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NADINE S. SAMTER, WA Bar # 

23881

nsamter@ftc.gov

KATHARINE F. BARACH, WA Bar 

# 51766

kbarach@ftc.gov

Federal Trade Commission

915 2nd Ave., Suite 2896, Seattle, WA 

98174

Tel: (206) 220-6350/Samter Cell 

(202) 725-4585

Fax: (206) 220-6366

CARLA L. CHEUNG, CA Bar #

291562 (Local Counsel)

ccheung1@ftc.gov

10990 Wilshire Blvd., Suite 400

Los Angeles, CA 90024

Tel: (310) 824-4300/Cell: (202) 644-

6785

Fax: (310) 824-4318

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION

ROB BONTA

Attorney General of California

NICKLAS A. AKERS

Senior Assistant Attorney General

JUDITH FIORENTINI

Supervising Deputy Attorney General

MICAH C.E. OSGOOD (SBN 

255239)

MICHELLE BURKART (SBN 

234121)

Deputy Attorneys General

California Department of Justice

455 Golden Gate Ave. Suite 11000

San Francisco, CA 94102

(415) 510-44002

mike.osgood@doj.ca.gov

Attorneys for Plaintiff

THE PEOPLE OF THE STATE OF 

CALIFORNIA 

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION, 

and THE PEOPLE OF THE STATE OF 

CALIFORNIA, 

 Plaintiffs, 

 vs.

CRI GENETICS, LLC, a limited 

liability company, also doing business 

as OMNIPGX, 

 Defendant.

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Case No. 2:23-CV-9824

COMPLAINT FOR PERMANENT

INJUNCTION, CIVIL PENALTIES, AND 

OTHER RELIEF

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Plaintiffs, the Federal Trade Commission (“FTC”), and The People of the 

State of California, acting through Rob Bonta, Attorney General (“California”) 

(collectively, “Plaintiffs”), for their Complaint allege:

1. The FTC brings this action under Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), which authorizes the FTC to 

seek, and the Court to order, permanent injunctive relief for Defendant’s acts or 

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

2. Plaintiff California brings this action under California’s Unfair 

Competition Law, Business and Professions Code § 17200 et seq., and California’s 

False Advertising Law, Business and Professions Code §17500 et seq., which 

authorize the Court to order civil penalties, injunctive relief, restitution, and other 

equitable relief. 

SUMMARY OF CASE

3. Defendant CRI Genetics, LLC (“CRI” or “Defendant”), a DNA 

testing company, violated Section 5 of the FTC Act, 15 U.S.C. § 45(a), and 

California’s Unfair Competition Law and False Advertising Law, by 

misrepresenting to consumers that its DNA ancestry testing is more accurate and 

detailed than those of CRI’s competitors and, using a patented software algorithm 

for matching DNA, CRI’s ancestry reports would show consumers exactly where 

their ancestors were from and when they arrived there with over 90 percent 

accuracy going back 50 or more generations. Defendant made these claims on the 

Internet through a variety of deceptive means that violated Section 5 of the FTC 

Act, and California’s Unfair Competition Law and False Advertising Law. These 

claims were widely disseminated on Defendant’s own websites. 

4. Defendant also violated Section 5 of the FTC Act, and California’s 

Unfair Competition Law and False Advertising Law, through the use of numerous 

deceptive marketing tactics designed to manipulate users into purchases. 

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Defendant first lured consumers to its marketing websites using websites 

deceptively formatted to look like independent sites for unbiased reviews and 

ratings of DNA ancestry testing companies. Defendant failed to disclose on the 

websites that it owned them and provided the content in them. Defendant then 

doubled down on the deception by posting phony consumer reviews purportedly 

from “satisfied” customers. Next, Defendant used a false message that test kits 

were in limited supply to pressure consumers to buy products and services 

immediately, claiming without basis that packages were often “out of stock” or 

“backordered,” and “not always available.” Defendant forced consumers to click 

through numerous pop-up pages of offers characterized as “special rewards” that 

purportedly “9.1 out of 10 consumers choose.” Defendant trapped many 

consumers into unwanted purchases by deceptively labeling the pop-up pages as 

steps in the transaction and representing to consumers that their order “was not 

complete” and that they would have the opportunity to review their selected items 

and amounts in a final summary before being charged. Instead, Defendant charged 

consumers immediately and failed to disclose this practice, forcing many 

consumers to go through Defendant’s refund process to recoup the unwanted 

charges. Together these deceptive marketing tactics, many of which can be 

described as “dark patterns,” manipulated consumers, based on false claims 

deceiving them about the product quality and popularity, into making immediate 

purchases.

JURISDICTION AND VENUE

5. This Court has subject matter jurisdiction over the federal claims

pursuant to 28 U.S.C. §§ 1331, 1337(a), and 1345, and supplemental jurisdiction 

over the state law claims pursuant to 28 U.S.C. § 1367. 

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

(c)(2), and (d), and 15 U.S.C. § 53(b). 

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PLAINTIFFS

7. The FTC is an independent agency of the United States Government 

created by the FTC Act, which authorizes the FTC to commence this district court 

civil action by its own attorneys. 15 U.S.C. §§ 41–58. The FTC enforces 

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive 

acts or practices in or affecting commerce. 

8. The People of the State of California bring this action by and through 

Attorney General Rob Bonta, who is authorized by California Business and 

Professions Code §§ 17535 and 17536 to enforce the California False Advertising 

Law, California Business and Professions Code § 17500 et seq., and authorized by 

California Business and Professions Code §§ 17204 and 17206 to enforce the 

California Unfair Competition Law, California Business and Professions Code § 

17200 et seq. 

DEFENDANT

9. Defendant CRI Genetics, LLC, also doing business as OmniPGX, is a 

California limited liability corporation with its principal place of business at 122 

Sheldon Street, El Segundo, California 90245. CRI transacts or has transacted 

business in this District and throughout the United States. At times relevant to this 

Complaint, acting alone or in concert with others, Defendant has advertised, 

marketed, distributed, or sold DNA test kits and ancestry and health and wellness 

reports to consumers throughout the United States.

COMMERCE

10. At all times relevant to this Complaint, Defendant has 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.

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DEFENDANT’S COURSE OF CONDUCT

Defendant’s DNA Testing Products and Services

11. Defendant has advertised, marketed, promoted, offered for sale, and 

sold DNA saliva swab test kits since at least 2017. Defendant has also advertised, 

marketed, promoted, offered for sale, and sold DNA reports generated from the 

results of the saliva swab kits processed by a third-party laboratory. The reports 

purportedly provide consumers with information about their genetic ancestry,

potential health and wellness traits and conditions, and paternity. Defendant sells 

its DNA test kits and ancestry and other reports directly to consumers through its

website, www.crigenetics.com (the “CRI Website”). 

12. Defendant’s basic package includes three distinct reports that purport 

to show consumers’ geographical and ethnic ancestry: the Recent Ancestry Report, 

the Advanced Ancestry Report, and the Advanced Ancestry Timeline. The Recent 

Ancestry Report is an analysis of consumers’ DNA that purports to show 

consumers their ethnic and geographic ancestry from the last five generations of 

their family. 

13. Defendant’s Advanced Ancestry Report is an analysis of consumers’ 

DNA that purports to show consumers their ancestry dating back thousands of 

years, reflecting consumers’ “oldest” ancestries in their family histories. 

14. Defendant’s Advanced Ancestry Timeline is an analysis of 

consumers’ full DNA sequence that purports to show consumers when certain ethic 

or regional features entered their DNA, dating back more than 50 generations. 

15. Defendant also offers and sells a more expensive package that 

includes the basic package with additional DNA-based health and wellness reports. 

The DNA health and wellness reports purport to identify statistically significant 

associations between consumers’ genetic markers and certain medical conditions 

and traits, such as a propensity to have lactose intolerance or a certain eye or hair 

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color.

16. Defendant also offers and sells consumers additional products and 

services after consumers make initial package selections. These additional offers 

typically include DNA reports providing additional information regarding maternal 

or paternal ancestry lines and celebrity reports that Defendant claims will match 

consumers’ DNA with those of famous people. Defendant also offers customers 

additional DNA test kits for family members and expedited delivery on their 

reports after consumers select their initial packages. 

17. Defendant’s packages range from $99 to $199, depending on the 

number of reports consumers purchase. Some consumers pay over $300 to 

Defendant, depending on the number of products or services that they choose to 

order in addition to the initial package. Defendant’s gross revenues from 2017 to 

2021 are as much as $42.8 million. 

DNA Testing Generally

18. Genetic testing for ancestry involves comparing the genetic variations 

in a person’s DNA sequence to certain genetic mutations in the DNA sequences of 

other people who have submitted their DNA samples for genetic testing and whose 

ancestries are known from genealogical research and confirmed family histories. 

These pools of DNA samples from people with established ancestries are referred 

to as “DNA Reference Datasets.” 

19. Genetic testing is also used to match genetic patterns of people with 

certain known health conditions or traits. For example, a known genetic mutation 

may be associated or correlated with certain traits, such as having blue eyes or red 

hair, or may be associated with certain health conditions such as lactose intolerance 

or the tendency towards insulin resistance. Although genetic testing can identify

these mutations in the genome, people who have the mutations do not necessarily 

have the associated trait or condition associated with the mutation because genetic 

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mutations are not always expressed. 

20. Most genetic testing companies use similar standardized tests for 

processing consumers’ biological samples. The results of these tests do not 

significantly vary based on who performs the tests if they are processed in an 

accredited lab. As a result, each genetic testing company will likely identify the 

same genetic variations and mutations in a person’s DNA with a high level of 

accuracy. The results of the DNA tests showing genetic mutations are commonly 

referred to as “DNA Raw Data Profiles.” Although many DNA testing companies 

permit consumers to download and keep their DNA Raw Data Profiles, Defendant 

does not. 

21. After the test kits are processed and the DNA Raw Data Profiles are 

compiled, DNA testing companies prepare reports that estimate consumers’ 

ancestries or traits by comparing certain segments of those consumers’ DNA from 

the DNA Raw Data Profiles to the companies’ DNA Reference Datasets. Each 

company’s DNA Reference Dataset is comprised of publicly available DNA data 

from people with known ethnicities, as well as DNA data that each company 

compiled from its own customers’ DNA Raw Data Profiles. As a result, each 

company’s DNA Reference Dataset is unique and proprietary to that company. 

22. The size and variation of the known ancestries in each company’s 

DNA Reference Dataset can also vary substantially. The genetic testing companies 

with the largest and most ethnically diverse DNA Reference Datasets are likely to 

produce the most accurate ancestry reports. CRI does not have the largest and 

most ethnically diverse DNA Reference Datasets by a significant margin compared 

to several other DNA testing companies in the market. 

23. Genetic testing companies estimate consumers’ ancestry composition 

by comparing consumers’ DNA Raw Data Profiles with the companies’ 

proprietary DNA Reference Datasets using software algorithms. Each company’s 

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software algorithm is proprietary as well. The algorithms “predict” consumers’ 

ancestry and the companies generate reports to communicate the information to 

consumers, often through various graphics and with varying levels of detail and 

analysis. Each company’s algorithmic estimations of ancestry also have different 

margins of error. 

24. DNA testing for ancestry is at best an estimation of one’s ancestry and 

the achievable accuracy in ancestry predictions is limited. Further, because the 

DNA Reference Datasets and matching algorithms are different for every 

company, consumers who test their DNA with more than one company may find 

significantly different estimations of their ancestry from each of their tests. 

25. DNA ancestry testing also is limited in its usefulness for accurately 

determining a person’s geographical heritage because genes do not correspond 

exclusively to one part of the world. DNA ancestry tests merely look for how 

often variations occur and algorithmically assign geographical areas based on 

statistical probabilities. For example, a genetic variant found in Africa may also be 

found in South America. As a result, DNA ancestry tests cannot provide a precise 

picture of when one’s ancestors lived in a particular geographical area. 

Defendant’s Claims About The Accuracy

 Of Its DNA Testing Products and Services and Algorithm

26. Since 2017, Defendant has advertised, marketed, and promoted its

DNA-based reports through a variety of methods, including through several 

websites (crigenetics.com, geneticsdigest.com, geneticsillustrated.com, 

buyerranking.com, omnipgx.com, and herbalistreport.com); search engine and 

display advertising; consumer testimonials; and social media.

27. From 2017 to April 2021, Defendant’s core product representations 

centered on the accuracy of its ancestry breakdowns reported to consumers from 

their DNA test results. Defendant claimed that its DNA ancestry testing products 

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and services: (1) were the most accurate and detailed DNA ancestry tests and 

reports available on the market; (2) would show consumers’ ancestry breakdown

with an accuracy rate of over 90%; and (3) would show exactly where consumers’ 

ancestors came from and exactly when they arrived there going back more than 50

generations. 

28. From 2017 to April 2021, to induce consumers to purchase its DNA

testing products and services, Defendant disseminated or caused to be disseminated 

advertisements and promotional materials, including, but not necessarily limited to, 

the attached Exhibits A through M, through the means described above. Defendant 

represented that its products were the most accurate and detailed DNA ancestry 

tests and reports available on the market in advertisements that contained the 

following statements and depictions: 

A. From www.crigenetics.com (excerpts attached as Exhibit A (Oct. 14, 

2020) (“Ex. A”), p. A-6; and Exhibit B (Oct. 22, 2020) (“Ex. B”), p. B15):

“CRI is an advanced team of Geneticists, Anthropologists, and Social 

Scientists, who work together to deliver you the most accurate estimation 

of your ancestry possible.” 

B. From www.crigenetics.com, (excerpts attached as Ex. A, p. A-4; Ex. 

B, p. B-32; Exhibit C (Nov. 18, 2020) (“Ex. C”), p. C-6; Exhibit D 

(Dec. 2, 2020) (“Ex. D”), p. D-4): 

“Simply put, the genetic expertise at CRI Genetics is unmatched 

anywhere else in the business. That means that you get fascinating 

Ancestry reports and useful Health reports that are not just detailed, but 

are also extraordinarily accurate. We’re very confident you will love 

every step of the process at CRI Genetics.”

29. Defendant also represented that its products and services would show 

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consumers’ ancestry breakdown with an accuracy rate of over 90% in 

advertisements that contained the following statements and depictions:

A. From www.crigenetics.com, (excerpts attached as Ex. A, p. A-18; Ex. 

B, p. B-13; and Exhibit E (Dec. 9, 2020) (“Ex. E”), p. E-3:

“Genealogical testing is much like predicting the weather: it’s not 

possible to be 100% correct all the time, but we can at least be mostly 

correct most of the time by observing patterns, knowing history, and 

using statistics. In our case, our results are typically 99.9% accurate, 

which is a little better than trying to predict the weather.” 

B. From www.crigenetics.com, (excerpts attached as Ex. A, p. A-10):

“You’ll Never Look At Family Photos The Same Way Again

Knowing your background gives you a deeper connection to all corners 

of the world that are uniquely YOURS. Know exactly where your DNA 

comes from with 90%+ accuracy . . . Get A Detailed, Accurate 

Breakdown of Your Heritage.” [emphasis in original].

C. From www.crigenetics.com, (excerpts attached as Ex. E, p. E-6): 

“The BioGeographical Ancestry estimation we have determined for you 

is extremely accurate. The latest genetic reading equipment, our patented 

DNA analysis software, along with our experience and techniques allow 

us to achieve accuracy greater than 99.9%.”

30. Defendant further represented that its products would show exactly 

where consumers’ ancestors came from and exactly when they arrived there going 

back more than 50 generations in advertisements that contained the following 

statements and depictions:

A. From www.crigenetics.com, (excerpts attached as Ex. A, p. A-8; Ex. 

B, p. B-1; Ex. D, p. D-1; Ex. E, p. E-1):

“Our Advanced Ancestry Timeline takes you back 50+ generations, to 

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find out exactly WHEN and WHERE your ancestors are from.” 

[emphasis in original].

B. From www.crigenetics.com (excerpts attached as Ex. C, p. C-2):

“Timing and Location: By examining 642,824 relevant markers across 

your genome using my patented DNA analysis software, I will be able to 

tell you not only where your ancestors came from, but also exactly 

when they arrived.” [emphasis in original]. 

C. From www.crigenetics.com (current version available for viewing at 

https://www.youtube.com/watch?v=OGLiMoE3xfY) (transcript 

available on request): 

“CRI Genetics matches your unique DNA with 642,824 genetic markers 

to both show you where your ancestors are from and also to pinpoint 

precisely when they got there.” 

31. Defendant’s claim that CRI’s DNA testing products and services are 

more accurate and detailed than those of other companies on the market was 

unsubstantiated at the time it was made because Defendant did not know, nor could 

it have known, the size and composition of those companies’ DNA Reference 

Datasets, or the margin of errors in those companies’ matching algorithms. This 

information is guarded proprietary information for each company. Because 

Defendant did not have access to this information, it could not have had a 

reasonable basis for its claim of superior accuracy. 

32. Defendant also could not establish each consumer’s ancestry with an 

accuracy rate of 90 percent or more because the accuracy of ancestry estimations 

for each consumer can vary considerably with their ancestries. These predictions 

have different probabilities of errors in estimation, again depending on the 

composition and size of the DNA Reference Dataset. Most ancestry estimations 

are not nearly as accurate as 90 percent.

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33. Finally, Defendant’s claim that its DNA ancestry tests can show 

exactly when and where consumers’ ancestors were from dating back 50 or more 

generations was unsubstantiated and false. DNA ancestry tests merely identify

variations in one’s genome and then those variations are algorithmically assigned

geographical areas based on statistical probabilities. Genes do not correspond to 

exclusive geographical locations because human migration patterns over the 

centuries were varied and wide. As a result, DNA ancestry tests alone cannot 

precisely or exactly pinpoint when a particular person’s ancestors lived in a 

particular geographical area. Such accuracy and detail of one’s ancestry can only 

be achieved with in-depth genealogical research into one’s family history. Even 

then there are difficulties estimating exactly where someone’s ancestors are from 

and when they lived there, especially dating as far back as 50 or more generations. 

In addition, CRI did not provide the genealogical tools for consumers to research 

their actual families’ histories or migration patterns or to find relatives and 

discover family relationships.

Defendant’s False Patent Claim

34. From 2017 to April 2021, Defendant also represented that its DNA 

matching algorithm software was patented in advertisements that contained the 

following statement and depiction:

From www.crigenetics.com, (excerpts attached as Ex. A, p. A-4; Ex. B, 

p. B-32; Ex. C, p. C-6; Ex. D, p. D-4):

“We use patented DNA algorithms designed by renowned Molecular 

Geneticist Alexei Fedorov, who was apprentice to Nobel Prize winning 

scientist Walter Gilbert at Harvard University.” 

35. In fact, Defendant never obtained a patent for its matching algorithm 

or software. 

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Failure To Disclose Defendant’s Material

Connection To Marketing Websites

36. From 2017 to February 2021, Defendant purchased search 

advertisements from Google and Bing that displayed textual links to websites that 

Defendant owned and operated, including but not limited to, the websites 

geneticsdigest.com and buyerranking.com. Consumers who entered search terms 

in Google and Bing such as “DNA testing,” “genetic testing,” “Ancestry DNA,” or 

“23andMe,” were shown, on the first page of the search results, Defendant’s search 

ads, which claimed consumers would find ratings for the top choices for DNA 

ancestry testing companies on Defendant’s websites. 

The Genetics Digest Website

37. From 2017 until February 2021, consumers who clicked on the search 

advertisements that linked to geneticsdigest.com were taken to a website depicting 

a heading in large bold font titled “Genetics Digest,” which claimed to be the name 

of the organization that owned the website. 

38. The Genetics Digest website represented that it was an independent 

and unbiased source of information for DNA testing and did not disclose that 

Defendant’s principal owned the website and produced its content and, therefore, 

Defendant had a material connection to the website. For example, the “About” 

section of the website claimed that the website offered objective information with 

phrases implying it was intended to help consumers decide which products “really 

are the best” and “really are high quality:” 

From the landing page of geneticsdigest.com (excerpts attached as 

Exhibit F (Dec. 17, 2020) (“Ex. F”), pp. F-8, 17, and 19; Exhibit G (Nov. 4, 

2020) (“Ex. G”), p. G-9; Exhibit H (Feb. 23, 2021) (“Ex. H”), p. H-11): 

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39. The introductory “Welcome” section of the Genetics Digest website

stated that Genetics Digest’s aim was “to provide credible, accurate information” 

and “unbiased product reviews for consumers looking to purchase anything related 

to the field of genetics,” as shown in the following statement and depiction:

From the “About” page of geneticsdigest.com (excerpts at Exhibit 

Ex. G, p. G-1): 

40. The “Terms and Conditions” page of the Genetics Digest website also 

stated that Genetics Digest was “an interactive online service . . . owned and 

operated by GeneticsDigest.com” that consists of “independent reviews and 

judgments based on our judgement [sic] of work of third party experts across 

multiple categories,” as shown in the following statement and depiction:

From the “Terms and Conditions” page of geneticsdisgest.com (excerpts 

at Ex. G, p. G-3): 

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41. Sometime on or around February 2021, Defendant inserted in the 

Genetics Digest website the statement that “Genetics Digest has a financial 

connection to the products sold via links on our website such as our top choice: 

CRI Genetics.” The statement was placed at the top of the landing page of the 

website, in very small print in light gray color, just above the title “GENETICS 

DIGEST,” depicted as follows: 

From geneticsdigest.com (excerpts at Ex. H, p. H-1): 

42. Sometime on or around March 2021, Defendant replaced the prior 

statement with the statement, “Genetics Digest aims to provide you with helpful 

information about DNA analysis and Genome Testing advancements. We are 

affiliated with CRI Genetics.” This statement was similarly placed at the top of the 

Genetics Digest landing page, with a much smaller font size to the title “Genetic 

Digest” and in a very light gray color, depicted as follows:

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From geneticsdigest.com (excerpts attached at Exhibit I (June 9, 2021) 

(“Ex. I”), p. I-1): 

 

43. Placing the statements above the title in much smaller size font and 

much lighter color than the prominent title of the website made them likely to be 

overlooked by consumers. Further, these statements did not disclose or adequately 

disclose the true nature of Defendant’s material connection to the Genetics Digest 

website. The disclosures only generally referenced CRI’s “financial connection 

to” or “affiliation with” Genetics Digest, which did not adequately inform 

consumers that, in fact, Defendant effectively owned and operated the Genetics 

Digest website and that the reviews and ratings of the DNA ancestry companies 

were not based on independent and unbiased research. 

The Buyer Ranking Website

44. From at least 2018 until April 2021, consumers who clicked on the 

search advertisements that linked to buyerranking.com were taken to a website 

depicting a heading in large bold font titled “Buyer Ranking,” which claimed to be 

the name of the organization that owned the website. 

45. The Buyer Ranking website represented that it was an independent 

and unbiased source for consumer information and did not disclose that Defendant

owned the website and produced its content and, therefore, had a material 

connection to the website. Defendant made statements on Buyer Ranking claiming 

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that, “at BuyerRanking, we’re consumers too and we want the best deals on the 

highest quality goods at the most reasonable prices as much as anyone else . . . it’s 

hard to tell which deals are really the best and which products really are high 

quality,” and suggesting that the website’s “mission” is to “empower” the 

consumer “as a buyer” with “confidence” to get “the best bang for your buck,” as 

shown in the following statements and depictions:

From buyerranking.com “About” section (excerpts attached at Exhibit 

J (Dec. 30, 2020) (“Ex. J”), p. J-11): 

From buyerranking.com (excerpts at Ex. J, p. J-1): 

46. On or around April 2021, Defendant took down the Buyer Ranking 

website.

Misleading Reviews and Ratings 

47. From 2017 until February 2021, the Genetics Digest website provided 

consumers with information about what to look for when choosing a DNA ancestry 

testing company and mistakes to avoid. It also represented to consumers that the 

Genetics Digest website provided independent and unbiased reviews and ratings of

DNA ancestry testing companies. 

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48. On the Genetics Digest website, the “editors” claimed to have 

conducted unbiased and independent research of many of the DNA testing 

companies on the market, stating that Genetic Digest’s “team of scientists, 

researchers, and writers” have “examined nearly every test in the booming market” 

to help consumers “sort out the great ones from the cheap knockoffs,” as shown in 

the following statement:

From the geneticsdigest.com landing page (excerpts at Ex. F, p. F-2; Ex. 

G, p. G-10; Ex. H, pp. H-2 to H-3):

“Now it’s harder than ever to find a good DNA test . . . Luckily, you’re in 

the right place. Our team of scientists, researchers, and writers at Genetics 

Digest know the field better than most. We’ve examined nearly every DNA 

test in the booming market. We’ll help you sort out the great ones from the 

‘cheap knockoffs’” (emphasis in original).

49. The website then represented that, based on the purportedly 

independent and unbiased research of Genetics Digest’s “team,” CRI’s DNA 

ancestry testing was the top choice over the DNA testing companies, Ancestry 

DNA and 23andMe. 

50. In describing the attributes of Defendant’s DNA ancestry testing that 

led to Genetic Digest’s top choice, the Genetics Digest website repeated the same 

deceptive accuracy claims that appeared on the CRI website, including that CRI’s 

DNA ancestry reports “are generated using a patented DNA analysis algorithm 

created by Alexei Fedorov,” and that the reports have “a deeply detailed Ancestry 

Timeline that shows you where your relatives are from and exactly how and 

when they got there, going back over 50 generations” [emphasis in original], as 

shown in the following statement and depiction:

From geneticsdigest.com (excerpts at Ex. F, p. F-5; Ex. H, p. H-8): 

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51. The Genetics Digest website also represented that CRI had an

“Overall Rating: Excellent” and a star rating of “4.9/5” stars, outranking the star 

ratings for 23andMe and AncestryDNA. The article also claimed that the “cons” 

of CRI’s testing are that the tests are “Frequently Backordered” and that some tests 

are “not always available,” leading consumers to believe that CRI’s tests were in 

high demand and therefore hard to get, which was not the case. These 

representations are shown in the following statements and depictions: 

From geneticsdigest.com (excerpts at Ex. F, p. F-4; see also Ex. G, p. G11; Ex. H, pp. H-7 to H-8): 

52. Defendant did not disclose the source of the star ratings on the website 

but, instead, implied that the star ratings were generated from the independent and 

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unbiased actual product testing and research of the writers of the article. In fact, 

the star ratings were not based on the independent and unbiased actual product 

testing and research of the writers of Genetics Digest. 

53. From 2018 until April 2021, the Buyer Ranking website also claimed 

that it provided consumers with information about what to look for when choosing 

a DNA ancestry testing company. The Buyer Ranking website represented to 

consumers that it provided independent and unbiased reviews and ratings of DNA 

ancestry testing companies. 

54. On the Buyer Ranking website, the editors claimed to help consumers 

who were “lost in the market” to find their way, representing that the review was 

independent and unbiased because Buyer Ranking “sampled DNA tests from 12 

different companies” and “analyzed them to see which ones accomplish the 

benefits listed” on the website, as shown in the following depiction and statements:

From buyerranking.com (excerpts at Ex. J, p. J-3):

From buyerranking.com (excerpts at Ex. J, p. J-5):

55. The Buyer Ranking website further represented that its research 

“team” called the DNA testing companies’ customer services pretending to be 

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confused consumers and presenting various problems and questions to see “how 

responsive, friendly, patient, and helpful they were,” as shown in the following 

depiction and statements:

From buyerranking.com (excerpts at Ex. J, p. J-6):

56. The article then represented that, based on this purportedly 

independent and unbiased research, Defendant’s DNA ancestry testing was the 

“Top Recommended DNA Testing Service” over the DNA testing companies

Family Tree DNA and Living DNA. In describing the attributes of Defendant’s 

DNA ancestry testing that led to the Buyer Rankings top choice, the website 

repeated the same deceptive claims that appear on Defendant’s website, 

representing that Defendant has a “Patented DNA Analysis Technology” and that 

Defendant’s DNA ancestry reports provided consumers with “VERY Detailed 

Genetic Information” and, as shown in the above depiction, Buyer Ranking also 

represented that CRI had a star rating of “4.7/5” stars, with the “cons” again listed 

as products “Frequently Out of Stock” and certain tests “not always available,” as 

shown in the following statement and depiction: 

From buyerranking.com (excerpts at Ex. J, pp. J-6 to J-7): 

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57. Defendant did not disclose the source of the star ratings on the 

website. Instead, Defendant implied that the star ratings were generated from the 

independent and unbiased product testing and research of the writers of the article. 

In fact, the star ratings were not based on the independent and unbiased product 

testing and research of the writers of the article. 

False Or Misleading Endorsement Claims

58. From 2017 until sometime around April 2021, Defendant’s website 

homepage and Facebook page also prominently displayed over a dozen 

endorsements from consumers who claimed they had used Defendant’s DNA 

testing products and services and were satisfied. These endorsements purportedly 

reflected the independent experiences and opinions of impartial ordinary users of 

Defendant’s DNA testing products and services. 

59. These endorsements were accompanied with photos of the purported

endorsers, their first names and last initials, and a star rating of the endorsers’

purported experience with CRI, indicating that they were highly satisfied. For 

example, Defendant’s website, crigenetics.com, and Facebook page prominently 

displayed the following endorsements, among others:

From www.crigenetics.com, (excerpts attached at Exhibit K (Nov. 18, 

2020) (“Ex. K”), p. K-3): 

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60. These consumer endorsements posted on the CRI Website and on 

CRI’s Facebook page were completely fabricated. Defendant paid a third party to 

write them. Further, the accompanying photos were not photos of Defendant’s 

customers. As such, these endorsements did not reflect the independent 

experiences and opinions of impartial ordinary users of Defendant’s DNA testing 

products and services. 

61. In 2020, Defendant also produced and posted a video on the CRI 

Website and CRI’s Facebook page, and through advertisements placed throughout 

the Internet. The video purported to reflect the independent experience and 

opinion of an impartial ordinary user of Defendant’s DNA testing products and 

services named Wayne, who claimed to be a Native American who tested his DNA 

with CRI and discovered that he has the oldest DNA found in America. At the end 

of the video, Wayne endorsed CRI’s DNA ancestry tests and reports and provided 

a link to CRI’s website. (A link to the video can be found at 

https://www.crigenetics.com/fb/vsl-wayne). The video of Wayne was widely 

disseminated. 

62. In fact, this video does not reflect the independent experience and 

opinion of an impartial ordinary user of Defendant’s DNA testing products and 

services. Defendant wrote and produced the video and hired a paid actor to play 

the role of Wayne. Wayne is a fictional character whose “experience” with DNA 

testing is loosely based on one of Defendant’s customers, who did not provide 

Defendant with an endorsement or cooperate in making the video. Defendant did

not disclose or adequately disclose in the video that Wayne was a fictional 

character or that the video was a paid advertisement. 

Defendant’s Deceptive Website Billing Practices

63. Consumers who choose to purchase one of Defendant’s DNA testing 

packages must click on one of the two packages Defendant offers on the CRI 

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Website to make the purchase. Once consumers select and click on their desired 

package, they are prompted to enter and submit their personal and payment 

information. The website ordering page did not disclose that when consumers 

entered their payment information that they would be charged immediately for 

each item selected for purchase and that the order for that item was final.

64. After consumers entered and submitted their personal and payment 

information, Defendant’s website offered several additional products or services

for purchase. These additional products and services appeared serially as pop-up 

pages. Consumers had to click through as many as five of these offers for 

additional products and services and either decline or purchase each one before 

moving on in the ordering and purchasing process. As described below, Defendant 

used numerous deceptive marketing techniques, known as “dark patterns,” to push 

consumers into purchasing additional products and services.

65. Since 2017 until at least June 2021, Defendant represented on each 

pop-up page offering additional products and services that consumers’ orders were 

not complete and that consumers would have an opportunity to view a final 

confirmation page and change their selections before being charged.

66. Each pop-up page prominently displayed a box with a yellow “Wait!” 

symbol and notified consumers that “Your order is not complete.” Each pop-up 

page also prominently displayed a graphic depiction of the ordering process above 

this notification using a bar with arrows indicating that the consumer was at “Step 

Two PRODUCT OPTIONS” of a three-step process, “Step Three” being a 

“FINAL CONFIRMATION.” Each additional product or service was 

characterized as a “Special Reward” that the consumer had been “chosen” to 

receive that is a “one-time special offer.” The following example of a pop-up page 

from the CRI Website shows these statements and depictions:

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From crigenetics.com (excerpts attached as Exhibit L (June 30, 2021) 

(“Ex. L”), at p. L-6): 

67. Consumers were required to scroll to the bottom of each pop-up page 

to either click on a bright orange button stating, “YES I WANT THIS SPECIAL 

ADDED TO MY ORDER,” or click on a less prominent and gray smaller print 

button stating, “NO THANKS, I UNDERSTAND THAT I WON’T SEE THIS 

OFFER AGAIN,” to advance through the ordering process. Consumers were also 

falsely told that “9.1 out of 10 choose this option.” These statements and depictions 

appeared on CRI’s website as follows:

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From crigenetics.com (excerpts at Ex. L, p. L-7): 

68. These statements and depictions on each pop-up page represented to 

consumers that they had not completed their orders and would have an opportunity 

to view a final confirmation page where they could edit the items selected and 

complete their orders before charges for payment were submitted. 

69. As depicted in Paragraph 67 above, each pop-up page also warned 

consumers to “not hit the ‘Back’ button as it can lead to a multiple charge on your 

card” [sic] just below the prominent statement that “Your order is not complete.” 

This tactic dissuaded consumers from backing out of the pop-up pages if they 

mistakenly chose one of the offers or changed their mind about the selection. 

70. After consumers finished clicking through each of the pop-up pages, 

they were not taken to a final confirmation page where they could review and edit 

their selections. Instead, they were presented with a final page stating, “Thank 

You For Your Order! Your order has been successfully processed, you will 

receive an email with the details,” as shown in the following depiction and 

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statements:

From crigenetics.com (excerpt at Ex. L, p. L-32):

 

71. Contrary to Defendant’s representations that consumers’ orders were 

not complete and could be reviewed and edited, consumers were immediately 

charged for each selection and did not have an opportunity to review and change or 

delete their selections on a final confirmation page. Defendant did not disclose or 

adequately disclose on any of the pop-up pages to consumers that charges for each 

item selected would immediately be submitted. As a result, many consumers 

ended up with unwanted charges for which they had to go through Defendant’s 

refund process to recoup. 

72. In June 2021, after learning about the FTC’s investigation, Defendant 

revised this ordering process on the CRI Website. Consumers were still required 

to select a package and enter their personal and payment information before 

proceeding through the pop-up pages for additional products and services. The 

website ordering page still did not disclose that when consumers entered their 

payment information that they would be charged immediately for each item 

selected for purchase and that each order would be final. 

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73. On each of the revised website’s pop-up pages, the graphic arrow 

depicted a two-step ordering process, with “Step 2” the point in the ordering 

process when consumers “REVIEW OPTIONAL ADD-ONS,” representing to 

consumers that their orders were not complete. The arrow graphic no longer 

showed a “Step 3” final confirmation. The revised website also continued to warn 

consumers to not hit the “Back” button, but then explained that if consumers hit the 

“Back” button, they “cannot get back to this page once you leave,” implying that 

consumers may interrupt the ordering process if they tried to back out of the page, 

further manipulating them to continue with the ordering process. An example of a 

revised additional offer page on the CRI website showed the following statements 

and depictions:

From www.crigenetics.com (excerpts attached as Exhibit M (Mar. 16, 

2022) (“Ex. M”), p. M-7): 

74. Consumers still had to review each pop-up page and scroll to the 

bottom either to add an additional item to their order or to select not to add the item 

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to their order to move through the ordering process. However, at the bottom of 

each pop-up page of the revised CRI website, a box was displayed showing an 

itemization of each item the consumer selected thus far, the quantity and the price 

of the item, and a “subtotal” of charges. Next to each item selected was a trashcan 

icon, which commonly indicates that the item next to the icon can be deleted if 

clicked. The trashcan icon in CRI’s summary of charges box led consumers to 

believe that they could delete an item before the order became final and a charge 

for that item was submitted for payment. An example of the ordering buttons and 

the summary box with the trashcan icons that appeared on each pop-up page is 

shown in the following statements and depictions from the CRI Website: 

From www.crigenetics.com (excerpts at Ex. M, pp. M-17 to M-18): 

 

75. In fact, when consumers clicked on the trashcan icon next to an item, 

the item could not be deleted on any of the pop-up pages. Once consumers 

completed viewing and clicking through the additional pop-up pages, they received 

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a final summary of charges without the trashcan icons shown next the item. The 

final summary included a message stating, “Thank you for your order!” The 

following is an example of the revised website page showing the statement and 

depiction of the final summary: 

From crigenetics.com (excerpts at Ex. M, p. M-36) (redacted for SPII): 

76. Contrary to the representations that consumers’ orders had not been

completed and they could delete selections by clicking on the trashcan icons, 

Defendant continued to immediately submit charges for consumers’ selections 

without permitting them to delete an item before the charge for that item was

submitted for payment. Nor did Defendant disclose or adequately disclose 

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anywhere on the website before consumers selected items that, once selected, the 

selection would be final and payment would be immediately processed. 

77. As a result, consumers who mistakenly or inadvertently selected

products or services or who changed their minds after selecting them, were 

required to seek refunds through Defendant’s refund process to recoup these 

unwanted charges. 

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

FTC has reason to believe that Defendant has violated or is about to violate laws 

enforced by the Commission because, among other things, Defendant engaged in 

the unlawful conduct over a period of four years, willfully and knowingly, despite 

having knowledge of hundreds of consumer complaints and refund requests, as 

well as inquiries by the Better Business Bureau regarding their deceptive practices

and only ceased its unlawful activities after the FTC notified Defendant of its 

pending investigation. 

VIOLATIONS OF THE FTC ACT

79. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or 

deceptive acts or practices in or affecting commerce.”

80. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act.

81. Acts or practices are unfair under Section 5 of the FTC Act if they 

cause or are likely to cause substantial injury to consumers that consumers cannot 

reasonably avoid themselves and that is not outweighed by countervailing benefits 

to consumers or competition. 15 U.S.C. § 45(n).

Count I

False or Unsubstantiated Claims Regarding DNA Testing 

Products and Services and Algorithm Software 

82. In numerous instances in connection with the advertising, marketing, 

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promotion, offering for sale, or sale of DNA testing products and services, 

including through the means described in Paragraphs 26 through 35 and 

Paragraphs 50-53 and 56-57, Defendant has represented, directly or indirectly, 

expressly or by implication, that Defendant’s DNA testing products and services:

A. Are the most accurate and detailed DNA testing products and services

available on the market; 

B. Will show consumers’ ancestry with an accuracy rate of over 90 percent; 

C. Will show exactly where consumers’ ancestors came from and exactly 

when they arrived there extending back over 50 or more generations; and 

D. Are generated from a patented algorithm software. 

83. The representations set forth in Paragraph 82 are false and misleading 

and were not substantiated at the time the representations were made.

84. Therefore, the making of the representations as set forth in Paragraph 

82 constitutes a deceptive act or practice in or affecting commerce, in violation of 

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

Count II

Failure to Disclose Material Connections to Marketing Websites

85. In numerous instances, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of DNA testing products and services, 

including through the means described in Paragraphs 36 through 57, Defendant has 

represented, directly or indirectly, expressly or by implication, that

geneticsdigest.com and buyerranking.com provided consumers with independent 

and unbiased research, ratings, and information related to genetics testing and

DNA ancestry testing companies.

86. In numerous instances in which Defendant has made the 

representations set forth in Paragraph 85, Defendant has failed to disclose or 

disclose adequately to consumers that Defendant has a material connection to the 

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websites geneticsdigest.com and buyerranking.com. This additional information 

would be material to consumers in deciding to purchase the DNA testing products 

and services that Defendant advertises, markets, promotes, offers for sale, or sells. 

87. In light of the representation described in Paragraph 85, Defendant’s 

failure to disclose or disclose adequately the material information as set forth in 

Paragraph 86 constitutes a deceptive act or practice in violation of Section 5(a) of 

the FTC Act, 15 U.S.C. § 45(a).

Count III

False or Unsubstantiated DNA Testing Product and Service Ratings

88. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of DNA testing products and services, 

including through the means described in Paragraphs 36 through 57, Defendant has 

represented, directly or indirectly, expressly or by implication, that the websites

geneticsdigest.com and buyerranking.com provide consumers with independent 

unbiased research, ratings, and information related to DNA testing and testing 

companies and their products and services, including Defendant’s DNA testing 

products and services. 

89. The representation set forth in Paragraph 88 is false and misleading 

and were not substantiated at the time the representations were made.

90. Therefore, the representation as set forth in Paragraph 88 constitutes a 

deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a). 

Count IV 

False or Misleading Endorsements 

91. Through the means described in Paragraphs 58 through 62, Defendant 

has represented, directly or indirectly, expressly or by implication, that certain 

reviews and testimonials of Defendant’s DNA testing products and services on 

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Defendant’s websites and social media reflected the independent experiences and 

opinions of impartial ordinary users of Defendant’s DNA testing products and 

services.

92. In fact, numerous reviews of Defendant’s DNA testing products and 

services on Defendant’s websites and social media did not reflect the independent 

experiences and opinions of impartial ordinary users of Defendant’s DNA testing

products and services because they are not real purchasers or users of the products 

and services. Therefore, the representation as set forth in Paragraph 91 is false and 

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

Count V 

Deceptive Billing Practices

93. Through the means described in Paragraphs 63 through 77, Defendant 

has represented, directly or indirectly, expressly or by implication, that when 

consumers select products and services for purchase on Defendant’s website, 

consumers’ orders are not final and payment for the items selected will not be 

submitted until after consumers can confirm, edit, or delete their selections on a 

final confirmation page. 

94. In fact, when consumers selected products and services for purchase 

on Defendant’s website, consumers’ orders were final and payment for the items 

selected was submitted before consumers could confirm, edit, or delete their 

selections on a final confirmation page. As result, in numerous instances, 

consumers were forced to seek a refund from Defendant for unwanted charges. 

95. Therefore, the making of the representation as set forth in Paragraph 

93 constitutes a deceptive act or practice in or affecting commerce, in violation of 

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

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Count VI 

Failure to Disclose Immediate Charges

96. Through the means described in Paragraphs 63 through 77, Defendant 

has represented, directly or indirectly, expressly or by implication, that when 

consumers select products and services for purchase on Defendant’s website, 

consumers’ orders are not final and payment for the items selected will not be 

submitted until after consumers can confirm, edit, or delete their selections on a 

final confirmation page. 

97. In numerous instances in connection with this representation, 

Defendant failed to disclose, or disclose adequately, that when consumers selected

products and services for purchase on Defendant’s website, consumers’ orders 

were final and payment for the items selected was submitted before consumers 

could confirm, edit, or delete their selections on a final confirmation page.

98. Defendant’s failure to disclose the material information described in 

Paragraph 97, in light of the representation described in Paragraph 96, constitutes a 

deceptive act or practice, in or affecting commerce, in violation of Section 5(a) of 

the FTC Act, 15 U.S.C. § 45(a).

VIOLATIONS OF CALIFORNIA LAW

Count VII

Untrue or Misleading Advertising

99. Plaintiff California alleges and incorporates by reference Paragraphs 1 

through 98 above as though fully set forth herein. 

100. Defendant has engaged in, aided and abetted, and conspired to engage 

in acts or practices that constitute violations of Business and Professions Code § 

17500 et seq., by making or disseminating, or causing to be made or disseminated, 

false or misleading statements with the intent to induce members of the public to 

purchase Defendant’s services or products when Defendant knew, or by the 

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exercise of reasonable care should have known, that the statements were false or 

misleading.

101. Defendant’s false or misleading statements include, but are not limited 

to, the following:

A. False or misleading claims regarding DNA testing products and 

services and algorithm software in CRI branded websites, apps, social media 

pages, advertisements, and other promotional materials;

B. False or misleading reviews, rankings, comparisons, and similar 

promotional efforts regarding CRI’s products and services on purportedly 

independent websites owned, controlled, and/or operated by Defendant;

C. False or misleading reviews and testimonials by purported customers; 

and

D. False or misleading statements and user experiences in connection 

with ordering and paying for Defendant’s products and services. 

Count VIII 

Unlawful, Unfair, and/or Fraudulent Business Practices

102. Plaintiff The People of the State of California alleges and incorporates 

by reference Paragraphs 1 through 101 above as though fully set forth herein. 

103. Defendant has engaged in, aided and abetted, and conspired to engage 

in acts or practices that are unlawful, unfair, or fraudulent, and which constitute 

unfair competition within the meaning of Business and Professions Code § 17200. 

These acts or practices include, but are not limited to, the following:

A. Defendant has violated Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a), as alleged above;

B. Defendant has violated Business and Professions Code § 17500 et 

seq., as alleged in Count VII above; 

C. Defendant has violated the California Consumer Legal Remedies Act, 

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California Civil Code § 1770 (5), by representing that its goods or services 

have sponsorship, approval, characteristics, ingredients, uses, benefits, or 

quantities that they do not have;

D. Defendant has violated the California Consumer Legal Remedies Act, 

California Civil Code § 1770(7), by representing that its goods or services are of a 

particular standard, quality, or grade, when they are of another; and

E. Defendant has violated the California Consumer Legal Remedies Act, 

California Civil Code § 1770(9), by advertising goods or services with intent not to 

sell them as advertised.

CONSUMER INJURY

104. Consumers have suffered and will continue to suffer substantial injury 

as a result of Defendant’s violations of the FTC Act, California’s Unfair 

Competition Law, and California’s False Advertising Law. Absent injunctive 

relief by this Court, Defendant is likely to continue to injure consumers and harm 

the public interest. 

PRAYER FOR RELIEF

Wherefore, Plaintiffs request that the Court:

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

Act by Defendant; 

B. Pursuant to California’s Business and Professions Code section 

17535, that Defendant, along with Defendant’s successors, agents, representatives, 

employees, and all persons who act in concert with Defendant, be permanently 

enjoined from making any false or misleading statements in violation of Business 

and Professions Code section 17500 as alleged in this Complaint; 

C. Pursuant to California’s Business and Professions Code section 

17203, that the Court enter all orders necessary to prevent Defendant, as well as 

Defendant’s successors, agents, representatives, employees, and all persons who 

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act in concert with Defendant from engaging in any act or practice that constitutes 

unfair competition in violation of Business and Professions Code section 17200; 

D. Pursuant to California’s Business and Professions Code section

17203, that the Court enter all orders or judgments as may be necessary to restore 

to any person in interest any money or other property that Defendant may have 

acquired by violations of Business and Professions Code section 17200, as proved 

at trial; 

E. Pursuant to California’s Business and Professions Code section

17536, that the Court assess a civil penalty of two thousand five hundred dollars 

($2,500) against Defendant for each violation of Business and Professions Code 

section 17500, as proved at trial; 

F. Pursuant to California’s Business and Professions Code section

17206, that the Court assess a civil penalty of two thousand five hundred dollars 

($2,500) against Defendant for each violation of Business and Professions Code 

section 17200, as proved at trial; 

G. Pursuant to California’s Business and Professions Code section

17206.1, subdivision (a), that the Court assess, in addition to any penalties assessed 

under Business and Professions Code sections 17206 and 17536, a civil penalty of 

two thousand five hundred dollars ($2,500) against Defendant for each violation of 

Business and Professions Code section 17200 perpetrated against senior citizens or 

disabled persons, as proved at trial; 

H. That Plaintiffs recover their costs of suit; and

I. For such other and further relief that the Court deems just and proper.

Respectfully submitted,

Dated: November 20, 2023 s/Nadine S. Samter 

NADINE S. SAMTER

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KATHARINE BARACH

Federal Trade Commission

915 Second Avenue, Ste. 2896

Seattle, WA 98174

Tel: (206) 220-6350

Samter Work Cell (202) 725-4585

CARLA L. CHEUNG

Federal Trade Commission

10990 Wilshire Blvd., Suite 400

Los Angeles, CA 90024

Tel: (310) 824-4300/Cell: (202) 644-6785

Fax: (310) 824-4318 

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

Dated: , 2023 ROB BONTA

Attorney General of California

NICKLAS A. AKERS

Senior Assistant Attorney General

JUDITH FIORENTINI

Supervising Deputy Attorney General

MICAH C.E. OSGOOD 

Deputy Attorney General

MICHELLE BURKART 

Deputy Attorney General

California Department of Justice

455 Golden Gate Ave. Suite 11000

San Francisco, CA 94102

(415) 510-44002

mike.osgood@doj.ca.gov

Nov. 20

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Attorneys for Plaintiff

PEOPLE OF THE STATE OF 

CALIFORNIA 

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