 

induced them to send money by pretending to be a grandchild or other relative who was in 

distress in a foreign nation. The FTC provided assistance to the DOJ in this case. 

IV.Outreach and Education Activities

A. Pass It On Educa�on Campaign

 

99 Press Release, FTC, FTC to Send Refund Checks to Consumers who Lost Money in Business Opportunity 

Telemarketing Scam (Mar. 5, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/03/ftc-sendrefund-checks-consumers-who-lost-money-business. 100 Press Release, FTC, Defendants Who Allegedly Took Millions from Consumers Trying to Launch Or Succeed in 

Home-Based Businesses Settle FTC Charges (June 24, 2014), available at https://www.ftc.gov/news-events/pressreleases/2014/06/defendants-who-allegedly-took-millions-consumers-trying-launch-or. 101 Press Release, U.S. Department of Justice, 10 Defendants Charged In Manhattan Federal Court With Running 

Nationwide Telemarketing Fraud Scheme Targeting The Elderly (Nov. 20, 2019), available at

https://www.justice.gov/usao-sdny/pr/10-defendants-charged-manhattan-federal-court-running-nationwidetelemarketing-fraud. 102 Press Release, U.S. Department of Justice, Canadian National Who Conned U.S. Senior Citizens out of Money 

via ‘Grandparent Scam’ Sentenced to 41 months in Federal Prison (Mar. 9, 2020), available at

https://www.justice.gov/usao-cdca/pr/canadian-national-who-conned-us-senior-citizens-out-money-grandparentscam-sentenced-41; United States v. Kirstein, No. 13-cr-469 (C.D. Cal. Mar. 3, 2020) (Minute Entry: Minutes of 

Sentencing).
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FEDERAL TRADE COMMISSION FTC.GOV 37

Pass It On is the FTC’s ongoing fraud prevention education campaign for older adults. 

Campaign materials show respect for the readers’ life experience and accumulated knowledge, 

and provide resources they can read and “pass on” to family and friends to start conversations 

about fraud. When the Pass It On campaign began, its print and online material addressed seven 

common frauds: Identity Theft, Imposter Scams, Charity Fraud, Health Care Scams, Paying Too 

Much, and “You’ve Won” Scams. In response to users’ requests, the FTC added articles about 

Tech Support Scams, Grandkid Scams, Online Dating Scams, and IRS Imposter Scams. In 2019, 

the FTC expanded Pass It On again, by adding material about Unwanted Calls, Home Repair 

Scams, Work-at-Home Scams and Money Mule Scams. Materials refresh and add to readers’ 

knowledge by briefly summarizing how certain scams work and what the reader can do in 

response.

The FTC has distributed more than 14 million Pass It On items since the campaign began, 

including 2.3 million items in Fiscal Year 2020. The free English and Spanish print material is 

requested by groups such as banks, libraries, police departments, adult protective service offices, 

state attorneys general, military support groups, and educational and community groups 

nationwide. Campaign materials are available at ftc.gov/PassItOn, ftc.gov/pasalo (Spanish), and 

ftc.gov/Bulkorder. 

The FTC sends online Consumer Alerts about many of the topics covered by Pass It On and 

other topics of interest to older adults, such as Social Security imposter scams; and health care, 

online safety, and mystery shopper scams. The FTC emails the alerts to more than 425,600

subscribers, which includes individual consumers, community groups, advocates, news media 

outlets, and other stakeholders, and posts the material on its website to share the prevention 

messages.103

B. Communica�ng through Video

This year, the FTC released the Hang up On Social Security Scam Calls video, with 

stories from two older men who got intimidating calls from Social Security imposters.104 They 

describe the calls’ shocking − and false − threats of a “no bail warrant for your arrest,” and an 

“armed marshal at your door,” and explain how important it is to talk with people about these 

experiences, so they can help others prepare for the calls. The FTC distributes videos like this to 

people in the community through various partners, including ethnic and mainstream media, legal 

aid offices, consumer advocacy groups, the Better Business Bureau, and fellow law enforcement 

agencies.

 

103 Information about subscribing to this service is available at www.ftc.gov/subscribe. 104 This video can be viewed, shared, or downloaded at https://www.consumer.ftc.gov/media/video-0192-hangsocial-security-scam-calls. 
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 38

C. Common Ground Events

As part of the Every Community Initiative, the FTC hosted three Common Ground 

conferences in the past year that brought together stakeholders – including local law enforcement 

officials, legal services providers, and community-based organizations – to talk about consumer 

protection issues and spur cooperation on these issues. 

• In October 2019, FTC Chairman Simons and the Virginia Attorney General gave 

the opening remarks at a Common Ground conference in Chesterfield, Virginia

titled, Protecting Virginia’s Consumers.

105 Speakers from the FTC, state attorney 

general’s office, and AARP Virginia participated in a panel about scams that 

affect older adults, and how they can avoid being defrauded. 

• In December 2019, regulators from five states, legal services organizations, 

federal, and Canadian consumer protection and competition agencies attended a 

two-day Common Ground conference in Seattle, Washington, titled Protecting 

Northwest Consumers.106 Panelists from the FTC, Washington Attorney General’s 

Office, and AARP discussed how to reach and educate people who are vulnerable 

and isolated. 

• In March 2020, advocates, law enforcement personnel, regulators, social service 

providers and others gathered in Memphis, Tennessee for a two-day Common 

Ground conference, titled Working Together to Protect Heartland Consumers.

107

Speakers included Bureau of Consumer Protection Director Andrew Smith, the 

Tennessee Attorney General, and staff from the DOJ, the Securities and Exchange 

Commission, and the US Postal Inspection Service. Panel discussions addressed 

issues affecting older adults and protecting underserved communities from 

consumer fraud.

D. Other Outreach Rela�ng to Older Adults

The FTC collaborates with many organizations across the country to share its consumer 

education messages and inform the public about its work. In the past year, FTC staff in 

 

105 Information about this conference is available at https://www.ftc.gov/news-events/events-calendar/protectingvirginias-consumers-common-ground-conference. 106 Information about this conference is available at 

https://www.ftc.gov/system/files/documents/public_events/1567993/2019_common_ground_agenda_-

_december_12.pdf. 107 Information about this conference is available at https://www.ftc.gov/news-events/events-calendar/workingtogether-protect-heartland-consumers-common-ground-conference.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 39

Washington, DC and eight regional offices have presented, exhibited, or participated in more 

than 275 outreach events with the public, other law enforcement agencies, and/or other 

stakeholders who share its goal of protecting members of various communities. More than 100 of 

the outreach events served older adults and the people who work with them, or engaged partner 

organizations in discussions about issues that affect older adults.

FTC staff participated in events with local, state, and federal organizations, including the 

National Association for Area Agencies on Aging, Better Business Bureau, Senior Medicare 

Patrols, as well as adult housing communities, public libraries, consumer organizations, legal 

services providers, and law enforcement task forces. Staff joined in more than a dozen activities 

with AARP, including nationwide webinars about imposters and tax identity theft, national and 

statewide tele-town halls, and three in-person Scam Jams. Staff attended workshops and expos to 

meet with older adults in their communities, and presented on webinars about robocalls affecting 

older consumers. FTC staff discussed scams that affect older adults at several conferences in 

2020, including the National Aging and Law Conference, American Society on Aging 

Conference, New England Library Association Conference, and Elder Abuse conferences with 

the Federal Bureau of Investigation and at the Washington State Criminal Justice Center. Staff 

also spoke about frauds that affect Asian American and Pacific Island elders at a Berkeley Law 

School event and presented on a National Caucus and Center on Black Aging Senior Day 

webinar. Further, in March, the FTC and Social Security Administration held a Facebook Live 

event to talk about scams that involve people pretending to be Social Security officials. 

The FTC’s outreach with groups and communities throughout the country provides a way 

to share the agency’s important prevention messages, and opens up the communication lines so 

the FTC hears about the scams and other consumer protection problems affecting the public. 

This, in turn, can generate opportunities for policy and education initiatives, as well as new case 

leads. 

E. Coronavirus Educa�on and Outreach to Older Adults

When the coronavirus pandemic began, the FTC quickly pivoted to provide information 

to the public about the myriad of COVID-related scams and issues that surfaced. The FTC issued 

its first alert about a potential scam related to the virus on February 10, 2020, highlighting how 

scammers like to use such events in their schemes.108 Shortly thereafter, the FTC developed a 

multi-media campaign with consumer and business advice, all available from 

ftc.gov/coronavirus. This webpage, available in English and Spanish, is a directory to the FTC’s 

coronavirus education resources. The site contains tips for consumers on how to stay safe during 

the pandemic; links to blog posts and alerts; a collection of short social media materials; 

infographics; links to fact sheets in five Asian languages; and a list of additional government 

 

108 Consumer Alert, FTC, Coronavirus: Scammers follow the headlines (Feb. 10, 2020) available at

https://www.consumer.ftc.gov/blog/2020/02/coronavirus-scammers-follow-headlines. 
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 40

resources. The page contains tabs to additional information for consumers and businesses, 

information about law enforcement actions related to the pandemic, how to report COVIDrelated consumer issues, and other resources. As of September 30, visitors have viewed a 

collective 4.7 million pages of the material available.

The FTC has issued more than 120 blog posts and Consumer Alerts on pandemic-related 

topics including stimulus payments, health and treatment claims, charity fraud, government 

imposter scams, contact tracing, privacy issues, and scams targeting small business. A Consumer 

Alert about potential scams related to the government stimulus payments received the most hits,

with 1.6 million views.109 The FTC has worked aggressively to educate consumers of all ages 

about coronavirus-related scams, but offered several Consumer Alerts on issues affecting older 

consumers110 including one about what to do if a nursing home or care facility wrongfully took 

your stimulus check,111 as well as one warning about “grandparent scam” calls with a 

coronavirus twist.112 The FTC and Consumer Financial Protection Bureau Office for Older 

Americans published joint alerts about caregiving scams and government imposter scams during 

the pandemic.

113 Local media and community partners that subscribe to these alerts, including 

libraries, banks, and local law enforcement, share and forward the information to their members, 

which expands the FTC’s audience. 

FTC staff in Washington, DC and eight regional offices have conducted local and 

national outreach related to the pandemic with its partners and engaged with ethnic media, 

community organizations and many others through webinars, tele-town halls, Twitter chats, 

Facebook Live events, and interviews with local and national media. A small sample includes 

webinars with the Better Business Bureau in several states; the American Bankers Association 

Foundation; Small Business Development Corporations; the FDIC; affordable housing 

managers; members of the Puerto Rico Bar Association; FEMA emergency responders; the 

National Asian American Coalition; and public librarians in several states. Staff conducted a 

 

109 Consumer Alert, FTC, Checks from the government (Mar. 18, 2020) available at 

https://www.consumer.ftc.gov/blog/2020/03/checks-government. 110 See, e.g., Consumer Alert, FTC, 60 and over in the time of COVID-19? Read on (Mar. 30, 2020) available at 

https://www.consumer.ftc.gov/blog/2020/03/60-and-over-time-covid-19-read. 111 Consumer Alert, FTC, Did a nursing home or assisted living facility take your stimulus check? (Mar. 15, 2020) 

available at https://www.consumer.ftc.gov/blog/2020/05/did-nursing-home-or-assisted-living-facility-take-yourstimulus-check. 112 Consumer Alert, FTC, Grandparent scams in the age of Coronavirus (Apr. 3, 2020) available at

https://www.consumer.ftc.gov/blog/2020/04/grandparent-scams-age-coronavirus. 113 Consumer Alert, FTC, Avoid scams while finding help during quarantine (Apr. 7, 2020) available at

https://www.consumer.ftc.gov/blog/2020/04/avoid-scams-while-finding-help-during-quarantine; Consumer Alert, 

FTC, How to avoid COVID-19 government imposter scams (June 1, 2020) available at 

https://www.consumer.ftc.gov/blog/2020/04/avoid-scams-while-finding-help-during-quarantine.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 41

dozen media interviews in English and Spanish, and joined with the DOJ and HHS to warn 

people about contact tracing scams.114

FTC staff participated in more than 30 coronavirus education and outreach events with 

older adults and the people who work with them, such as task force partners, legal service 

providers, aging service providers, state agencies, and other outreach partners. FTC staff 

participated in national and statewide AARP tele-town halls about coronavirus scams − one of 

which reached 850,000 participants. Staff shared coronavirus information with people who get 

home-delivered meals in Seattle and Washington, DC, and residents of a Tennessee retirement 

community. They presented information about coronavirus scams to older adults in Illinois, 

Minnesota, Missouri, and Wisconsin, at webinars hosted by local Better Business Bureaus. The 

FTC joined a Center for Medicare Services’ tele-town hall with government and senior service 

providers, and worked with members of Congress on almost a dozen coronavirus outreach 

events. Staff in Washington, DC and four regional offices provided members with English- and 

Spanish-language material and participated in their calls and webinars with older adults and 

other constituents. All of these efforts have worked to provide key prevention information about 

coronavirus-related scams and consumer concerns to older consumers.

V. Conclusion

The FTC remains firmly committed to protecting older consumers through aggressive 

law enforcement and effective consumer education and outreach. Research, law enforcement 

experience, and input from stakeholders will continue to be critical as the Commission 

strategizes about how to use its resources to protect the growing population of older adults in the 

years ahead.

 

114 Press Release, DOJ, The Justice Department, Department of Health and Human Services, and the Federal Trade 

Commission Partner to Alert Public of Contact Tracing COVID-19 Fraud Schemes (June 30, 2020) 

https://www.justice.gov/opa/pr/justice-department-department-health-and-human-services-and-federal-tradecommission-partner#:~:text=The%20Justice%20Department%2C%20HHS%20and,or%20ftc.gov%2Fcomplaint.
Protecting Older Consumers | October 2020

FEDERAL TRADE COMMISSION FTC.GOV 42

Appendix A
APPENDIX A - Federal Trade Commission FY 2020

STYLE OF CASE Case Number Court Name Date Case Type Description Federal Trade Commission v. AdvoCare International, L.P, et al.

4:19-cv-00715 Eastern District of Texas 10/02/19 Multi-Level Marketing Alleged the defendants operated an illegal pyrami

deceived consumers into believing that they could income. 

Federal Trade Commission v. NatureCity, LLC, et al. 9:19-81387 Southern District of Florida 10/10/19 Unsubstantiated Health Claims Alleged the defendants deceived consumers with 

unsupported claims that products were effective trrange of conditions. 

Federal Trade Commission v. Devumi, LLC and German Calas, Jr.

9:19-cv-81419-RKA

Southern District of Florida 10/18/19 Fake Social Media Account Sales Alleged the defendants used deceptive online ma

and sold fake indicators of social media influence. 

In the Matter of Sunday Riley Modern Skincare, LLC and Sunday Riley

FTC Matter No. 192 3008

FTC Administrative Matter 10/21/19 Fake Product Reviews Alleged the respondents misled consumers by po

product reviews and by failing to disclose that the company employees. 

Federal Trade Commission v. Agora Financial LLC et al. 1:19-03100 District of Maryland 10/24/19 Deceptive sale of publications Alleged the defendants marketed publications tha

promised a cure for type 2 diabetes and promoted participate in a government-affiliated check progra

Federal Trade Commission v. Neora, LLC, et al. 19-19699 District of New Jersey 11/01/19

Multi-Level Marketing and unsubstantiated health claims

Alleged the defendant operated as an illegal pyramfalsely promising recruits financial independence, promoting dietary supplements.

Federal Trade Commission v. American Financial Support Services Inc., et al.

8:19-02109-JVSADS Central District of California 11/04/19 Student Debt Relief Alleged the defendants deceptively marketed stud

forgiveness, consolidation, and repayment progra

In the Matter of NTT Global Data Centers Americas, Inc.

FTC Matter No. 182 3189

FTC Administrative Matter 11/05/19 EU-U.S. Privacy Shield Alleged the respondent misled consumers about i

the EU-U.S. Privacy Shield framework and failed tprogram’s requirements before allowing its certific

Federal Trade Commission, and Utah Division of Consumer Protection v. Nudge, LLC, et al.

2:19-cv-00867 District of Utah 11/05/19 Real Estate money- making scheme Alleged the defendant made empty promises abo

by “flipping” houses, to convince consumers to butraining packages that cost thousands of dollars. 

1
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. Effen Ads, LLC, et al. 2:19-cv-00945 District of Utah 11/26/19 Work at home scheme Alleged the defendants used misleading spam em

consumers into buying work-from-home services. 

Federal Trade Commission v. A.S. Research, LLC, et al. 1:19-cv-03423 District of Colorado 12/05/19 Unsubstantiated Health Claims Alleged the defendants used deceptive tactics to m

consumers into thinking their product could treat aalleviate joint pain. 

Federal Trade Commission v. On Point Global LLC, et al.

1:19-cv-25046-RNS

Southern District of Florida 12/09/19 Government Impersonation Alleged the defendants operated misleading webs

promised quick and easy government service. 

Federal Trade Commission v. The University of Phoenix, Inc. and Apollo Education Group, Inc.

2:19-cv-05772-ESW District of Arizona 12/10/19 Deceptive for profit school advertising Alleged the defendants used deceptive advertisem

touted their relationships and job opportunities witcompanies. 

Federal Trade Commission and State of Maine v. Health Research Laboratories, LLC and Kramer Duhon

2:17-cv-00467-JDL District of Maine 12/17/19 Unsubstantiated Health Claims Alleged the defendants promoted their products u

claims that they can treat and cure diseases, in viFTC settlement order. 

Federal Trade Commission v. Fleetcor Technologies, Inc. and Ronald Clarke

1:19-cv-05727-ELR

Northern District of Georgia 12/20/19 Fuel Card Fees Alleged the defendants charged customers hidden 

cards. 

In the Matter of InfoTrax Systems L.C. and Mark Rawlins

FTC Matter No. 162 3130

FTC Administrative Matter 12/30/19 Data Security

Alleged the respondents failed to put in place reassafeguards, allowing a hacker to access the persoof more than a million consumers.

United States of America v. Mortgage Solutions FCS, Inc.

4:20-cv-00110-DMR

Northern District of California 01/06/20 Privacy Alleged that defendants revealed personal inform

consumers in response to negative reviews poste

In the Matter of Medable FTC Matter No. 182 3192 FTC Administrative Matter 01/06/20 EU-U.S. Privacy Shield Alleged the respondent falsely claimed participatio

Privacy Shield framework. 

Federal Trade Commission v. James D. Noland, Jr., et al.

2:20-cv-00047-DWL District of Arizona 01/08/20 Multi-Level Marketing Alleged the defendants operated a pyramid schem

promises of wealth and income to entice thousandto join. 

2
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. Grand Bahama Cruise Line, LLC, et al.

6:20-cv-00052-RBD-GJK

Middle District of Florida 01/10/20 Robocall - Do Not Call Violations Alleged the defendants made illegal robocalls pitc

vacations. 

In the Matter of Global Data Vault LLC

FTC Matter No. 192 3093

FTC Administrative Matter 01/23/20 EU-U.S. Privacy Shield Alleged the respondent falsely claimed participatio

Privacy Shield framework. 

In the Matter of Click Labs, Inc. FTC Matter No. 192 3090 FTC Administrative Matter 01/23/20 EU-U.S. Privacy Shield Alleged the respondent falsely claimed participatio

Privacy Shield framework. 

In the Matter of TDARX, Inc. FTC Matter No. 192 3084 FTC Administrative Matter 01/23/20 EU-U.S. Privacy Shield Alleged the respondent falsely claimed participatio

Privacy Shield framework. 

In the Matter of Incentive Services, Inc.

FTC Matter No. 192 3078

FTC Administrative Matter 01/23/20 EU-U.S. Privacy Shield Alleged the respondent falsely claimed participatio

Privacy Shield framework. 

Federal Trade Commission v. Production Media Company et al.

3:20-cv-00143-BR District of Oregon 01/23/20 Small Business Advertising Scheme Alleged the defendants deceptively sold advertisin

businesses. 

Federal Trade Commission v. Quantum Wellness Botanical Institute, LLC, et al.

2:20-cv-00244-SMB District of Arizona 02/03/20 Unsubstantiated Health Claims Alleged the defendants deceptively claimed that th

a virtual cure-all for age-related ailments. 

Federal Trade Commission v. ZyCal Bioceuticals Healthcare Company, Inc., et al.

1:20-cv-10249 District of Massachusetts 02/10/20 Unsubstantiated Health Claims Alleged the defendants made false claims that the

scientifically proven to alleviate joint pain by growcartilage. 

Federal Trade Commission v. OTA Franchise Corporation, et 

al.

8:20-cv-00287-JVS-KES

Central District of California 02/12/20 Business Coaching Scheme Alleged the defendants used false or unsubstantia

claims to sell investment “training programs." 

Federal Trade Commission v. Neurometrix, Inc. and Shai Gozani

1:20-cv-10428 District of Massachusetts 03/03/20 Unsubstantiated Health Claims Alleged the defendants made deceptive claims ab

their electrical nerve stimulation device to treat pa

3
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. Michael A. Giannulis, et al.

 6:20-cv-00371-CEM-GJK

Middle District of Florida 03/03/20 Business Coaching Scheme Alleged the defendants used false claims and mis

testimonials to market "mentoring" services. 

Federal Trade Commission v. Steven J. Bransfield, et al.

6:20-cv-00372-CEM-GJK

Middle District of Florida 03/03/20 Business Coaching Scheme Alleged the defendants used false claims and mis

testimonials to market "mentoring" services. 

Federal Trade Commission v. Teami, LLC et al. 8:20-cv-518 Middle District of Florida 03/05/20 Unsubstantiated Health Claims & Endorsements Alleged the defendants promoted its products usin

health claims and endorsements by well-known soinfluencers who did not adequately disclose that tpaid. 

Federal Trade Commission v. BoostMyScore LLC et al. 1:20-cv-641 District of Colorado 03/06/20 Credit repair scheme

Alleged the defendants misled consumers with pr“drastically and immediately” improve credit scoreaccess to lower rates on mortgages.

Federal Trade Commission v. SLAC, Inc. et al.

5:20-cv-00470-JFW

Central District of California 03/09/20 student loan debt relief Alleged the defendants falsely promised to lower 

consumers’ student loans for an illegal upfront feeconsumers for positive reviews. 

In the Matter of T&M Protection Resources, LLC

FTC Matter No. 192 3092

FTC Administrative Matter 03/16/20 EU-U.S. Privacy Shield Alleged the respondent misrepresented its particip

compliance with the EU-U.S. Privacy Shield frame

Federal Trade Commission v. Health Center, Inc. and Peggy Pearce

2:20-cv-547 District of Nevada 03/19/20 Unsubstantiated Health Claims Alleged the defendants made deceptive advertisin

three “cure-all” health and wellness products. 

In the Matter of Retina-X Studios, LLC and James N. Johns, Jr.

FTC Matter No. 172 3118

FTC Administrative Matter 03/26/20 Data Security & Children's Privacy Alleged the respondents failed to secure the data 

“stalking” apps and ensure the apps were used fopurposes. 

Federal Trade Commission v. Renaissance Health Publishing, LLC and James Digeorgia

9:20-cv-80640 Southern District of Florida 04/17/20 Unsubstantiated Health Claims Alleged the defendants promoted a supplement a

for pain and joint inflammation. 

Federal Trade Commission v. Mile High Madison Group, Inc. et al.

1:20-cv-21622-FAM

Southern District of Florida 04/17/20 Unsubstantiated Health Claims Alleged the defendants deceptively promoted sup

false claims that their products could stop pain anrelated ailments. 

4
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. Ponte Investments, LLC and John C. Ponte

1:20-cv-00177 District of Rhode Island 04/17/20 Deceptive Small Business Loans Alleged the defendants falsely claimed to be an a

for a federal coronavirus relief lending program 

Federal Trade Commission v. Progressive Leasing, LLC 1:20-cv-01668 Northern District of Georgia 04/20/20 Rent-to-Own Alleged the defendants misled customers about th

items purchased through its rent-to-own payment 

Federal Trade Commission v. Fashion Nova, Inc. 2:20-cv-03641 Central District of California 04/20/20 Online merchandise sales Alleged the defendants didn’t properly notify cons

failed to ship merchandise in a timely manner, and gift cards to compensate rather than refunds. 

Federal Trade Commission v. RevenueWire, Inc. and Roberta Leach

1:20-cv-01032 District of Columbia 04/21/20 Credit Card Laundering Alleged the defendants laundered credit card pay

assisted and facilitated, two tech support scams. 

In the Matter of Marc Ching FTC Matter No. 202 3110 FTC Administrative Matter 04/22/20 Unsubstantiated Health Claims Alleged the respondent made baseless claims tha

could treat, prevent, or reduce the risk of COVID-

Federal Trade Commission v. Lead Express, Inc. et al.

2:20-cv-00840-JAD-NJK District of Nevada 05/11/20 Pay Day Lending

Alleged the defendants deceptively overcharged cwithdrew money repeatedly from consumers’ banwithout their permission. 

Federal Trade Commission vs. Position Gurus, LLC et al. 2:20-cv-710 Western District of Washington 05/12/20 Business Coaching Alleged the defendants targeted people who were 

new businesses online and used deception to sell marketing products and services. 

In the Matter of Federal-Mogul Motorparts LLC

FTC Matter No. 172 3102

FTC Administrative Matter 05/12/20 Claims About Brake Pads

Alleged the respondent made unsubstantiated clapads could stop a vehicle in a shorter distance in and reduce the risk of collisions, compared to compads.

Federal Trade Commission v. American Future Systems, Inc. 2:20-cv-02266 Eastern District of Pennsylvania 05/13/20 Unordered Merchandise Alleged the defendants charged organizations for 

newsletter subscriptions they never ordered and torganizations if they failed to pay for the unordere

5
APPENDIX A - Federal Trade Commission FY 2020

In the Matter of Tapplock, Inc. FTC Matter No. 192 3011 FTC Administrative Matter 05/18/20 Data Security Alleged the respondent falsely claimed that its sm

designed to be “unbreakable” and that it took reassecure the data it collected from users. 

Federal Trade Commission v. First Data Merchant Services LLC and Chi W. Ko

1:20-cv-3867 Southern District of New York 05/19/20 Payment Processing Alleged the defendants knowingly processed paym

laundered, or assisted laundering of, credit card trscams that targeted hundreds of thousands of con

Federal Trade Commission v. Liberty Chevrolet, Inc. and Carlo Fittanto

1:20-cv-03945-PAE

Southern District of New York 05/21/20 Auto Financing

Alleged the defendants discriminated against Africand Hispanic car buyers by charging higher financfees.

In the Matter of Shop Tutors, Inc, et al.

FTC Matter No. 182 3180

FTC Administrative Matter 05/21/20 Fake Reviews Alleged the respondent promoted deceptive ranki

products for a fee and posted fake positive review

Federal Trade Commission v. Qualpay, Inc. 6:20-cv-00945 Middle District of Florida 06/01/20 Payment Processing Alleged the defendants ignored clear warning sign

payment for an unlawful business coaching and inscheme 

United States of America v. HyperBeard, Inc. et al. 3:20-cv-03683 Northern District of California 06/03/20 Children's Privacy

Alleged the defendants allowed third-party ad netwpersonal information to track users of the companapps, without notifying parents or obtaining verifiaconsent.

United States of America v. Kohl's Department Stores, Inc. 2:20-cv-859 Eastern District of Wisconsin 06/08/20 Fair Credit Reporting Alleged the retailer refused to provide complete re

transactions to consumers whose personal informby identity thieves. 

Federal Trade Commission v. RCG Advances, LLC et al. 1:20-cv-04432 Southern District of New York 06/10/20 Small Business Financing/Collection

Alleged the defendants deceived small businessemisrepresenting the terms of merchant cash advaprovided, and then used unfair collection practices consumers to pay.

Federal Trade Commission v. Traffic Jam Events, LLC and David J. Jeansonne II

2:20-cv-1740 Eastern District of Louisiana 06/16/20 Auto Advertising Alleged the defendants deceived consumers with 

supposedly directing them how to obtain federal Cstimulus benefits, which instead lured them to a u

6
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. Physician's Technology, LLC et al.

2:20-cv-11694-NGE-RSW

Eastern District of Michigan 06/25/20 Unsubstantiated Health Claims Alleged the defendants falsely marketed a low-ligh

and made deceptive claims that the device treats pain and associated inflammation. 

In the Matter of Miniclip S.A. FTC Matter No. 192 3129 FTC Administrative Matter 06/29/20 Children's Privacy Alleged the respondent misled consumers about i

a program aimed at ensuring companies adhere tthe Children’s Online Privacy Protection Act. 

Federal Trade Commission and Office of the Attorney General, State of Florida, v. GDP Network LLC et al.

6:20-cv-1192-Orl-78DCI

Middle District of Florida 07/06/20

Credit Card Interest Rate Reduction Scheme

Alleged the defendants conducted a sham credit creduction operation.

Federal Trade Commission v. SuperGoodDeals.com, Inc and Kevin J. Lipsitz

1:20-cv-03027 Eastern District of New York 07/08/20 Online merchandise sales Alleged the defendants falsely promised consume

shipping of facemasks and other personal protect

In the Matter of Ortho-Clinical Diagnostics, Inc.

FTC Matter No. 192 3050

FTC Administrative Matter 07/08/20 EU-U.S. Privacy Shield Alleged the respondent misled consumers about i

the EU-U.S. Privacy Shield framework. 

In the Matter of WilliamsSonoma, Inc. FTC Matter No. 202 3025 FTC Administrative Matter 07/13/20 Made in the USA Claims Alleged the respondent made false, misleading, o

claims that products were all or virtually all made States. 

Federal Trade Commission v. National Landmark Logistics LLC et al.

0:20cv2592 District of South Carolina 07/13/20 Phantom Debt Alleged the defendants engaged in deceptive and 

collection practices. 

Federal Trade Commission v. Absolute Financial Services LLC et al.

0:20cv2596 District of South Carolina 07/13/20 Phantom Debt Alleged the defendants engaged in deceptive and 

collection practices. 

United States of America v. MyLife.com, Inc. and Jeffrey Tinsley

 2:20-cv-06692 Central District of California 07/27/20 Fair Credit Reporting Alleged that defendants misled consumers to thin

individuals might contain criminal and other record

7
APPENDIX A - Federal Trade Commission FY 2020

Federal Trade Commission v. F & G International Group Holdings, LLC et al.

6:08-tc-05000 Southern District of Georgia 07/28/20 R-value claims Alleged the defendants falsely overstated the R-v

the coatings, making deceptive statements about insulating power 

Federal Trade Commission, v. SPM Thermo-Shield, Inc. et al. 2:20-cv-00542 Middle District of Florida 07/28/20 R-value claims Alleged the defendants falsely overstated the R-v

the coatings, making deceptive statements about insulating power 

Federal Trade Commission v. Superior Products International II, Inc.and Joseph E. Pritchett

2:20-cv-02366 District of Kansas 07/28/20 R-value claims

Alleged the defendants falsely overstated the R-vthe coatings, making deceptive statements about insulating power

Federal Trade Commission v. SUPERTHERM, Inc. et al. 3:20-CV-08190 District of Arizona 07/28/20 R-value claims

Alleged the defendants falsely overstated the R-vthe coatings, making deceptive statements about insulating power

Federal Trade Commission v. Golden Sunrise Nutraceutical, Inc. et al.

1:20-cv-01060-DAD-SKO 

Eastern District of California 07/30/20 Unsubstantiated Health Claims Alleged the defendants advertised a treatment pla

scientifically proven way to treat COVID-19. 

Federal Trade Commission v. Yellowstone Capital LLC et al. 1:20-cv-06023 Southern District of New York 08/03/20 Merchant Cash Advance

Alleged the defendants unlawfully withdrew millionexcess payments from their customers’ accounts, they provided refunds, sometimes took weeks or eprovide them.

Federal Trade Commission v. Zaappaaz LLC and Azim Makanojiya

4:20-cv-02717 Southern District of Texas 08/04/20 Online merchandise sales Alleged the defendants failed to notify consumers 

delays in a timely manner and give consumers the cancel orders and receive prompt refunds. 

Federal Trade Commission v. QYK Brands LLC et al.

8:20-cv-01431-JLS-KES

Central District of California 08/04/20 Online merchandise sales Alleged the defendants failed to notify consumers 

delays in a timely manner and give consumers the cancel orders and receive prompt refunds. 

Federal Trade Commission v. American Screening, LLC et al. 4:20-cv-1021 Eastern District of Missouri 08/04/20 Online merchandise sales Alleged the defendants failed to notify consumers 

delays in a timely manner and give consumers the cancel orders and receive prompt refunds. 

8
APPENDIX A - Federal Trade Commission FY 2020

In the Matter of Traffic Jam Events, LLC and David J. Jeansonne II

FTC Matter No. 202 3127

FTC Administrative Matter 08/07/20 Auto Advertising

Alleged that respondents deceived consumers witsupposedly directing them to obtain federal COVIbenefits. 

Federal Trade Commission, v. Age of Learning, Inc. 2:20-cv-07996 Central District of California 9/1/2020 Negative Option Scheme

Alleged the defendant unfairly billed users without authorization and made it difficult for consumers tmemberships, preventing consumers from avoidincharges.

Federal Trade Commission; the People of the State of New York, the Commonwealth of Virginia, State of Minnesota, and State of New Jersey, v. Outreach Calling, Inc., et al.

1:20-cv-07505-MKV

Southern District of New York 9/15/2020 Charity

Alleged the defendants served as the primary funnumber of sham charities that were the subject of enforcement actions. 

Federal Trade Commission v. NutraClick, LLC, et al. 2:20-cv-08612 Central District of California 9/21/2020 Negative Option Scheme Alleged the defendants continued to deceptively m

products in a negative option scheme in violation order. 

Federal Trade Commission v. Critical Resolution Mediation LLC, et al.

1:20cv3932 Northern District of Georgia 9/22/2020 Phantom/abusive debt collection Alleged the defendants used deceptive practices, 

government or law enforcement officials, to collecconsumers did not owe. 

9