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Case 8:19-cv-01243-GW-JEM Document 1 Filed 06/21/19 Page 1 of 15 Page ID #:1

Joseph H. Hunt 

Assistant Attorney General 

Civil Division 

Nicola T. Hanna 

United States Attorney 

Gustav W. Eyler 

Director 

Consumer Protection Branch 

Rachel Baron 

Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, DC 20044 

(202) 532-4488

Rachel.e.baron@usdoj.gov 

OF COUNSEL: 

Barbara Chun, Cal. Bar No. 186907 

bchun@ftc.gov

Federal Trade Commission 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Tel: (310) 824-4300; Fax: (310) 824-4380 
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UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

UNITED STATES OF AMERICA, 

 Plaintiff, 

v.

Media Mix 365, LLC, a California 

limited liability company, also d/b/a 

Solar Research Group and Solar 

Nation, 

Nicholas J. Long, individually and as 

an owner and officer of Media Mix 

365, LLC, and 

Nicole J. Long, a/k/a Nicole 

Leonard, a/k/a Nicole Leonard-Long, 

as an owner of Media Mix 365, LLC, 

Defendants. 

 Case No. 19-1243 

COMPLAINT FOR PERMANENT 

INJUNCTION, CIVIL PENALTIES 

AND OTHER EQUITABLE RELIEF

 

Plaintiff, the United States of America, acting upon notification and 

uthorization to the Attorney General by the Federal Trade Commission (“FTC”), 

ursuant to Section 16(a)(1) of the Federal Trade Commission Act (“FTC Act”), 

5 U.S.C. § 56(a)(1), for its Complaint alleges: 

1. Plaintiff brings this action under Sections 5(a), 5(m)(1)(A), 13(b), 

6(a), and 19 of the FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), 56(a), and 

7b, and Section 6 of the Telemarketing and Consumer Fraud and Abuse 

revention Act (the “Telemarketing Act”), 15 U.S.C. § 6105, to obtain monetary 

ivil penalties, permanent injunctive relief, rescission or reformation of contracts, 

a

p

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5

P

c

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restitution, the refund of monies paid, disgorgement of ill-gotten monies, and other 

equitable relief for Defendants’ acts or practices in violation of Section 5(a) of the 

FTC Act, 15 U.S.C. § 45(a), and the FTC’s Telemarketing Sales Rule (“TSR”), as 

amended, 16 C.F.R. Part 310. 

INTRODUCTION

2. Media Mix 365, LLC (“Media Mix”) is a telemarketer that develops 

leads for home solar energy companies by initiating outbound telephone calls to 

consumers. Nicholas J. Long and Nicole J. Long are the owners of Media Mix. 

Since at least 2015, Media Mix has called millions of phone numbers on the 

National Do Not Call Registry maintained by the FTC (the “National Do Not Call 

Registry” or “Registry”) and has called phone numbers repeatedly or continuously 

with the intent to annoy, abuse, or harass any person at the called number. These 

calls violate Section 5 of the FTC Act, 15 U.S.C. § 5(a) and the TSR, 16 C.F.R. 

Part 310. 

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 

§§ 1331, 1337(a), 1345, and 1355. 

4. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), 

(c)(1), (c)(2), and 1395(a), and 15 U.S.C. § 53(b). 

THE TELEMARKETING SALES RULE AND 

THE NATIONAL DO NOT CALL REGISTRY 

5. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101-6108. The FTC adopted the original TSR in 1995, extensively 

amended it in 2003, and amended certain provisions thereafter. 16 C.F.R. Part 

310.

6. Among other things, the 2003 amendments to the TSR established the 

National Do Not Call Registry of consumers who do not wish to receive certain 

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types of telemarketing calls. Consumers can register their telephone numbers on 

the Registry without charge either through a toll-free telephone call or over the 

Internet at donotcall.gov. 

7. Consumers who receive telemarketing calls to their registered 

numbers can complain of Registry violations the same way they registered, 

through a toll-free telephone call or over the Internet at donotcall.gov, or by 

otherwise contacting law enforcement authorities. 

8. The FTC allows sellers, telemarketers, and other permitted 

organizations to access the Registry over the Internet at 

telemarketing.donotcall.gov, to pay the fee(s) if required, and to download the 

numbers not to call. 

9. Under the TSR, a “telemarketer” means any person who, in 

connection with telemarketing, initiates or receives telephone calls to or from a 

customer or donor. 16 C.F.R. § 310.2(ff). A “seller” means any person who, in 

connection with a telemarketing transaction, provides, offers to provide, or 

arranges for others to provide goods or services to the customer in exchange for 

consideration. Id. § 310.2(dd). 

10. Under the TSR, an “outbound telephone call” means a telephone call 

initiated by a telemarketer to induce the purchase of goods or services or to solicit 

a charitable contribution. Id. § 310.2(x). 

11. The TSR prohibits sellers and telemarketers from initiating an 

outbound telephone call to numbers on the Registry unless the seller or 

telemarketer can prove that the seller (1) has obtained the consumer’s express 

agreement, in writing, to place such calls, or (2) has an established business 

relationship with the consumer, and the consumer has not stated that he or she does 

not wish to receive such calls. Id. § 310.4(b)(1)(iii)(B). Valid written consent to 

receive a live telemarketing call to a number on the Registry requires: (i) a writing 

signed by the consumer, (ii) clearly evidencing authorization to receive calls 

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placed on behalf of a specific seller, and (iii) stating the phone number to which 

such calls may be placed. Id. § 310.4(b)(1)(iii)(B)(1). Telemarketers must retain 

all records of such “express agreement.” Id. § 310.5(a)(5). An established business 

relationship means a relationship between a seller and a consumer based on (1) the 

consumer’s purchase, rental, or lease of the seller’s goods or services or a financial 

transaction between the consumer and the seller, within the eighteen months 

immediately preceding the date of the telemarketing call; or (2) the consumer’s 

inquiry or application regarding a product or service offered by the seller, within 

the three months immediately preceding the date of the telemarketing call. Id. § 

310.2(q). 

12. The TSR prohibits sellers and telemarketers from causing any 

telephone to ring, or engaging any person in telephone conversation, repeatedly or 

continuously with intent to annoy, abuse, or harass any person at the called 

number. Id. § 310.4(b)(1)(i).

13. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. 

§ 6102(c), and Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation 

of the TSR constitutes an unfair or deceptive act or practice in or affecting 

commerce, in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

DEFENDANTS

14. Defendant Media Mix 365, LLC, also doing business as Solar 

Research Group and Solar Nation, is a California limited liability company with its 

principal place of business in Santa Ana, California. Media Mix is a closely held 

LLC owned by only Nicholas J. Long and Nicole J. Long. Media Mix transacts or 

has transacted business in this District and throughout the United States. 

15. Media Mix is familiar with telemarketing statutes and regulations. 

Since 2016, Media Mix has been named as a defendant in at least three lawsuits, 

including two class actions, that allege National Do Not Call Registry violations. 

See Madar v. Media Mix 365 LLC, 37-2016-00336110-SC-SC-CTL (San Diego 

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County, filed 5/17/16); Affolder v. Media Mix 365 LLC, Nicholas Long, and Does 

1-25, 8:16-cv-1470-DOC-KES (C.D. Cal., filed 8/9/2016); Boger v. Trinity 

Heating & Air, Inc. and Media Mix 365, LLC, 8:17-cv-01729-TDC (D. Md., filed

6/23/17). 

16. Since 2016, some Media Mix clients also have been sued for calls to 

numbers on the National Do Not Call Registry. Media Mix was an initiator of the 

violative phone calls as alleged in each action. For example, in Worsham v. 

Trinity Heating and Air, Inc., 1:16-cv-01131-JFM (D. Md., filed 5/31/16), the 

complaint alleged that the defendant’s telemarketers identified themselves as 

“Solar Research Group,” which is one of Media Mix’s fictitious business names. 

Likewise, in Slovin v. Sunrun, Inc., 4:15-cv-05340-YGR (N.D. Cal., filed

7/12/16), the complaint alleged that Media Mix made calls on behalf of Sunrun 

using the fictitious business name “Solar Nation,” in violation of the National Do 

Not Call Registry. 

17. Media Mix has access to the National Do Not Call Registry. In 

December 2013, Media Mix subscribed for access to the Registry and downloaded 

the phone numbers registered in four Colorado area codes. It has not downloaded 

any phone numbers since then under its own subscription to the Registry. The 

FTC also has no record that Media Mix has accessed the Registry at any time 

under another subscription. 

18. Defendant Nicholas J. Long (“Nick Long”) is the chief executive 

officer and an owner of Media Mix. At times material to this Complaint, acting 

alone or in concert with others, Nick Long has had the authority and responsibility 

to prevent or correct the unlawful telemarketing practices of Media Mix and has 

formulated, directed, controlled, had the authority to control, or participated in the 

acts or practices of Media Mix, including the acts and practices set forth in this 

Complaint. Nick Long resides in this District and, in connection with the matters 

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alleged herein, transacts or has transacted business in this District and throughout 

the United States. 

19. Nick Long is familiar with telemarketing statutes and regulations. In 

2010, Texas sued Nick Long, Michael Aaron Jones (also known as Aaron Michael 

Jones) (“Jones”), Andrew Salisbury (“Salisbury”), their company, On Point Media, 

Inc., and others for calling phone numbers on the National Do Not Call Registry 

while telemarketing auto warranties. Texas v. SCM Media, Inc. A-09-CV-387-SS 

(W.D. Tex. 2011). In 2011, Nick Long, Salisbury, and Jones stipulated to entry of 

an order (the “Order”) to settle the Texas case. The Order required Nick Long, 

Salisbury, and Jones to comply with federal and state telemarketing statutes, 

including the Telemarketing Act, 15 U.S.C. §§ 6101-6108, and all regulations 

promulgated pursuant to such statutes for calls to Texas consumers or for calls 

conducted from Texas. It also enjoined them from aiding, abetting, or facilitating 

others in making telephone calls that violated those telemarketing statutes and 

regulations, or from initiating or causing others to initiate outbound telephone calls 

to phone numbers on the National Do Not Call Registry. 

20. Nick Long provided a document to Texas called “Do Not Call List 

Training.” This document explains that “The National Do Not Call Registry is 

available to help consumers block unwanted telemarketing calls at home.” The 

document also notes that “Telemarketers have up to 30 days from the date 

[consumers] register [on the Do Not Call Registry] to remove [the consumers’] 

phone number from their list and stop calling [the consumers].”

21. In 2016, Nick Long and Media Mix were named as defendants in a 

class action that alleges Media Mix called numbers on the National Do Not Call 

Registry to telemarket home solar energy systems. See Affolder, 8:16-cv-1470-

DOC-KES. 

22. Since 2010, Nick Long has maintained close business ties to his 

codefendants in the Texas lawsuit, Salisbury and Jones. Both Salisbury and Jones 

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were recently sued by the FTC for placing millions of calls to numbers on the Do 

Not Call Registry. Since at least 2016, Nick Long has also had close business ties 

to Justin Ramsey. Justin Ramsey has also been sued by the FTC for placing 

millions of calls to numbers on the Do Not Call Registry. 

 In May 2018, the FTC sued Salisbury and his company, World 

Connection USA, LLC (“World Connection”), in FTC v. Christiano, 

SACV 18-0936-DOC (C.D. Cal.). The Christiano complaint alleged 

that since 2005, the defendants made or assisted, and facilitated the 

making of, telemarketing calls to phone numbers on the Registry. 

Nick Long was the organizer and is the registered agent for World 

Connection and was personally served with the Christiano complaint 

on June 4, 2018. 

 In January 2017, the FTC sued Jones and others in FTC v. Jones, 

8:17-cv-58-DOC-JCG (C.D. Cal.). The Jones complaint alleged that, 

since at least March 2009, Jones controlled an enterprise that made or 

facilitated the making of prerecorded calls (“robocalls”) to numbers 

on the National Do Not Call Registry. Jones’s robocalling enterprise 

included On Point Media, the auto warranty telemarketing company 

that Jones, Salisbury, and Nick Long controlled and which was a 

defendant in the 2010 Texas action. 

 In January 2017, the FTC sued Justin Ramsey and others in FTC v.

Ramsey, 9:17-cv-80032-KAM (S.D. Fla.). The Ramsey complaint 

alleged that, since 2012, Ramsey and his company, Prime Marketing, 

LLC, robocalled numbers on the National Do Not Call Registry. 

Media Mix employed Ramsey to make calls on its behalf for some of 

Media Mix’s clients until July 2016. In April 2016, Media Mix paid 

Prime Marketing over $110,000. 

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 In July 2018, the FTC sued Ramsey and Jones, and Ramsey’s

company, Allstar Data, LLC, in FTC v. Pointbreak Media, LLC, 18-

61017-CIV-Altonaga/ Seltzer (S.D. Fla.). The Pointbreak Media 

complaint alleged that, since at least November 2016, the defendants 

operated a telemarketing scam that included robocalling phone 

numbers on the National Do Not Call Registry. From May to October 

2016, Media Mix paid Allstar Data over $124,000. 

23. Defendant Nicole J. Long (“Nicole Long”), also known as Nicole 

Leonard and Nicole Leonard-Long, is Media Mix’s majority owner and is married 

to Nick Long. She was Media Mix’s organizer and initial agent for service of 

process in 2013. At various times in documents filed with the California Secretary 

of State or the Orange County Clerk-Recorder, she has declared she is its manager, 

member, CEO, and owner. She registered Media Mix’s fictitious business name, 

“Solar Research Group.” At all times material to this Complaint, acting alone or in 

concert with others, Nicole Long has had the authority and responsibility to 

prevent or correct the unlawful telemarketing practices of Media Mix and has 

formulated, directed, controlled, had the authority to control, or participated in the 

acts or practices of Media Mix, including the acts and practices set forth in this 

Complaint. Nicole Long resides in this District and, in connection with the matters 

alleged herein, transacts or has transacted business in this District and throughout 

the United States. 

COMMERCE 

24. At all times material to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS ACTIVITIES

25. Defendants are “telemarketers” engaged in “telemarketing” as those 

terms are defined in the TSR. 

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26. Defendants initiate outbound telephone calls to consumers in the 

United States to induce the purchase of home solar energy systems. 

27. Defendants engage in telemarketing by a plan, program, or campaign 

conducted to induce the purchase of home solar energy systems by the use of one 

or more telephones and which involves more than one interstate telephone call. 

28. Since at least 2015 and as part of their campaign to market home solar

energy systems, Defendants have initiated millions of outbound telemarketing calls

to the phone numbers of consumers who had previously registered their phone 

numbers on the Do Not Call Registry. 

29. Defendants’ telemarketers typically identify themselves as “Solar 

Research Group” or “Solar Nation” (Defendants’ fictitious business names).

30. During the telemarketing calls, Defendants’ telemarketers ask 

consumers scripted questions to assess their interest in and eligibility for a home 

solar energy system. 

31. Consumers who express an interest and who meet the prequalification 

criteria are then transferred by Defendants’ telemarketers to Defendants’ clients. 

Defendants’ clients pay Defendants a fee for the leads they purchase from 

Defendants. 

32. Defendants have called numbers on the National Do Not Call 

Registry. Defendants have not removed the phone numbers of consumers who 

were registered on the National Do Not Call Registry by employing a version of 

the National Do Not Call Registry obtained from the Commission no more than 

thirty-one days before the date of any call. 

33. Consequently, Defendants have made millions of calls to telephone 

numbers on the National Do Not Call Registry. 

34. Millions of consumers whose telephone numbers were on the National

Do Not Call Registry and who received Defendants’ telemarketing calls since 2015

did not have a pre-existing business relationship with Defendants nor had they 

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given express written consent to receive telemarketing calls from Defendants or 

from the third parties to whom Defendants sold the sales leads. 

35. Defendants have also made thousands of telephone calls that caused 

telephones to ring, or engaged people in telephone conversations, repeatedly or 

continuously: 

 Media Mix called thousands of phone numbers more than 3 times in a 

single day; 

 Media Mix called thousands of phone numbers more than 30 times each; 

 Media Mix called one number more than 300 times in less than six months; 

 And finally, Media Mix called one number over 1,000 times in less than 

one year. 

Defendants made these calls with the intent to annoy, abuse, or harass any 

person at the called number. 

36. Defendants’ conduct is ongoing. The FTC continues to receive 

complaints about Defendants calling phone numbers on the Registry. 

37. Based on the facts and violations of law alleged in this Complaint, the 

FTC has reason to believe that Defendants are violating or are about to violate laws

enforced by the Commission. 

VIOLATIONS OF THE TELEMARKETING SALES RULE 

Count I 

Calls to Persons Registered on the National Do Not Call Registry

38. In numerous instances, in connection with telemarketing, Defendants 

have initiated or caused others to initiate an outbound telephone call to a person’s 

telephone number on the National Do Not Call Registry in violation of the TSR. 16

C.F.R. §310.4(b)(1)(iii)(B). 

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Count II 

Repeated, Continuous Calls 

39. In numerous instances, in connection with telemarketing, Defendants 

have caused telephones to ring, or have engaged persons in telephone 

conversations, repeatedly or continuously with intent to annoy, abuse, or harass 

any person at the called number, in violation of the TSR. 16 C.F.R. 

§ 310.4(b)(1)(i). 

CONSUMER INJURY 

40. Consumers are suffering, have suffered, and will continue to suffer 

substantial injury as a result of Defendants’ violations of the FTC Act and the TSR.

Absent injunctive relief by this Court, Defendants are likely to continue to injure 

consumers and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

41. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court

to grant injunctive and such other relief as the Court may deem appropriate to halt 

and redress violations of any provision of law enforced by the FTC. Section 19 of 

the FTC Act, 16 U.S.C. § 57b, and Section 6(b) of the Telemarketing Act, 15 

U.S.C. § 6105(b), authorize this Court to grant such relief as the Court finds 

necessary to redress injury to consumers resulting from Defendants’ violations of 

the FTC Act and the TSR, including rescission or reformation of contracts, and the 

refund of money. 

42. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as 

modified by Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 

1990, 28 U.S.C. § 2461, as amended, and as implemented by FTC Rule 1.98(d), 

16 C.F.R. § 1.98(d), authorizes this Court to award monetary civil penalties. 

From 2015 until July 31, 2016, the Court was authorized to award a penalty of up 

to $16,000 for each violation of the TSR. See 16 C.F.R. §1.98(d) (2009). 

Effective August 1, 2016, the maximum penalty amount was adjusted to $40,000 

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per violation. 16 C.F.R. § 1.98(d) (2016). Effective January 24, 2017, the 

maximum civil penalty amount was adjusted to $40,654. 16 C.F.R. § 1.98 (2017).

Effective January 22, 2018, the maximum civil penalties amount was adjusted to 

$41,484 for each violation of the TSR. 16 C.F.R. § 1.98 (2018). As of February 

14, 2019, the maximum civil penalties amount was adjusted to $42,530 for each 

violation of the TSR. 16 C.F.R. § 1.98 (2019). Some of the TSR violations 

alleged in this Complaint occurred during 2015-2018 when the civil penalty was 

capped at $16,000, $40,000, $40,654, or $41,484 per violation. Defendants’ 

violations of the TSR were committed with the knowledge required by Section 

5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

43. This Court, in the exercise of its equitable jurisdiction, may award 

ancillary relief to remedy injury caused by Defendants’ violations of the TSR and 

the FTC Act. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff requests that this Court, pursuant to Sections 5(a),

5(m)(1)(A), 13(b), 16(a), and 19 of the FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A)

53(b), 56(a), and 57b, and Section 6(b) of the Telemarketing Act, 15 U.S.C. 

§ 6105(b), and the Court’s own equitable powers: 

A. Enter judgment against Defendants and in favor of Plaintiff for each 

violation alleged in this complaint; 

B. Award Plaintiff monetary civil penalties from each Defendant for 

every violation of the TSR; 

C. Enter a permanent injunction to prevent future violations of the FTC 

Act and the TSR by Defendants; 

D. Award such relief as the Court finds necessary to redress injury to 

consumers resulting from Defendants’ violations of the FTC Act and 

the TSR, including but not limited to, rescission or reformation of 

 

, 

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contracts, restitution, the refund of monies paid, and the disgorgement

of ill-gotten monies; and 

E. Award Plaintiff the costs of bringing this action, as well as such other 

and additional relief as the Court may determine to be just and proper.

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Dated: June 20, 2019 Respectfully submitted, 

JOSEPH H. HUNT 

Assistant Attorney General 

Civil Division 

NICOLA T. HANNA 

United States Attorney 

GUSTAV W. EYLER 

Director 

Consumer Protection Branch 

/s/ Rachel Baron____________ 

Rachel Baron 

Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

P.O. Box 386 

Washington, DC 20044 

(202) 532-4488

Rachel.e.baron@usdoj.gov 

 

OF COUNSEL: 

THOMAS N. DAHDOUH 

Regional Director 

Western Region 

Federal Trade Commission 

Barbara Chun 

Attorney 

Federal Trade Commission 

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