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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-cv-60924-ALTONAGA/Strauss 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

R360 LLC and STEVEN DOUMAR, 

Defendants. 

________________________________/ 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND CIVIL PENALTY 

JUDGMENT 

THIS CAUSE came before the Court upon Plaintiff, Federal Trade Commission’s Notice 

of Filing of Proposed Stipulated Order for Permanent Injunction and Civil Penalty Judgment 

[ECF No. 5]. The Federal Trade Commission (“FTC” or “Commission”), filed its Complaint 

for Civil Penalties, Permanent Injunction, and Other Equitable Relief [ECF No. 1], pursuant to 

Sections 5(a)(1), 5(m)(1)(A), 13(b), 16(a), and 19 of the Federal Trade Commission Act (“FTC 

Act”), 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 53(b), 56(a), and 57b, and Section 8023 of the Opioid 

Addiction Recovery Fraud Prevention Act of 2018 (“OARFPA”), 15 U.S.C. section 45d. (See 

id.). Defendants, Steven Doumar [ECF No. 6] and R360 LLC [ECF No. 7] have waived service 

of the summons and the Complaint. The Commission and Defendants stipulate to the entry of 

this Stipulated Order for Permanent Injunction and Civil Penalty Judgment (“Order”) to resolve 

all matters in dispute in this action between them. 

Being fully advised, it is ORDERED AND ADJUDGED as follows: 

1. This Court has jurisdiction over this matter. 
 

 

 

 

 

 

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2. The Complaint charges that Defendants participated in deceptive acts or practices 

in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and Section 8023 of 

OARFPA, 15 U.S.C. § 45d, in connection with the advertising of Substance Use 

Disorder Treatment Services. 

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

as specifically stated in this Order. Only for purposes of this action, Defendants 

admit the facts necessary to establish jurisdiction. 

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 and the Commission waive all rights to appeal or otherwise challenge 

or contest the validity of this Order. 

DEFINITIONS 

For this Order, the following definitions apply: 

A. “Covered Product or Service” means any Substance Use Disorder Treatment 

Product or Substance Use Disorder Treatment Service. 

B. “Defendants” means the Individual Defendant and the Corporate Defendant, 

individually, collectively, or in combination. 

1. “Corporate Defendant” means R360 LLC, and its successors and 

assigns. 

2. “Individual Defendant” means Steven Doumar. 

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C. “Substance Use Disorder Treatment Product” means a product for use or 

marketed for use in the treatment, cure, or prevention of a substance use disorder, 

including an opioid use disorder. 

D. “Substance Use Disorder Treatment Service” means a service that purports to 

provide referrals to treatment, treatment, or recovery housing for people 

diagnosed with, having, or purporting to have a substance use disorder, including 

an opioid use disorder. 

ORDER 

I. PROHIBITION AGAINST MISREPRESENTATIONS 

IT IS ORDERED that 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, in connection with promoting 

any Covered Product or Service are permanently restrained and enjoined from misrepresenting, 

or assisting others in misrepresenting, expressly or by implication: 

A. That consumers will receive a personalized assessment of their individual needs 

for such product or service; 

B. That consumers will obtain a referral for or be directed to a particular product or 

service based upon their individualized needs; 

C. That such product or service has been endorsed, selected, or evaluated by any 

particular person; 

D. That an expert evaluated such product or service, based upon an actual exercise of 

the represented expertise; 

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E. The nature of any criteria used to evaluate such product or service, including that 

any criteria are meaningful, rigorous, or objective; and 

F. Any other fact material to consumers concerning such product or service, such as: 

the total costs; any material restrictions, limitations, or conditions; or any material 

aspect of its performance, efficacy, nature, or central characteristics. 

II. MONETARY JUDGMENT FOR CIVIL PENALTY 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of $3,800,000 is entered in favor of the Commission 

against Individual Defendant and Corporate Defendant, jointly and severally, as a 

civil penalty. 

B. The Judgment is suspended subject to the Subsections below. 

C. The Commission’s agreement to the suspension of the judgment is expressly 

premised upon the truthfulness, accuracy, and completeness of Defendants’ sworn 

financial statements and related documents (collectively, “financial 

representations”) submitted to the Commission, namely: 

1. The Financial Statement of Individual Defendant Steven Doumar signed 

on June 10, 2020, including the attachments; 

2. The Financial Statement of Corporate Defendant R360 LLC signed by 

Steven Doumar, President, on June 10, 2020, including the attachments; 

3. The additional documentation and information submitted by email from 

Defendants’ counsel to Commission counsel on: April 21, 2020 (email 

from Jacqlyn Rovine to Christine DeLorme and Karen Mandel attaching 

personal and corporate bank account statements, and corporate balance 

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sheets and profit and loss statements); May 6, 2020 (email from Jacqlyn 

Rovine to Christine DeLorme and Karen Mandel attaching promissory 

notes and individual and corporate tax returns); May 28, 2020 (two emails 

from Jacqlyn Rovine to Christine DeLorme and Karen Mandel: the first 

attaching individual and corporate financial statements, personal bank 

account statements, and financial statements for other corporate entities; 

and the second attaching promissory notes and documents relating to a 

civil court proceeding); June 10, 2020 (two emails from Jacqlyn Rovine to 

Christine DeLorme and Karen Mandel: the first attaching a contractor 

agreement, individual and corporate financial statements, a billing 

statement, promissory notes and related information, and personal bank 

account statements; and the second attaching individual and corporate 

financial statements); June 11, 2020 (email from Jacqlyn Rovine to 

Christine DeLorme and Karen Mandel attaching personal bank account 

statements); and September 2, 2020 (email from Randal M. Shaheen to 

Christine DeLorme and Karen Mandel). 

D. The suspension of the Judgment will be lifted as to any Defendant if, upon motion 

by the Commission, the Court finds that Defendant failed to disclose any material 

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

misstatement or omission in the financial representations identified above. 

E. If the suspension of the Judgment is lifted, the Judgment becomes immediately 

due as to that Defendant in the amount specified in Subsection A above (which 

the parties stipulate only for purposes of this Section represents the amount of the 

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civil penalty for the violations alleged in the Complaint), less any payment 

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

entry of this Order. 

III. 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 will be taken as true, without further proof, in 

any subsequent civil litigation by or on behalf of the Commission, including in a 

proceeding to enforce its rights to any payment or monetary judgment pursuant to 

this Order. 

C. Defendants agree that the Judgment represents a civil penalty owed to the 

government of the United States and is not compensation for actual pecuniary loss 

and, therefore, as to the Individual Defendant, it is not subject to discharge under 

the Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7). 

D. Defendants acknowledge that their Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Defendants must 

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

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

IV. COOPERATION 

IT IS FURTHER ORDERED that Individual Defendant and Corporate Defendant must 

fully cooperate with representatives of the Commission in this case and in any investigation 

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related to or associated with the transactions or the occurrences that are the subject of the 

Complaint. Such Defendants must provide truthful and complete information, evidence, and 

testimony. Individual Defendant must appear, and Corporate Defendant must cause its officers, 

employees, representatives, or agents to appear for interviews, discovery, hearings, trials, and 

any other proceedings that a Commission representative may reasonably request upon 5 days’ 

written notice, or other reasonable notice, at such places and times as a Commission 

representative may designate, without the service of a subpoena. 

V. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of 

this Order: 

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

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

perjury. 

B. For 10 years after entry of this Order, Individual Defendant for any business that 

such Defendant, individually or collectively with any other Defendant, is the 

majority owner or controls directly or indirectly, and Corporate Defendant, must 

deliver a copy of this Order to: (1) all principals, officers, directors, and LLC 

managers and members; (2) all employees having managerial responsibilities for 

conduct related to the subject matter of the Order and all agents and 

representatives who participate in conduct related to the subject matter of the 

Order; and (3) any business entity resulting from any change in structure as set 

forth in the Section titled Compliance Reporting. Delivery must occur within 7 

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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 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

VI. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

A. Ninety days 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, which 

representatives of the Commission 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 the goods 

and services offered, the means of advertising, marketing, and sales, and 

the involvement of any other Defendant (which Individual Defendant must 

describe if he knows or should know due to his own involvement); (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 

acknowledgement obtained pursuant to the Section of this Order titled 

Order Acknowledgments, unless previously submitted to the Commission. 

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

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

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

for which Individual Defendant performs services whether as an employee 

or otherwise and any entity in which Individual Defendant has any 

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

involvement in each such business, including title, role, responsibilities, 

participation, authority, control, and any ownership. 

B. For 10 years after entry of this Order, each Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 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 

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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 14 days of its filing. 

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

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

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

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

_____” and supplying the date, signatory’s full name, title (if applicable), and 

signature. 

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

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

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

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. 

The subject line must begin: FTC v. R360 LLC, No. _______. 

VII. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 10 years 

after entry of the Order and retain each such records for 5 years. Specifically, Corporate 

Defendant and Individual Defendant, for any business that such Defendant, individually or 

collectively with any other Defendants, is a majority owner or controls directly or indirectly, 

must create and retain the following records: 

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

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

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

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

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

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

D. All records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and 

E. A copy of each unique advertisement or other marketing material. 

VIII. COMPLIANCE MONITORING 

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

compliance with this Order, including the financial representations upon which the Judgment 

was suspended: 

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

Commission, 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 is also authorized to obtain discovery, without further leave of court, 

using any of the procedures prescribed by Federal Rules of Civil Procedure 29, 30 

(including telephonic depositions), 31, 33, 34, 36, 45, and 69. 

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

directly with each Defendant. Defendants must permit representatives of the 

Commission to interview any employee or other person affiliated with any 

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Defendant who has agreed to such an interview. The person interviewed may 

have counsel present. 

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

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

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. 

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

reporting agency must furnish consumer reports concerning Individual Defendant, 

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

§1681b(a)(1). 

IX. 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. The Clerk shall mark the 

case CLOSED. 

DONE AND ORDERED in Miami, Florida, this 23rd day of May, 2022. 

________________________________________ 

CECILIA M. ALTONAGA 

CHIEF UNITED STATES DISTRICT JUDGE 

cc: Counsel of record 

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SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION: 

________________________________ Date: 

CHRISTINE L. DELORME 

(Special Bar ID A5502888) 

KAREN MANDEL 

(Special Bar ID A5501752) 

Attorneys, Division of Advertising Practices 

Federal Trade Commission 

600 Pennsylvania Ave. NW 

Washington, DC 20580 

Tel: 202-326-2095, -2491 

Fax: 202-326-3259 

cdelorme@ftc.gov 

kmandel@ftc.gov 

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CASE NO. 22-cv-60924-ALTONAGA/Strauss 

FOR DEFENDANTS: 

________________________________ Date: __________ 

LINDA A. GOLDSTEIN, ESQ. 

RANDAL M. SHAHEEN, ESQ. 

BakerHostetler 

45 Rockefeller Plaza 

New York, NY 10111 

Tel: (212) 589-4200 

Fax: (212) 589-4201 

lgoldstein@bakerlaw.com 

rshaheen@bakerlaw.com 

COUNSEL for R360 LLC and Steven Doumar 

DEFENDANTS: R360 LLC and Steven Doumar 

________________________________ Date: __________ 

STEVEN DOUMAR 

INDIVIDUALLY AND AS AN OFFICER OF R360 LLC 

AND AS AN OFFICER OF R360 LLC 

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