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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx)

JS-6 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

WESTERN DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

 v. 

MYLIFE.COM, INC., a corporation, 

and 

JEFFREY TINSLEY, individually and as 

an officer of MYLIFE.COM, INC., 

Defendants. 

Case No. 2:20-cv-6692-JFW (PDx) 

STIPULATED ORDER FOR 

PERMANENT INJUNCTION 

AND EQUITABLE MONETARY 

RELIEF 

Case 2:20-cv-06692-JFW-PD Document 204 Filed 12/15/21 Page 1 of 27 Page ID #:9596
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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

Plaintiff and the Defendants stipulate to the entry of this Stipulated Order for 

Permanent Injunction and Equitable Monetary Relief (“Order”) to resolve all matters 

in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows:

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants participated in deceptive and 

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

violation of ROSCA, 15 U.S.C. § 8404, and in violation of the FCRA, 15 U.S.C. §§ 

1681-1681x, in the promotion and sale of background reports. 

3. Defendants neither admit nor deny any of the allegations in the

Complaint, except as specifically stated in their answer to the Complaint. 

4. Defendants waive any claim that they 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 agree to bear their own costs and attorney fees. 

5. Defendants waive all rights to appeal or otherwise challenge or contest 

the validity of this Order. 

DEFINITIONS 

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

A. “Clear(ly) and conspicuous(ly)” means that a required disclosure is 

difficult to miss (i.e., easily noticeable) and easily understandable by ordinary 

consumers, including in all of the following ways: 

1. In any communication that is solely visual or solely audible, the 

disclosure must be made through the same means through which the communication 

is presented. In any communication made through both visual and audible means, 

such as a television advertisement, the disclosure must be presented simultaneously 

in both the visual and audible portions of the communication even if the representation 

requiring the disclosure is made in only one means. 

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CASE NO. 2:20-CV-6692-JFW (PDx) 

2. A visual disclosure, by its size, contrast, location, the length of 

time it appears, and other characteristics, must stand out from any accompanying text 

or other visual elements so that it is easily noticed, read, and understood. 

3. An audible disclosure, including by telephone or streaming video, 

must be delivered in a volume, speed, and cadence sufficient for ordinary consumers 

to easily hear and understand it. 

4. In any communication using an interactive electronic medium, 

such as the Internet or software, the disclosure must be unavoidable.

5. The disclosure must use diction and syntax understandable to 

ordinary consumers and must appear in each language in which the representation that 

requires the disclosure appears. 

6. The disclosure must comply with these requirements in each 

medium through which it is received, including all electronic devices and face-to-face 

communications. 

7. The disclosure must not be contradicted or mitigated by, or 

inconsistent with, anything else in the communication. 

B. “Covered Information” means individually identifiable information 

from or about an individual consumer, including: (1) first and last name; (2) a physical 

address; (3) an email address or other online contact information, such as an instant 

messaging user identifier or a screen name; (4) a telephone number; (5) a persistent 

identifier, such as a customer number held in a “cookie,” a static Internet Protocol 

(“IP”) address, a mobile device ID, or processor serial number; (6) date of birth; (7) 

real property information; (8) corporate affiliations and professional licenses; (9) 

photos and videos; (10) work history; (11) sex offender status; (12) arrest records; (13) 

bankruptcy records; (14) liens; (15) eviction records; (16) civil and criminal court 

record information; (17) traffic tickets or citations; and (18) any information combined 

with any of (1) through (17) above. 

C. “Consumer Report” means any written, oral, or other communication 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

of any information by a Consumer Reporting Agency bearing on a consumer’s credit 

worthiness, credit standing, credit capacity, character, general reputation, personal 

characteristics, or mode of living which is used or expected to be used or collected in 

whole or in part for a Permissible Purpose. 

D. “Consumer Reporting Agency” means any Person which, for monetary 

fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part 

in the practice of assembling or evaluating consumer credit information or other 

information on consumers for the purpose of furnishing Consumer Reports to third 

parties, and which uses any means or facility of interstate commerce for the purpose 

of preparing or furnishing Consumer Reports. 

E. “Covered Business” means: (1) Corporate Defendant; (2) any business 

that Corporate Defendant, individually or collectively with Individual Defendant, is a 

majority owner or controls, directly or indirectly; and (3) any business that Individual 

Defendant, individually or collectively with Corporate Defendant, is a majority owner 

or controls directly or indirectly. 

F. “Covered Record” means any written or oral communication that 

includes any of the following information from or about an individual consumer: (1) 

sex offender status; (2) arrest records; (3) bankruptcy records; (4) liens; (5) eviction 

records; (6) civil and criminal court record information; and (7) traffic tickets or 

citations. 

G. “Defendants” means the Individual Defendant and the Corporate 

Defendant, individually, collectively, or in any combination. 

1. “Corporate Defendant” means MyLife.com, Inc., and its 

successors and assigns. 

2. “Individual Defendant” means Jeffrey Tinsley. 

H. “Negative Option Feature” means, in an offer or agreement to sell or 

provide any product or service, a provision under which the consumer’s silence or 

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

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

acceptance of the offer. 

I. “Person” means any individual, partnership, corporation, trust, estate, 

cooperative, association, government or governmental subdivision or agency, or other 

entity. 

J. “Permissible Purpose” means: 

1. In response to the order of a court having jurisdiction to issue such 

an order, or a subpoena issued in connection with proceedings before a Federal grand 

jury; or 

2. In accordance with the written instructions of the consumer to 

whom it relates; or 

3. To a person which the Consumer Reporting Agency has reason to 

believe: 

a. intends to use the information in connection with 

a credit transaction involving the consumer on whom the information is to be 

furnished and involving the extension of credit to, or review or collection of 

an account of, the consumer; or 

b. intends to use the information for employment purposes; or 

c. intends to use the information in connection with the 

underwriting of insurance involving the consumer; or 

d. intends to use the information in connection with a 

determination of the consumer’s eligibility for a license or other benefit granted by a 

governmental instrumentality required by law to consider an applicant’s financial 

responsibility or status; or 

e. intends to use the information, as a potential investor or 

servicer, or current insurer, in connection with a valuation of, or an assessment of the 

credit or prepayment risks associated with, an existing credit obligation; or 

f. otherwise has a legitimate business need for the 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

information: 

i. in connection with a business transaction that is 

initiated by the consumer; or 

ii. to review an account to determine whether the 

consumer continues to meet the terms of the account; or 

g. executive departments and agencies in connection with the 

issuance of government-sponsored individually-billed travel charge cards; or 

4. In response to a request by the head of a State or local child support 

enforcement agency (or a State or local government official authorized by the head of 

such an agency), if the person making the request certifies to the Consumer Reporting 

Agency that: 

a. the Consumer Report is needed for the purpose of 

establishing an individual’s capacity to make child support payments, determining the 

appropriate level of such payments, or enforcing a child support order, award, 

agreement, or judgment; 

b. the parentage of the consumer for the child to which the 

obligation relates has been established or acknowledged by the consumer in 

accordance with State laws under which the obligation arises (if required by those 

laws); and 

c. the Consumer Report will be kept confidential, will be used 

solely for a purpose described in Definition J.4.a, and will not be used in connection 

with any other civil, administrative, or criminal proceeding, or for any other purpose; 

or 

5. To an agency administering a State plan under Section 454 of the 

Social Security Act (42 U.S.C. § 654) for use to set an initial or modified child support 

award; or 

6. To the Federal Deposit Insurance Corporation or the National 

Credit Union Administration as part of its preparation for its appointment or as part of 

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CASE NO. 2:20-CV-6692-JFW (PDx) 

its exercise of powers, as conservator, receiver, or liquidating agent for an insured 

depository institution or insured credit union under the Federal Deposit Insurance Act 

or the Federal Credit Union Act, or other applicable Federal or State law, or in 

connection with the resolution or liquidation of a failed or failing insured depository 

institution or insured credit union, as applicable. 

ORDER 

I. PROHIBITED BUSINESS ACTIVITIES 

 (FAIR CREDIT REPORTING ACT) 

IT IS ORDERED that Defendants, their officers, agents, employees, and 

attorneys, and all other Persons in active concert or participation with any of them, 

who receive actual notice of this Order, whether acting directly or indirectly, in 

connection with operating as a Consumer Reporting Agency, are hereby permanently 

restrained and enjoined from: 

A. Failing to maintain reasonable procedures designed to limit the

furnishing of Consumer Reports to Persons with Permissible Purposes to receive 

them. Such reasonable procedures shall require that: (1) prospective users of the 

information identify themselves, certify the purposes for which the information is 

sought, and certify that the information will be used for no other purpose; and that (2) 

Defendants make a reasonable effort to verify the identity of a new prospective user 

and the uses certified by such prospective user prior to furnishing such user a 

Consumer Report; 

B. Failing to maintain reasonable procedures to assure the maximum

possible accuracy of the information concerning the individual about whom the report 

relates; 

C. Failing to provide a notice to users (Attached hereto as Attachment A to 

this Order) of such Person’s responsibilities under the FCRA; and 

D. Furnishing a Consumer Report to any Person whom Defendants do not 

have reason to believe has a Permissible Purpose to receive the Consumer Report. 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

II. FAIR CREDIT REPORTING ACT MONITORING PROGRAM 

IT IS FURTHER ORDERED that each Covered Business must not advertise, 

market, promote, or offer for sale any Covered Information unless it first establishes 

and implements, and thereafter maintains, a comprehensive monitoring program to 

regularly review, assess, and determine the applicability of the FCRA to the business 

practices of the Covered Business, and if the FCRA applies to those business practices, 

to regularly review, assess, and determine whether they comply with the requirements 

of the FCRA as required by the statute and Section I of this Order (hereinafter, the 

“Monitoring Program”). To satisfy this requirement, each Covered Business must, at 

a minimum: 

A. Document in writing the content, implementation, and maintenance of 

the Monitoring Program; 

B. Designate a qualified employee or employees to coordinate and be 

responsible for the Monitoring Program; 

C. Assess and document, prior to the inception of the Monitoring Program 

and at least once every twelve (12) months thereafter, whether the Covered 

Information promoted or offered for sale by the Covered Business is a Consumer 

Report, and whether the Covered Business is acting as a Consumer Reporting Agency. 

Such assessment shall include, at a minimum, a review of: 

1. All products and services offered or sold; 

2. Marketing and advertising materials used to offer or sell those

products and services (including but not limited to any advertisements, blog posts, 

testimonials, published statements, customer service scripts, and any method or device 

used to direct Persons to a website); 

3. Any measures to prevent users from using a Covered Business’ 

products or services for purposes governed by the FCRA (e.g., disclaimers, 

certifications, account terminations, blocking); and 

4. Any information about how users of those products or services use, 

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CASE NO. 2:20-CV-6692-JFW (PDx) 

intend to use, or expect to use those products or services (including but not limited to 

consumer correspondence, consumer complaints, and consumer testimonials); 

D. Design, implement, maintain, and document safeguards to assure FCRA 

compliance. Such safeguards must include, at a minimum: 

1. Training of all officers, employees, agents, and independent 

contractors, at onboarding and at least every twelve (12) months thereafter, on the 

FCRA’s legal requirements and activities that would violate those requirements; 

2. Refraining from advertising, marketing, promoting, describing, or 

offering for sale any product or service that involves Covered Information as suitable 

or appropriate for any Permissible Purpose, unless the requirements of the FCRA and 

this Order that would apply to a Consumer Report are satisfied as to that product or 

service; 

3. Prepublication review of all marketing and advertising materials 

used to offer or sell those products and services (including but not limited to any 

advertisements, blog posts, testimonials, published statements, customer service 

scripts, and any method or device used to direct Persons to a website); 

4. Clearly and Conspicuously disclosing permissible and 

impermissible uses of any Covered Information under the FCRA and this Order prior 

to providing or disclosing such information; 

5. Procedures to onboard users, including requiring users to agree to 

contracts or terms and conditions governing FCRA compliance and Clear and 

Conspicuous disclosure of such terms and conditions; 

6. User access controls, such as controls on the number of Covered

Records obtained per day; and 

7. Ongoing reviews, tests, or audits of the ways that users use or

expect to use that Covered Business’ products or services; 

E. Evaluate and adjust the Monitoring Program in light of any changes to 

the business’ operations or business arrangements, or any other circumstance that the 

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CASE NO. 2:20-CV-6692-JFW (PDx) 

business knows or has reason to know may materially affect the Monitoring Program’s 

effectiveness. At a minimum, each Covered Business must evaluate the Monitoring 

Program every twelve (12) months and implement modifications based on the results; 

and 

F. At least once every twelve (12) months, provide (1) the written program 

required by Subsection II.A and any evaluations thereof or updates thereto, and (2) the 

assessments and documentation required by Subsection II.C to the Covered Business’s 

board of directors or governing body or, if no such board or equivalent governing body 

exists, to a senior officer responsible for regulatory compliance. 

III. PROHIBITION AGAINST MISREPRESENTATIONS TO 

CONSUMERS 

IT IS FURTHER ORDERED that Defendants, their officers, agents, 

employees, and attorneys, and all other Persons in active concert or participation with 

any of them, who receive actual notice of this Order, whether acting directly or 

indirectly, in connection with advertising, marketing, promoting, or offering any 

product or service, are permanently restrained and enjoined from misrepresenting, 

expressly or by implication: 

A. What a user can do or achieve with the service; 

B. Payment, renewal, cancellation, or refund terms relating to the product 

or service; 

C. Policies or practices regarding payments, renewals, cancellation, or 

refunds; 

D. The extent to which, or the probability that any consumer may have 

Covered Records; and 

E. Any other fact that is material to users concerning Covered Records or 

any of the information therein, such as any material aspect of their accuracy, nature, 

or characteristics; or any material restrictions, limitations, or conditions on users’ 

ability to access, alter, use, correct, or delete them. 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

IV. PROHIBITION AGAINST UNSUBSTANTIATED 

RESPRESENTATIONS REGARDING COVERED RECORDS 

IT IS FURTHER ORDERED that Defendants, their officers, agents, 

employees, and attorneys, and all other Persons in active concert or participation with 

any of them, who receive actual notice of this Order, whether acting directly or 

indirectly, in connection with advertising, marketing, promoting, or offering any 

product or service, are permanently restrained and enjoined from stating, directly or 

by implication, that: 

A. A consumer may have or does have Covered Records; 

B. Defendants have found Covered Records; or 

C. There are possible or probable Covered Records; 

unless the representation is non-misleading, and, at the time of making such 

representation, Defendants have found a Covered Record about that consumer from a 

third-party source. 

V. PROHIBITION AGAINST STATEMENTS 

REGARDING TRAFFIC TICKETS 

IT IS FURTHER ORDERED that Defendants, their officers, agents, employees, 

and attorneys, and all other Persons in active concert or participation with any of them, 

who receive actual notice of this Order, whether acting directly or indirectly, in 

connection with advertising, marketing, promoting, or offering any product or service, 

are permanently restrained and enjoined from stating, directly or by implication, that 

a traffic ticket or a traffic citation is a criminal or arrest record. Provided, however, 

that this provision does not preclude Defendants from stating that they received 

information from a third-party on a specific date that indicates that court records may 

exist relating to the subject of the search. 

VI. BAN ON NEGATIVE OPTIONS 

IT IS FURTHER ORDERED that Defendants, whether directly or through an 

intermediary, are permanently restrained and enjoined from advertising, marketing, 

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CASE NO. 2:20-CV-6692-JFW (PDx) 

promoting, or offering for sale any product or service with a Negative Option 

Feature. 

VII. MONETARY JUDGMENTS AND PARTIAL SUSPENSIONS 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Twenty-Eight Million Nine Hundred FortyFive, Nine Hundred Sixty-Eight Dollars ($28,945,968) is entered in favor of the 

Plaintiff against Corporate Defendant, as monetary relief. 

B. Judgment in the amount of Five Million Dollars ($5,000,000) is entered 

in favor of the Plaintiff against Individual Defendant, as monetary relief. 

C. Corporate Defendant is ordered to pay to Plaintiff, by making total 

payment to the Treasurer of the United States, Sixteen Million Dollars 

($16,000,000), as follows: 

1. Corporate Defendant must pay Two Million Dollars ($2,000,000) 

to Plaintiff on or before January 15, 2022. 

2. Corporate Defendant must pay two (2) additional discrete 

payments of One Million, One Hundred Sixty-Six Thousand, One Hundred and SixtySix Dollars and sixty-six cents ($1,166,666.66) each, on or before each of the 

following dates: 

a. June 30, 2022; and 

b. September 30, 2022; 

3. Corporate Defendant must pay one One (1) additional discrete 

payment of One Million, One Hundred Sixty-Six Thousand, One Hundred and SixtySix Dollars and sixty-eight cents ($1,166,666.68), on or before December 31, 2022; 

4. Corporate Defendant must pay twelve (12) additional discrete

payments of Eight Hundred and Seventy-Five Thousand Dollars ($875,000) each, on 

or before each of the following dates: 

a. March 31, 2023; 

b. June 30, 2023; 

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c. September 30, 2023; 

d. December 31, 2023; 

e. March 31, 2024; 

f. June 30, 2024; 

g. September 30, 2024; 

h. December 31, 2024; 

i. March 31, 2025; 

j. June 30, 2025; 

k. September 30, 2025; and 

l. December 31, 2025. 

5. All such payments must be made by electric fund transfer in 

accordance with instructions provided by a representative of the Plaintiff. Written 

confirmation of each wire transfer shall be delivered via email to Zachary A. Dietert, 

Trial Attorney, Consumer Protection Branch, U.S. Department of Justice, 450 5th 

Street, N.W. Suite 6400-South, Washington, DC 20530, Zachary.A.Dietert 

@usdoj.gov. The wire transfer transmittal shall include the title of this litigation and 

a reference to DJ #102-4025. 

6. Upon such total payments, the remainder of the Corporate 

Defendant’s judgment is suspended, subject to Subsection VII.J below.

7. Corporate Defendant may prepay at any time, and without penalty, 

the remaining balance, or any part thereof, of the Sixteen Million Dollars 

($16,000,000) owed under this Order. Any such prepayment made prior to an 

installment due date shall be credited as if made on the next installment due date, and 

Corporate Defendant shall be relieved of making any further payments on the 

installment due date for any prepayments to the extent of such prepayment. Nothing 

herein shall be construed to relieve Corporate Defendant of its obligation to make 

timely payment for any installments as they become due, which have not otherwise 

fully been paid in advance.

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8. Until such time that the total amount of Sixteen Million Dollars 

($16,000,000) is paid in full, Corporate Defendant is prohibited from paying any 

dividends to any shareholders and is prohibited from increasing the salary or paying 

bonuses or other form of financial compensation to any of Corporate Defendant’s 

employees who were paid or to be paid an annual salary of $100,000.00 or more for 

the years 2016 to the present, other than through annual Cost-of-Living Adjustments 

at the rate approved by the Social Security Administration. 

D. Individual Defendant is ordered to pay to Plaintiff, by making total 

payment to the Treasurer of the United States, Five Million Dollars ($5,000,000), as 

follows: 

1. Individual Defendant shall pay Three Hundred Thousand Dollars 

($300,000) to Plaintiff no later than December 15, 2021. 

2. Individual Defendant shall pay sixteen (16) additional discrete

payments of Two Hundred Ninety-Three Thousand, Seven Hundred and Fifty Dollars 

($293,750) each, on or before each of the following dates: 

a. March 31, 2022; 

b. June 30, 2022; 

c. September 30, 2022; 

d. December 31, 2022; 

e. March 31, 2023; 

f. June 30, 2023; 

g. September 30, 2023; 

h. December 31, 2023; 

i. March 31, 2024; 

j. June 30, 2024; 

k. September 30, 2024; 

l. December 31, 2024; 

m. March 31, 2025; 

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n. June 30, 2025; 

o. September 30, 2025; and 

p. December 31, 2025. 

3. All such payments must be made by electric fund transfer in 

accordance with instructions provided by a representative of the Plaintiff. Written 

confirmation of each wire transfer shall be delivered via email to Zachary A. Dietert, 

Trial Attorney, Consumer Protection Branch, U.S. Department of Justice, 450 5th 

Street, N.W. Suite 6400-South, Washington, DC 20530, Zachary.A.Dietert 

@usdoj.gov. The wire transfer transmittal shall include the title of this litigation and 

a reference to DJ #102-4025. 

4. To secure the payment obligation under Subsection VII.D.2, 

above, Individual Defendant grants the Plaintiff a security interest in certain property 

located at 85 Crestview Ave, Camarillo, CA 93010, and proceeds thereof (hereinafter, 

the “Collateral”), as set forth in the Deed of Trust attached hereto as Attachment B 

(hereinafter, “Deed”). Individual Defendant shall do all things necessary to 

implement and comply with its obligations in this Order. Individual Defendant 

represents and acknowledges that the Plaintiff is relying on the material 

representations that Individual Defendant is the sole owner in fee simple of the 

Collateral, that title to the Collateral is marketable, and that the Collateral currently is 

not encumbered by any other lien, mortgage, deed of trust, assignment, pledge, 

security interest, or other interest except as previously disclosed to the Commission. 

Individual Defendant represents that none of the encumbrances on the Collateral is in 

default. 

5. Individual Defendant further agrees that, as of the date on which 

they sign this Order, they shall refrain from transferring, converting, encumbering 

(including encumbering by failing to pay any taxes or assessments), selling, assigning, 

or otherwise disposing of the Collateral, except with the express prior written 

permission of counsel for the Plaintiff and for the purpose of satisfying Individual 

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Defendant’s obligation in Subsections VII.D.1-2, above, and the proceeds of any such 

transaction shall be paid at settlement to the Plaintiff, provided, however, that this 

limitation shall end with the completion of all payments listed in Subsections VII.D.1-

2, above. 

6. Individual Defendant hereby releases and waives any statutory, 

common law, or other homestead exemption that may apply to the Collateral for 

purposes of the security interest granted to the Plaintiff, provided, however, that this 

release and waiver shall end with the completion of all payments listed in Subsections 

VII.D.1-2, above. 

7. Individual Defendant shall cooperate fully with the Plaintiff and 

be responsible for preparing, executing, and recording the necessary documents and 

doing whatever else is reasonably necessary or desirable to perfect, evidence, and 

effectuate the Plaintiff’s liens, security interests, and other protections granted herein. 

Individual Defendant shall submit to the clerk’s office for recording all security 

documents used to perfect the Plaintiff’s lien on the Collateral within fourteen (14) 

days after entry of this Order, and shall deliver to the Plaintiff copies of such officially 

recorded documents and a statement showing the outstanding balance owed on any 

preexisting security deeds as of the date of entry of this Order within seven (7) days 

after receipt of such documents. 

8. Individual Defendant may prepay at any time, and without penalty, 

the remaining balance, or any part thereof, of the $5 million ($5,000,000.00) owed 

under this Order. Any such prepayment made prior to an installment due date shall 

be credited as if made on the next installment due date, and Individual Defendant shall 

be relieved of making any further payments on the installment due date for any 

prepayments to the extent of such prepayment. Nothing herein shall be construed to 

relieve Individual Defendant of its obligation to make timely payment for any 

installments as they become due, which have not otherwise fully been paid in advance. 

9. Until such time that the total amount of Sixteen Million Dollars 

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($16,000,000) is paid by Corporate Defendant in full, Individual Defendant is 

prohibited from receiving any dividends from Corporate Defendant. 

E. In the event that Individual Defendant fails to make the required 

payments when due under Subsections VII.D.1-2 of this Order, or the Plaintiff is not 

allowed to retain any such payment, or if Individual Defendant fails to comply with 

any part of Section VII.D of this Order and such failure is not timely cured within 

five (5) business days: 

1. The entire judgment amount in Subsection VII.B, less any amount

previously paid, shall immediately become due and payable by Individual Defendant. 

Interest computed at the rate prescribed under 28 U.S.C. § 1961, as amended, shall 

immediately begin to accrue on the unpaid balance. Time is of the essence for the 

payments specified in this Section; and 

2. The Individual Defendant consents to the appointment of a 

receiver by the Court for purpose of taking possession and control of and liquidating 

the Collateral, with the rights and powers, and privileges of an equity receiver. The 

costs and expenses of the receivership, including reasonable compensation for the 

receiver and personnel retained by the receiver, shall be paid solely from the proceeds 

of the Collateral. The Plaintiff and Individual Defendant waive the requirements of 

28 U.S.C. § 2001 and 28 U.S.C. § 2004 in connection with any pending or 

contemplated sale by the receiver. 

F. Upon full payment of their obligations under Subsection VII.D.2 of this 

Order and a subsequent written request by Individual Defendant, the Plaintiff agrees 

to reconvey or release the Deed within a reasonable time. Individual Defendant shall 

prepare and provide to the Plaintiff any documents required to reconvey or release 

the Deed, and shall be responsible for recording the necessary documents and doing 

whatever else is reasonably necessary or desirable to perfect, evidence, and 

effectuate the Plaintiff’s reconveyance or release, and shall pay all of the fees and 

costs related to such reconveyance or release, including filing fees. In addition, the 

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Plaintiff shall promptly cancel the Deed to the extent necessary to facilitate the sale 

or encumbrance of the Collateral if the funds owed to the Plaintiff pursuant to 

Subsections VII.D.1-2 of this Order are remitted directly to the Plaintiff from the 

proceeds of such sale or encumbrance immediately upon closing of such sale or 

encumbrance. 

G. If, upon motion of the Plaintiff, a Court determines that Individual 

Defendant made a material misrepresentation or omitted material information 

concerning ownership or authority to pledge the Collateral, any encumbrance of the 

Collateral, or the value of the Collateral, the entire Judgment amount in Subsection 

VII.B, above (which the Individual Defendant stipulates only for purposes of this 

Section represents the consumer injury alleged in the Complaint), less any amounts 

previously paid by Individual Defendant, shall immediately become due and payable 

by him. Interest computed at the rate prescribed under 28 U.S.C. § 1961, as 

amended, shall immediately begin to accrue on the unpaid balance. 

Provided that proceedings instituted under this provision would be in addition 

to, and not in lieu of, any other remedies, as may be provided by law, including but 

not limited to, contempt proceedings or any other proceedings that the Commission 

may initiate to enforce this Order. 

H. The Commission’s and Plaintiff’s agreement to this Order is expressly 

based on the material representations that Individual Defendant has the right and 

authority to enter into the Deed, and that such Collateral is not encumbered by any 

lien, assignment, security interest, or other interest not otherwise disclosed in the 

Deed or Financial Disclosures previously made to the Commission. 

I. The Commission’s and Plaintiff’s agreement to the installment plans 

described above in Subsections VII.C and VII.D and the suspension of part of 

Corporate Defendant’s judgment is expressly premised upon the truthfulness, 

accuracy, and completeness of Defendants’ sworn financial statements and related 

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documents (collectively, “financial representations” ) submitted to the Commission, 

namely: 

1. The Financial Statement of Corporate Defendant signed on 

October 24, 2019, including the attachments; 

2. The additional information and documentation submitted by 

secure file transfer protocol from Corporate Defendants’ counsel at DLA Piper to 

Commission counsel dated October 31, 2019 and November 14, 2019, attaching 

additional financial records and supplements to Corporate Defendant’s Financial 

Statement listed above; 

3. The Financial Statement of Individual Defendant signed on 

January 17, 2020, including the attachments; 

4. The additional information and documentation submitted by 

e-mail and secure file transfer protocol from Individual Defendants’ counsel, Joseph 

Jay, to Commission counsel dated January 24, 2020, attaching supplements to 

Individual Defendant’s Financial Statement listed above; 

5. The Revised Financial Statement of Individual Defendant signed 

on January 25, 2020, including the attachments; 

6. The additional information, documentation, and financial records 

listed in Defendants’ counsels’ letter to Andrea V. Arias, Jamie E. Hine, and Brian C. 

Berggren of the Division of Privacy and Identity Protection, Bureau of Consumer 

Protection, Federal Trade Commission, dated May 17, 2020, including the 

attachments thereto; 

7. Corporate Defendant’s sworn testimony during the Fed. R. Civ. P. 

30(b)(6) deposition of Corporate Defendant in this case, the documents that Corporate 

Defendant produced to Plaintiff on the date of that deposition, Individual Defendant’s 

sworn testimony during his deposition in this case; and 

8. The additional information, documentation, and financial records 

Defendants provided to Plaintiff between October 25, 2021 and November 2, 2021. 

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J. The suspension of the judgment will be lifted as to Corporate Defendant 

if upon motion by the Plaintiff, the Court finds that any Defendant failed to disclose 

any material asset, materially misstated the value of any asset, or made any other 

material misstatement or omission in the deposition testimony, produced documents, 

or sworn statements and related documents identified in the paragraph above. If the 

suspension of the judgment is lifted, the judgment becomes immediately due as to that 

Defendant in the amount specified in Subsection VII.A above, which the parties 

stipulate, for the purposes of this Section only, represents the consumer injury 

determined by the Court in the Order at ECF No. 179, less any payment previously 

made pursuant to this Section, plus interest computed from the date of entry of this 

Order.

VIII. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that:

A. Defendants relinquish 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 shall 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 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. Defendants acknowledge that their Taxpayer Identification Number 

(Social Security Numbers or Employer Identification Number), which Defendants 

must submit to the Plaintiff, may be used for collecting and reporting on any 

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

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

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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, including consumer 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 

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

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

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

is to be deposited to the U.S. Treasury as disgorgement. Defendants have no right to 

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

Section. 

F. Defendants, Defendants’ officers, agents, employees, and attorneys, and 

all other persons in active concert or participation with any of them, who receive actual 

notice of this Order, whether acting directly or indirectly, are permanently restrained 

and enjoined from directly or indirectly failing to provide sufficient customer 

information to enable the Commission to efficiently administer consumer redress. 

Defendants represent that they have provided this redress information to the 

Commission. If a representative of the Commission requests in writing any 

information related to redress, Defendants must provide it, in the form prescribed by 

the Commission, within fourteen (14) days. 

IX. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendants, their officers, agents, 

employees, and attorneys, and all other Persons in active concert or participation 

with any of them, who receive actual notice of this Order, whether acting directly or 

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

A. Failing to provide within fourteen (14) days of the entry of the Order, in 

a sortable format such as an Excel spreadsheet or its equivalent, the following 

MyLife customer information for the period from November 1, 2016 to October 31, 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

2021: first and last name, telephone number, email address, mailing address, 

subscription type, subscription duration, total paid, refund/chargebacks (if 

applicable), and a unique customer ID sufficient to identify multiple subscriptions for 

the same customer; and 

B. 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 Covered Records or Covered 

Information. Provided, however, that Defendants may use customer information for 

any current customer if Defendants comply with Sections I through VI of this Order. 

X. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of

receipt of this Order: 

A. Each Defendant, within seven (7) days of entry of this Order, must submit 

to Plaintiff and the Commission an acknowledgment of receipt of this Order sworn 

under penalty of perjury. 

B. For twenty (20) years after entry of this Order, Individual Defendant for 

any business that Individual Defendant, individually or collectively with Corporate 

Defendant, is the majority owner or controls directly or indirectly, and Corporate 

Defendant must deliver a copy of this Order to: (1) all of each such business’s 

principals, officers, directors, and LLC managers and members; (2) all of each such 

business’s 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; (3) any business entity resulting 

from any change in structure as set forth in Section XI titled Compliance Reporting; 

and (4) any third party from whom any Defendant obtains Covered Information. 

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Delivery must occur within seven (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 a Defendant delivered a copy of 

this Order, that Defendant must obtain, within thirty (30) days, a signed and dated 

acknowledgment of receipt of this Order. 

XI. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

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

compliance report, sworn under penalty of perjury: 

1. Each Defendant must: (a) identify the primary physical, postal, 

and email address and telephone number, as designated points of contact that 

representatives of the Commission and Plaintiff may use to communicate with 

Defendant; (b) identify all of that Defendant’s businesses by all of their names, 

telephone numbers, and physical, postal, email, and Internet addresses; (c) describe 

the activities of each business, including but not limited to a description of any 

products or services that involve Covered Information, and the involvement of any 

other Defendant; (d) describe in detail whether and how that Defendant is in 

compliance with each Section of this Order; and (e) provide a copy of each Order 

Acknowledgment obtained pursuant to this Order, unless previously submitted to the 

Commission. 

2. Additionally, Individual Defendant must: (a) identify all of his 

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

residences; (b) identify all businesses in which he has involvement or an interest, 

including any business for which the Individual Defendant performs services whether 

as an employee or otherwise and any entity in which such Defendant has any 

ownership interest; and (c) describe in detail the Individual Defendant’s involvement 

in each such business, including title, role, responsibilities, participation, authority, 

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control, and any ownership. 

B. For twenty (20) years after entry of this Order, each Defendant must 

submit a compliance notice, sworn under penalty of perjury, within fourteen (14) days 

of any change in the following: 

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

point of contact; or (b) the structure of any Corporate Defendant or any entity that 

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

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

sale, or dissolution of the entity or any subsidiary, parent, or affiliate that engages in 

any acts or practices subject to this Order. 

2. Additionally, Individual Defendant must report any change in: (a) 

name, including aliases or fictitious name, or residence address; or (b) title or role in 

any business activity, including any business for which Individual Defendant performs 

services whether as an employee or otherwise and any entity in which Individual 

Defendant has any ownership interest, and identify the name, physical address, and 

any Internet address of the business or entity. 

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

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

such Defendant within fourteen (14) days of its filing. 

D. One year after entry of this Order, and each year thereafter for a period 

of twenty (20) years from entry of this Order, each Defendant must submit to the 

Commission all documentation required under Subsection II.C of this Order. 

E. 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. 

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

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

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: “United States v. MyLife.com, Inc. and Jeffrey Tinsley.” 

XII. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 

twenty (20) years after entry of the Order, and retain each such record for five (5) 

years. Specifically, Defendants must create and retain the following records: 

A. Accounting records showing the revenues generated from all products or 

services sold, and the disbursement of such revenues; 

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. Customer files containing the names, addresses, telephone numbers, 

dollar amounts paid, quantity of products or services purchased, and description of 

products or services purchased, to the extent such information is obtained in the 

ordinary course of business; 

D. Records of all complaints and refund requests concerning the subject 

matter of the Order, whether received directly or indirectly, such as through a third 

party, and any response to those complaints or requests; 

E. All sales or customer service scripts, form letters or emails, 

advertisements, or other marketing materials; 

F. All employee manuals and training materials concerning the subject 

matter of the Order; 

G. All records necessary to demonstrate full compliance with each Section 

of this Order. 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

XIII. ANNUAL CERTIFICATIONS 

IT IS FURTHER ORDERED that: 

A. One year after the issuance date of this Order, and each year thereafter, 

for any Covered Business that Individual Defendant is a majority owner or controls, 

directly or indirectly, Individual Defendant must provide the Commission with a 

certification that: (1) the Covered Business has established, implemented, and 

maintained the requirements of this Order; and (2) Individual Defendant is not aware 

of any material noncompliance that has not been (a) corrected or (b) disclosed to the 

Commission. The certification must be based on the personal knowledge of the 

Individual Defendant, or subject-matter experts upon whom the Individual Defendant 

relies in making the representation. 

B. One year after issuance date of this Order, and each year thereafter, 

Corporate Defendant must provide the Commission with a certification from a senior 

officer or manager that: (1) Corporate Defendant has established, implemented, and 

maintained the requirements of this Order; and (2) Corporate Defendant is not aware 

of any material noncompliance that has not been (a) corrected or (b) disclosed to the 

Commission. The certification must be based on the personal knowledge of the senior 

officer or manager, or subject-matter experts upon whom the senior corporate manager 

or senior officer reasonably relies in making the certification. 

C. Unless otherwise directed by a Commission representative in writing, 

submit all annual certifications to the Commission pursuant to this Order via email to 

DEBrief@ftc.gov or by overnight courier (not the U.S. Postal Service) to Associate 

Director of Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 

600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin: 

“United States v. MyLife.com, Inc. and Jeffrey Tinsley.” 

XIV. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’ 

compliance with this Order: 

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STIPULATED ORDER FOR PERMANENT INJUNCTION AND EQUITABLE MONETARY RELIEF 

CASE NO. 2:20-CV-6692-JFW (PDx) 

A. Within fourteen (14) days of receipt of a written request from a 

representative of the Commission or Plaintiff, each Defendant 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 and Plaintiff are 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 remote video or telephonic 

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

B. For matters concerning this Order, the Commission and Plaintiff are 

authorized to communicate directly with each Defendant. Defendant must permit 

representatives of the Commission and Plaintiff to interview any employee or other 

Person affiliated with any Defendant who has agreed to such an interview. The Person 

interviewed may have counsel present. 

C. The Commission and Plaintiff may use all other lawful means, including 

posing, through its representatives as consumers, suppliers, or other individuals or 

entities, to Defendants or any individual or entity affiliated with Defendants, 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. 

XV. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter 

for purposes of construction, modification, and enforcement of this Order. 

IT IS SO ORDERED this 15th day of December, 2021. 

__________________________________ 

 Hon. John F. Walter 

 UNITED STATES DISTRICT JUDGE 

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