Case 6:23-cv-01041-WWB-DCI Document 114-2 Filed 01/17/24 Page 1 of 23 PagelD 4776 

UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

ORLANDO DIVISION 

FEDERAL TRADE COMMISSION, 

Case No. 

Plaintiff, 

6:23-cv-1041 -WWB-DCI 

V. 

[PROPOSED] 

VISION ONLINE, INC., GANADORES IBR, INC., STIPULATED ORDER FOR 

VISION ONLINE DIGITAL, LLC, VISION PERMANENT INJUNCTION, 

ONLINE ENGLISH, LLC, VISION ONLINE MONETARY RELIEF AND 

LATINO, LLC, RICHARD ALVAREZ, SARA OTHER RELIEF AS TO 

ALVAREZ, ROBERT SHEMIN, and BRYCE BRYCE CHAMBERLAIN 

CHAMBERLAIN, 

Defendants. 

This matter comes before the Court upon the stipulation of the Plaintiff, the 

Federal Trade Commission ("FTC"), and individual Defendant Bryce Chamberlain, for 

the entry of an order for permanent injunction, monetary rel ief, and other relief as to 

Defendant Chamberlain. 

On June 5, 2023, the FTC filed its Complaint for Permanent Injunction, Monetary 

Relief, and Other Relief pursuant to Sections 13(b) and 19 of the Federal Trade 

Commission Act ("FTC Act"), the Business Opportunity Rule, the Cooling-Off Rule, and 

the Consumer Review Fairness Act ("CRFA") and moved pursuant to Fed. R. Civ. P. 

65(b) for a temporary restraining order. 

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The FTC and Defendant Chamberlain stipulate to the entry of this Stipulated 

Order for Permanent Injunction, Monetary Relief, and Other Relief (“Order”) to resolve 

all matters in dispute in this action between them. 

THEREFORE, IT IS STIPULATED AND ORDERED as follows: 

I. FINDINGS 

A. This Court has jurisdiction over this matter. 

B. The Complaint charges that Defendants participated in deceptive and 

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

Business Opportunity Rule, the Cooling-Off Rule, and the CRFA in the advertising, 

marketing, and selling of workshops, mentoring, and business opportunities 

(“Defendants’ Products”) to consumers in this District and throughout the United States. 

C. Defendant Chamberlain neither admits nor denies any of the allegations in 

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

action, Defendant Chamberlain admits the facts necessary to establish jurisdiction. 

D. Defendant Chamberlain waives any claim that he may have under the 

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

through the date of this Order, and agrees to bear his own costs and attorney fees. 

E. Defendant Chamberlain and the FTC waive all rights to appeal or 

otherwise challenge or contest the validity of this Order. 

II. DEFINITIONS 

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

A. “Business Opportunity” means a commercial arrangement in which: 

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1. A Seller solicits a prospective Purchaser to enter into a new 

business; and 

2. The prospective Purchaser makes a required payment; and 

3. The Seller, expressly or by implication, orally or in writing, 

represents that the Seller or one or more Designated Persons will: 

a. Provide locations for the use or operation of equipment, 

displays, vending machines, or similar devices, owned, 

leased, controlled, or paid for by the Purchaser; or 

b. Provide outlets, accounts, or customers, including, but not 

limited to, Internet outlets, accounts, or customers, for the 

Purchaser’s goods or services; or 

c. Buy back any or all of the goods or services that the 

Purchaser makes, produces, fabricates, grows, breeds, 

modifies, or provides, including, but not limited to, providing 

payment for such services as, for example, stuffing 

envelopes from the Purchaser’s home. 

B. “Corporate Defendants” means Vision Online, Inc., Ganadores IBR, Inc., 

Vision Online Digital, LLC, Vision Online English, LLC, Vision Online Latino, LLC, and 

each of their subsidiaries, affiliates, successors, and assigns. 

C. “Defendants” means the Corporate Defendants and the Individual 

Defendants, individually, collectively, or in any combination. 

D. “Designated Person” means any person, other than the Seller, whose 

goods or services the Seller suggests, recommends, or requires that the Purchaser use 

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in establishing or operating a new business. 

E. “Document” is synonymous in meaning and equal in scope to the usage 

of “document” and “electronically stored information” in Federal Rule of Civil Procedure 

34(a), and includes writings, drawings, graphs, charts, photographs, sound and video 

recordings, images, Internet sites, web pages, websites, electronic correspondence, 

including e-mail and instant messages, contracts, accounting data, advertisements, FTP 

Logs, Server Access Logs, books, written or printed records, handwritten notes, 

telephone logs, telephone scripts, receipt books, ledgers, personal and business 

canceled checks and check registers, bank statements, appointment books, computer 

records, customer or sales databases and any other electronically stored information, 

including Documents located on remote servers or cloud computing systems, and other 

data or data compilations from which information can be obtained directly or, if 

necessary, after translation into a reasonably usable form. A draft or non-identical 

copy is a separate Document within the meaning of the term. 

F. “Earnings Claim(s)” means any representation, expressly or by implication, 

about income, revenues, financial gains, percentage gains, profit, net profit, gross profit, or 

return on investment. Earnings Claims include, but are not limited to: (a) any chart, table, or 

mathematical calculation that demonstrates possible results based upon a combination of 

variables; (b) any statements from which a prospective consumer can reasonably infer that 

he or she will earn a minimum level of income (e.g., “earn enough money to buy a 

Porsche,” “earn a six-figure income,” or “earn your investment back within one year”); (c) 

references to earning sufficient income to enable a prospective consumer to quit one’s job, 

no longer work, or live off income from the good or service sold; (d) any statements or 

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claims regarding income made by representatives, endorsers, or instructors, including any 

reference to the aforementioned individuals making sufficient income to purchase a home, 

cars, boats, vacations, or travel; and (e) any representation of how much money a 

consumer could or would earn. 

G. “eCommerce Coaching Program” means any product or service, 

including any program or plan, including those that are Business Opportunities, that is 

represented, expressly or by implication, to coach, train, or teach a consumer or a 

Purchaser how to make money by establishing, operating, or improving an online store. 

This definition does not include books on eCommerce, in any form. 

H. “General Media” means all print, electronic, internet, social networking, 

radio, and other media outlets. 

I. “Individual Defendant(s)” means Richard Alvarez, Sara Alvarez, Robert 

Shemin, and Bryce Chamberlain, individually, collectively, or in any combination. 

J. “Investment Opportunity” means anything, tangible or intangible, that 

is offered, offered for sale, sold, or traded based wholly or in part on representations, 

either express or implied, about past, present, or future income, profit, or appreciation. 

K. “Person” means any natural Person or any entity, corporation, 

partnership, or association of Persons. 

L. “Pictorial” includes pictures, photographs, video, illustrations, and 

symbols. 

M. “Prohibited Agreement Provision” means a contract provision used in 

the course of selling or leasing goods or services that: 

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1. prohibits or restricts the ability of a Person who is a party to the 

contract to engage in a Relevant Communication; 

2. imposes a penalty or fee against a Person who is a party to the 

contract for engaging in a Relevant Communication; or 

3. transfers, or requires a Person who is a party to the contract to 

transfer, to any other Person any intellectual property rights in a 

Relevant Communication, with the exception of a non-exclusive 

license to lawfully use a Relevant Communication about a 

Defendant’s goods, services, or conduct. 

N. "Provide locations, outlets, accounts, or customers” means furnishing 

the prospective Purchaser with existing or potential locations, outlets, accounts, or 

customers; requiring, recommending, or suggesting one or more locators or lead 

generating companies; collecting a fee on behalf of one or more locators or lead 

generating companies; offering to furnish a list of locations; or otherwise assisting the 

prospective Purchaser in obtaining his or her own locations, outlets, accounts, or 

customers, provided, however, that advertising and general advice about business 

development and training shall not be considered as “providing locations, outlets, 

accounts, or customers.” 

O. “Purchaser” means a Person who buys a Business Opportunity or 

Investment Opportunity. 

P. “Real Estate Coaching Program” means any product or service, 

including any program or plan, including those that are Business Opportunities, that is 

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represented, expressly or by implication, to train or teach a consumer how to make 

money through investing in or buying and selling real estate. This definition does not 

include books on real estate investing, in any form, 

Q. “Relevant Communication” means a written, oral, or Pictorial review, 

performance assessment, or other similar analysis of goods or services, including 

conduct related to the goods or services. 

R. “Seller” means a Person who offers for sale or sells a Business 

Opportunity. 

III. PROHIBITION CONCERNING ECOMMERCE COACHING PROGRAMS AND 

REAL ESTATE COACHING PROGRAMS 

Defendant Chamberlain is permanently restrained and enjoined from advertising, 

marketing, distributing, promoting, offering for sale, or selling, or assisting in the 

advertising, marketing, distributing, promoting, offering for sale, or selling, of any 

eCommerce Coaching Program or Real Estate Coaching Program, even if it also is a 

Business Opportunity. 

IV. PROHIBITION CONCERNING EARNINGS CLAIMS 

Defendant Chamberlain and his agents, employees, and all other persons in 

active concert or participation with them, who receive actual notice of this Order by 

personal service or otherwise, whether acting directly or indirectly, in connection with 

the advertising, marketing, promoting, or offering for sale of any goods or services, are 

permanently restrained and enjoined from making any Earnings Claim or assisting 

others in making Earnings Claims, expressly or by implication, unless: 

A. The Earnings Claim is non-misleading; 

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B. At the time the Earnings Claim is made, Defendant Chamberlain: 

1. has a reasonable basis for the claim; 

2. has in his possession written materials that substantiate for the 

claimed earnings and that the claimed earnings are typical for 

consumers similarly situated to those to whom the claim is made; 

and 

3. makes the written substantiation for Earnings Claims available 

upon request to the consumer, potential Purchaser or investor, 

and the FTC; and 

C. Any earnings that form the basis for the Earnings Claims were 

achieved in compliance with the law. 

V. OTHER PROHIBITED BUSINESS PRACTICES 

Defendant Chamberlain and his agents, employees, and all other persons in 

active concert or participation with them, who receive actual notice of this Order by 

personal service or otherwise, whether acting directly or indirectly, in connection with 

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

permanently restrained and enjoined from: 

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

implication: 

1. That consumers will learn everything they need to know to make 

substantial income at a workshop or event; 

2. That a good or service: 

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a. will allow consumers to earn thousands of dollars in profit 

without needing a significant amount of money, good credit, 

or legal immigration status to succeed; 

b. is offered only for a limited time, can be purchased only at a 

particular event, or is offered only to selected consumers 

who are vetted to ensure they will be successful; or 

c. provides consumers with personalized assistance from 

experts or mentors. 

3. That Defendant Chamberlain needs need detailed financial 

information from consumers to determine if the consumers 

qualify for a good or service; 

4. That Purchasers will receive financing by purchasing a Business 

Opportunity or Investment Opportunity; or 

5. Any other fact material to consumers concerning a good or 

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

limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics. 

B. Advising consumers to increase their credit card limit or apply for 

additional credit cards to finance the purchase of any Business Opportunity or 

Investment Opportunity; 

C. Failing to ensure that any testimonials Defendant Chamberlain uses are 

truthful and non-misleading; 

D. Failing to disclose whether any positive reviews of, or testimonials about, 

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a good or service have been from owners, officers, employees, or agents of the Person 

offering the good or service for sale; 

E. Providing consumers with any Documents in a language different from the 

one used to offer the good or service, including purchase agreements that outline the 

cancellation policy and include other material terms of purchase, provided, however, 

that Settling Defendants may provide documents to consumers in both English and the 

language of the offer simultaneously. 

VI. PROHIBITION AGAINST VIOLATING THE DISCLOSURE REQUIREMENTS 

OF THE COOLING-OFF RULE 

Defendant Chamberlain and his agents, employees, and all other persons in 

active concert or participation with them, who receive actual notice of this Order by 

personal service or otherwise, whether acting directly or indirectly, in connection with 

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

advertising, marketing, distributing, promoting, offering for sale, or selling, of any goods 

or services, are permanently restrained and enjoined from failing to: 

A. Furnish buyers with a fully completed receipt or copy of any contract 

pertaining to such sale at the time of its execution, which is in the same language as 

that principally used in the oral sales presentation provided, however, that nothing 

herein shall prohibit him from providing the aforementioned documents to buyers in 

multiple languages. 

B. Furnish a “NOTICE OF CANCELLATION” or “NOTICE OF RIGHT TO 

CANCEL” in duplicate, that buyers can use to cancel the transaction, in accordance 

with 16 C.F.R. § 429.1, and 

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C. Orally inform buyers of their right to cancel the transaction. 

VII. PROHIBITIONS CONCERNING CONSUMER REVIEWS AND COMPLAINTS 

Defendant Chamberlain and his agents, employees, and all other persons in 

active concert or participation with them, who receive actual notice of this Order by 

personal service or otherwise, whether acting directly or indirectly, in connection with 

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

advertising, marketing, distributing, promoting, offering for sale, or selling, of any good 

or service, are permanently restrained and enjoined from: 

A. Prohibiting or restricting individual consumers’ ability to communicate 

reviews, performance assessments, and similar analyses about goods, services, or 

conduct they have purchased; 

B. Imposing a penalty or fee against individual consumers who engage in 

such communications; 

C. Suppressing the availability of truthful or non-defamatory negative 

comments or reviews of Defendant Chamberlain, or any of his goods or services, 

agents, or employees through any means, including threats, intimidation, nondisparagement clauses, conditioning refunds, and suppression of online content; 

D. Offering to any prospective customer a contract, or offering to any 

customer a renewal contract, that includes a Prohibited Agreement Provision; 

E. Requiring that a customer accept a Prohibited Agreement Provision as 

a condition of Defendant Chamberlain’s fulfillment of its obligations under a 

customer contract; or 

F. Requiring that a customer accept a Prohibited Agreement Provision as a 

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condition of a receiving a refund or Defendant Chamberlain not opposing a chargeback; 

or 

G. Representing, including through any notice, warning, threat to enforce, or 

attempt to enforce, to any purchaser of any good or service — regardless of when 

purchased — that any contract: 

1. Prohibits consumers from speaking about or publishing truthful or 

non-defamatory negative comments or reviews about Defendant 

Chamberlain, or any of Defendant Chamberlain’s goods, services, 

agents, or employees; or 

2. Imposes any precondition, penalty, or fee on consumers speaking 

about or publishing any comments or reviews about Defendant 

Chamberlain, or any of Defendant Chamberlain’s goods, services, 

agents, or employees. 

Nothing in this Section shall require Defendant Chamberlain to publish or host the 

content of any person, affect any other legal duty of a party to a contract, or affect any 

cause of action arising from the breach of such duty. 

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VIII. MONETARY RELIEF 

A. Judgment in the amount of Twenty-Nine Million One Hundred and 

Seventy-Five Thousand Dollars ($29,175,000) is entered in favor of the Commission 

against Defendant Chamberlain as monetary relief. The liability of Defendant 

Chamberlain for the judgment shall be joint and several with any other Defendants to 

the extent subsequently ordered. 

B. Defendant Chamberlain is ordered to pay to the Commission $35,000. 

Wells Fargo Bank, within five (5) days of the entry of this Order, and Defendant 

Chamberlain as applicable, shall, execute any paperwork and issue any instructions 

necessary to remit $35,000 from currently frozen Wells Fargo Bank savings account 

X0911 to the Commission by electronic fund transfer in accordance with instructions 

previously provided by a representative of the Commission. 

C. Upon the payment described in Section VIII.B, the remainder of the 

judgment is suspended, subject to the Subsections below. 

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

expressly premised upon the truthfulness, accuracy, and completeness of Defendant 

Chamberlain’s sworn financial statements and related documents submitted to the 

Commission, namely: the Financial Statement of Individual Defendant Bryce 

Chamberlain signed on June 14, 2023, including the attachments. 

E. The suspension of the judgment will be lifted as to Defendant Chamberlain 

if, upon motion by the Commission, the Court finds that Defendant Chamberlain failed 

to disclose any material asset, materially misstated the value of any asset, or made 

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any other material misstatement or omission in the financial representations identified 

above. 

F. If the suspension of the judgment is lifted, the judgment becomes 

immediately due as to Defendant Chamberlain in the amount specified in Subsection 

B above (which the parties stipulate only for purposes of this Section represents the 

consumer injury alleged in the Complaint), less any payment previously made 

pursuant to this Section or any payment made by any other Defendant in this case, 

plus interest computed from the date of entry of this Order. 

IX. ADDITIONAL MONETARY PROVISIONS 

A. Defendant Chamberlain relinquishes dominion and all legal and equitable 

right, title, and interest in all assets transferred pursuant to this Order and may not seek 

the return of any assets. 

B. The facts alleged in the Complaint against Chamberlain will be taken as 

true, without further proof, in any subsequent civil litigation by or on behalf of the 

Commission, including in a proceeding to enforce its rights to any payment or monetary 

judgment pursuant to this Order, such as a nondischargeability complaint in any 

bankruptcy case. 

C. The facts alleged in the Complaint against Chamberlain establish all 

elements necessary to sustain an action by the Commission pursuant to Section 

523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have 

collateral estoppel effect for such purposes. 

D. Defendant Chamberlain acknowledges that his Taxpayer Identification 

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Numbers (Social Security Number), which he previously submitted to the 

Commission, may be used for collecting and reporting on any delinquent amount 

arising out of this Order, in accordance with 31 U.S.C. §7701. 

E. All money received by the Commission pursuant to this Order may be 

deposited into a fund administered by the Commission or its designee to be used for 

consumer relief, such as redress and any attendant expenses for the administration of 

any redress fund. If a representative of the Commission decides that direct redress to 

consumers is wholly or partially impracticable or money remains after such redress is 

completed, the Commission may apply any remaining money for such related relief 

(including consumer information remedies) as it determines to be reasonably related 

to Defendants’ practices alleged in the Complaint. Any money not used for relief is to 

be deposited to the U.S. Treasury. Defendant Chamberlain has no right to challenge 

any actions the Commission or its representatives may take pursuant to this 

Subsection. 

F. The asset freeze imposed by the July 18, 2023 Preliminary Injunction 

Order [ECF No. 52], is modified to permit the payment identified in Section VIII.B 

above. Upon completion of that payment, the asset freeze as to Defendant 

Chamberlain is dissolved. Any existing asset freeze as to the remaining non-settling 

Defendants shall remain in full force and effect. 

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X. CUSTOMER INFORMATION 

Defendant Chamberlain and his agents, employees, and all other persons in active 

concert or participation with them, who receive actual notice of this Order by personal 

service or otherwise, are permanently restrained and enjoined from directly or indirectly: 

A. Disclosing, using, or benefitting from customer information, including the 

name, address, telephone number, email address, social security number, other 

identifying information, or any data that enables access to a customer’s account 

(including a credit card, bank account, or other financial account), that any Defendant 

obtained prior to entry of this Order in connection with the advertising, marketing, 

promoting, offering for sale, or selling of Defendants’ Products; and 

B. Failing to destroy such customer information in all forms in his possession, 

custody, or control within 7 days of entry of this Order. 

XI. COOPERATION 

Defendant Chamberlain must fully cooperate with representatives of the Commission 

in this case and in any investigation related to or associated with the transactions or the 

occurrences that are the subject of the Complaint. Defendant Chamberlain must provide 

truthful and complete information, evidence, and testimony. Defendant Chamberlain 

must appear for interviews, discovery, hearings, trials, and any other proceedings that a 

Commission representative may reasonably request upon 5 days written notice, or other 

reasonable notice, at such places and times as a Commission representative may 

designate, without the service of a subpoena. 

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XII. ORDER ACKNOWLEDGMENTS 

Defendant Chamberlain shall obtain acknowledgments of receipt of this Order as 

follows: 

A. Defendant Chamberlain, within 7 days of entry of this Order, must submit to 

the Commission an acknowledgment of receipt of this Order sworn under penalty of 

perjury. 

B. For 5 years after entry of this Order, Defendant Chamberlain for any 

business for which Defendant Chamberlain, individually or collectively with any other 

person, is the majority owner or controls directly or indirectly, must deliver a copy of 

this Order to: (1) all principals, officers, directors, and LLC managers and members; 

(2) all employees having managerial responsibilities for conduct related to the subject 

matter of the Order and all agents and representatives who participate in conduct 

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

any change in structure as set forth in the Section titled Compliance Reporting. 

Delivery must occur within 7 days of entry of this Order for current personnel. For all 

others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which Defendant Chamberlain delivered a 

copy of this Order, he must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

XIII. COMPLIANCE REPORTING 

Defendant Chamberlain shall make timely submissions to the Commission as follows: 

A. One year after entry of this Order, Defendant Chamberlain must submit a 

compliance report, sworn under penalty of perjury: 

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1. Defendant Chamberlain must: (a) identify the primary 

physical, postal, and email address and telephone number, as designated 

points of contact, which representatives of the Commission may use to 

communicate with him; (b) identify all of Defendant Chamberlain’s 

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

email, and Internet addresses; (c) describe the activities of each business, 

including the Products offered, the means of advertising, marketing, and 

sales, and the involvement of any other Defendant (which Defendant 

Chamberlain must describe if he knows or should know due to his own 

involvement); (d) describe in detail whether and how Defendant 

Chamberlain is in compliance with each Section of this Order; and (e) 

provide a copy of each Order Acknowledgment obtained pursuant to this 

Order, unless previously submitted to the Commission. 

2. Additionally, Defendant Chamberlain must: (a) identify all 

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

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

business for which Defendant Chamberlain performs services whether as 

an employee or otherwise and any entity in which Defendant Chamberlain 

has any ownership interest; and (c) describe in detail Defendant 

Chamberlain’s involvement in each such business, including title, role, 

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

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B. For 10 years after entry of this Order, Defendant Chamberlain must submit 

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

the following: 

1. Defendant Chamberlain must report any change in: (a) 

any designated point of contact; or (b) the structure of any entity in which 

he has any ownership interest in or controls directly or indirectly that may 

affect compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or 

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

2. Additionally, Defendant Chamberlain must report any 

change in: (a) name, including aliases or fictitious name, or residence 

address; or (b) title or role in any business activity, including any business 

for which he performs services whether as an employee or otherwise and 

any entity in which he has any ownership interest, and identify the name, 

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

C. Defendant Chamberlain must submit to the Commission notice of the filing 

of any bankruptcy petition, insolvency proceeding, or similar proceeding by or against 

Defendant Chamberlain within 14 days of its filing. 

D. Any submission to the Commission required by this Order to be sworn 

under penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, 

such as by concluding: “I declare under penalty of perjury under the laws of the 

United States of America that the foregoing is true and correct. Executed on: _____” 

and supplying the date, signatory’s full name, title (if applicable), and signature. 

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E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to 

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal Trade 

Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line 

must begin: FTC v. Vision Online, et al, X230023. 

XIV. RECORDKEEPING 

Defendant Chamberlain shall create the following records for 10 years after entry 

of the Order, and retain each such record for 5 years. Specifically, Defendant 

Chamberlain for any business that he, individually or collectively with any other 

Defendants, is a majority owner or controls directly or indirectly, must create and retain 

the following records: 

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

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

an employee or otherwise, that person’s: name; addresses; telephone numbers; job 

title or position; dates of service; and (if applicable) the reason for termination; 

C. records of all consumer complaints and refund requests, whether received 

directly or indirectly, such as through a third party, and any response; 

D. a copy of each unique advertisement or other marketing material 

disseminated to consumers; 

E. recordings of any live presentations to groups of consumers; and 

F. all records necessary to demonstrate full compliance with each provision of 

this Order, including all submissions to the Commission. 

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XV. COMPLIANCE MONITORING 

For the purpose of monitoring Defendant Chamberlain's compliance with this 

Order, including the financial representations upon which part of the judgment was 

suspended and any failure to transfer any assets as required by this Order: 

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

Commission, Defendant Chamberlain must: submit additional compliance reports or 

other requested information, which must be sworn under penalty of perjury; appear for 

depositions; and produce documents for inspection and copying. The Commission is 

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

procedures prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic 

depositions), 31, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission is authorized to 

communicate directly with Defendant Chamberlain. Defendant Chamberlain must permit 

representatives of the Commission to interview any employee or other person affiliated 

with Defendant Chamberlain who has agreed to such an interview. The person 

interviewed may have counsel present. 

C. The Commission may use all other lawful means, including posing, through its 

representatives as consumers, suppliers, or other individuals or entities, to Defendant 

Chamberlain or any individual or entity affiliated with him, without the necessity of 

identification or prior notice. Nothing in this Order limits the Commission’s lawful use of 

compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 

57b-1. 

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

reporting agency must furnish consumer reports concerning Defendant Chamberlain, 

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

XI. RETENTION OF JURISDICTION 

This Court shall retain jurisdiction of this matter for purposes of construction, 

modification, and enforcement of this Order. 

SO ORDERED, this day of , 2023. 

WENDY W. BERGER 

UNITED STATES DISTRICT JUDGE 

SO STIPULATED AND AGREED: 

FOR FEDERAL TRADE COMMISSION 

Date: January 12, 2024

J. Ronald Brooke, Jr. 

Virginia Rosa 

Attorneys 

Federal Trade Commission 

Division of Marketing Practices 

600 Pennsylvania Ave, NW 

Mailstop CC-6316 

Washington, DC 20580 

(202) 326-3068 / vrosa@ftc.gov 

(202) 326-3484 / jbrooke@ftc.gov 

(202) 326-3395 (fax) 

Attorneys for Plaintiff 

Federal Trade Commission 

22 
DEFENDANT: 

~

~ - CHAMBERLAIN 

,. 

23 

Case 6:23-cv-01041-WWB-DCI Document 114-2 Filed 01/17/24 Page 23 of 23 PageID 4798