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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

LURN, INC., a corporation, 

ANIK SINGAL, individually and as an officer of 

LURN, INC., 

TYRONE COHEN, individually, and 

DAVID KETTNER, individually, 

Defendants. 

Case No. 8:23-cv-02622-AAQ

STIPULATED ORDER FOR 

PERMANENT INJUNCTION, 

MONETARY RELIEF, AND 

OTHER RELIEF 

Plaintiff, the Federal Trade Commission (“Commission” or “FTC”), filed its Complaint 

for Permanent Injunction, Monetary Relief, and Other Relief (“Complaint”), for a permanent 

injunction, monetary relief, and other relief in this matter, pursuant to Sections 13(b) and 19 of 

the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b) and 57b, and the 

Telemarketing and Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 

U.S.C. §§ 6101-6108. The Commission and Defendants Lurn, Inc. (“Corporate Defendant”) and 

Anik Singal (“Defendant Singal”) stipulate to the entry of this Stipulated Order for Permanent 

Injunction, Monetary Judgment, and Other 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. 
Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 3 of 39 

2. The Complaint charges that Corporate Defendant and Defendant Singal 

participated in deceptive and unfair acts or practices that violate Section 5 of the FTC Act, 15 

U.S.C. § 45, and the FTC’s Telemarketing Sales Rule (“TSR” or “Rule”), 16 C.F.R. Part 310, 

and that the Commission has previously determined to be unfair or deceptive in connection with 

the advertising, marketing, distribution, and selling of ecommerce programs and courses to 

consumers throughout the United States. 

3. Corporate Defendant and Defendant Singal neither admit nor deny any of the 

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

action, Corporate Defendant and Defendant Singal admit the facts necessary to establish 

jurisdiction. 

4. Corporate Defendant and Defendant Singal 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. Corporate Defendant and Defendant Singal and the Commission 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, 

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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. 

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. 

8. This disclosure must not be presented to the consumer through a hyperlink. 

9. When the representation or sales practice targets a specific audience, such as 

children, the elderly, or the terminally ill, “ordinary consumers” includes reasonable members of 

that group. 

B. “Defendants” means all of the Individual Defendants and the Corporate 

Defendant, individually, collectively, or in any combination. 

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1. “Corporate Defendant” means Lurn, Inc., and its successors and assigns. 

2. “Individual Defendants” means Anik Singal, Tyrone Cohen, and David 

Kettner. 

B. “Earnings Claim” means any representation, specific or general, about income, 

revenues, financial gains, percentage gains, profit, net profit, gross profit, or return on 

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

mathematical calculation that demonstrates possible results based upon a combination of 

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

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

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

statements, claims, success stories, endorsements, or testimonials about the performance or 

profitability of representatives, endorsers, instructors, or customers. 

C. “Investment Opportunity” includes anything, tangible or intangible, that is 

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

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

D. “Telemarketing” means any plan, program, or campaign which is conducted to 

induce the purchase of goods or services by use of one or more telephones, and which involves a 

telephone call, whether or not covered by the Telemarketing Sales Rule. 

ORDER 

I. PROHIBITION CONCERNING EARNINGS CLAIMS 

IT IS ORDERED that Corporate Defendant, Defendant Singal, 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 

4 
A. 

B. 

C. 

D. 

E. 

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with promoting or offering for sale any good or service, are permanently restrained and enjoined 

from making any Earnings Claims or assisting others in making any Earnings Claims, expressly 

or by implication, unless: 

The Earnings Claims are non-misleading; 

At the time the Earnings Claims are made, Corporate Defendant and Defendant 

Singal have a reasonable basis for the claims and have in their possession written 

materials that substantiate them; 

To the extent that the Earnings Claims concern the performance or profitability of 

specific representatives, endorsers, instructors, or customers: 

1. Corporate Defendant and Defendant Singal must Clearly and 

Conspicuously disclose typical customer results, and have written substantiation 

for such typical results; and 

2. If Corporate Defendant or Defendant Singal make any statements 

characterizing or qualifying the typical results (by saying, for example, “most 

students do not earn income because they do not complete the program”), 

Corporate Defendant and Defendant Singal must have written substantiation for 

those statements as well; 

Corporate Defendant and Defendant Singal make the written substantiation for 

Earnings Claims available upon request to the consumer, potential purchaser, and 

the FTC; and 

Any earnings of Corporate Defendant and Defendant Singal that form the basis 

for the Earnings Claims were achieved in compliance with the law. 

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II. PROHIBITION AGAINST MISREPRESENTATIONS 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal, 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 the advertising, marketing, promoting, offering for sale, or selling of any 

good or service, are permanently restrained and enjoined from misrepresenting or assisting 

others in misrepresenting, expressly or by implication: 

A. The description of the good or service; 

B. That any past performance referenced in Corporate Defendant’s or Defendant 

Singal’s advertising, marketing, promoting, offering for sale, or selling of any good or 

service is indicative of future results; 

C. That any testimonials Corporate Defendant or Defendant Singal use in the 

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

reflect the experience that consumers are likely to have using such products or 

services; 

D. That purchasers or users of Corporate Defendant’s or Defendant Singal’s products or 

services will or are likely to achieve substantial profits or earnings; 

E. The risk, earnings potential, or profitability of goods or services that are the subject of 

a sales offer; 

F. The background, expertise, or other information about the skills or accomplishments 

of any person whose name or likeness is used in promoting Corporate Defendant’s or 

Defendant Singal’s goods or services to prospective purchasers; 

6 
 

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G. The level of experience required for consumers to effectively use Corporate 

Defendant’s or Defendant Singal’s goods or services; 

H. The time or effort required for consumers to effectively use Corporate Defendant’s or 

Defendant Singal’s goods or services; 

I. That Corporate Defendant’s or Defendant Singal’s goods or services will be sold to 

only a limited number of prospective participants; 

J. Any material aspect of the nature or terms of a refund, cancellation, or exchange 

policy for the good or service; or 

K. Any other fact material to consumers concerning any good or service, such as: the 

total costs; any material restrictions; limitations; or conditions; or any material aspect 

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

III. PROHIBITIONS REGARDING TELEMARKETING 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal, their 

officers, agents, and employees, and all other persons in active concert or participation with 

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

with Telemarketing of any goods or services are permanently restrained and enjoined from: 

A. Misrepresenting earnings potential or profitability; 

B. Misrepresenting material aspects of an Investment Opportunity; 

C. Misrepresenting any material aspect of the performance, efficacy, nature, or central 

characteristics of goods or services that are the subject of a sales offer; 

D. Making a false or misleading statement to induce any person to pay for goods or 

services; or 

E. Violating any provision of the TSR, 16 C.F.R. Part 310, attached as Attachment B. 

7 
A. 

B. 

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IV. JUDGMENT FOR MONETARY RELIEF 

IT IS FURTHER ORDERED that: 

Judgment in the amount of $14,077,121 is entered in favor of the Commission 

against Corporate Defendant and Defendant Singal, jointly and severally, as monetary relief. 

Corporate Defendant and Defendant Singal are ordered to pay to the Commission 

$2,500,000.00, which, as they stipulate, their undersigned counsel holds in escrow for no 

purpose other than payment to the Commission. Such payment must be made within 7 days of 

entry of this Order by electronic fund transfer in accordance with instructions previously 

provided by a representative of the Commission. Upon such payment, the remainder of the 

judgment is suspended, subject to the Subsections below. 

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

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

and Defendant Singal’s sworn financial statements and related documents (collectively, 

“Financial Attestations”) submitted to the Commission, namely: 

1. the Financial Statement of Anik Singal, signed on May 22, 2023, and all 

attachments thereto; 

2. the Financial Statement of Lurn, Inc., signed by Richard Ruggiero on 

March 28, 2023, and all attachments thereto; 

3. the updated Financial Statement of Lurn, Inc., signed by Anik Singal on 

May 23, 2023, and all attachments thereto; 

4. the additional information submitted by email from Greg Christiansen to 

Commission Counsel, Ben Davidson, Josh Doan, and Allen Dreschel, on May 12, 2023, 

and the attachment thereto, a letter of May 11, 2023 from Greg Christiansen to 

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Commission counsel, Ben Davidson, Josh Doan, and Allen Dreschel, on the subject of 

Mr. Singal’s asset portfolio; 

5. the additional information submitted by email from Michael Carrigan to 

Commission counsel, Josh Doan, on June 7, 2023, and the attachment thereto, a letter of 

June 7, 2023 from Joseph Garcia, Senior Liability Claim Specialist, Sedgwick, regarding 

the Singal Insurance Company; 

6. the additional documentation submitted by email from Greg Christiansen 

to Commission counsel, Allen Dreschel, on May 18, 2023, and all attachments thereto, 

including the Management Report for Singal Holding I LLC, the Balance Sheet for 

Kurma, the Profit and Loss Statement for Kurma; 

7. the additional documentation submitted by email from Greg Christiansen 

to Commission counsel, Allen Dreschel, on May 22, 2023, and all the attachments 

thereto, including the Management Report for Singal Holding I LLC, the Balance Sheet 

for Kurma, and the Profit and Loss Statement for Kurma; the Balance Sheet for Tenacity 

Watches, LLC, the Profit and Loss Statement for Tenacity Watches, LLC, the letter of 

March 13, 2023 from Mr. Joseph Garcia of Sedgwick to Mr. Richard Lurn regarding 

insurance issues, the insurance policies, schedules of coverage, and associated documents 

from HRP Insurance Company, Inc., the “Schedule 9 -- Contingent Liabilities” document 

submitted in connection with the Financial Statement of Anik Singal, the “Personal 

Financial Statement” supplementary document submitted in connection with the 

Financial Statement of Anik Singal, and the document detailing Anik Singal’s gross 

income submitted in connection with the Financial Statement of Anik Singal; 

8. the additional documentation submitted by email from Greg Christiansen 

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to Commission counsel, Allen Dreschel, on May 25, 2023, and all attachments thereto, 

including a document that contains images of six personal checks sent by Anik Singal in 

2021 and 2022, and the account statements for certain of Anik Singal’s cryptocurrency 

holdings; 

9. the additional documentation submitted by email from Greg Christiansen 

to Commission counsel, Benjamin Davidson, Josh Doan, and Allen Dreschel, on June 1, 

2023, and all attachments thereto, including the letter of Greg Christiansen to 

Commission counsel, Benjamin Davidson, Josh Doan, and Allen Dreschel dated May 31, 

2023, regarding the liquidity status of Anik Singal’s various real estate and investment 

holdings; the letter of May 29, 2023 from 

Jason M. Cross, Managing Director, Capital Markets, Redbrick LMD, LLC, to Anik 

Singal, regarding the liquidity status of his investment holdings in Redbrick OZ Fund, 

LLC; the letter of May 29, 2023 from Miguel Jauregui, Head of Capital Markets, SAB, to 

Anik and Andrea Singal, regarding the potential to obtain commercial real estate 

financing for the Mountain Express properties; the letter of May 29, 2023 from Jonathan 

Tower, Arctaris Impact Investors, LLC, to Anik Singal, regarding the rules that govern 

redemptions and distributions from the Arctaris Opportunity Zone Fund; the April 16, 

2022 supplement to the Amended and Restated Private Placement Memorandum for the 

Caliber Tax Advantaged Opportunity Zone Fund, LP; the Subscription Completion 

Package document issued in conjunction with the purchase of Caliber Tax Advantaged 

Opportunity Zone Fund, LP Units; the email of May 26, 2023 from Matt Cardall, Senior 

Vice President, Private Wealth Partners, CIM Group, to Anik Singal, regarding the 

minimum holding period for investments in the CIM Opportunity Zone Fund; and the 

10 
A. 

B. 

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document with a list of sources of income for Kurma from January 2022 to April 2023; 

10. the additional information submitted by email from Michael Carrigan to 

Commission counsel, Josh Doan, on June 7, 2023, and the attachment thereto, a letter of 

June 7, 2023 from Joseph Garcia, Senior Liability Claim Specialist, Sedgwick, regarding 

the Singal Insurance Company; and 

11. the additional information submitted by email from Michael Carrigan to 

Commission counsel, Josh Doan, on June 9, 2023, regarding the bankruptcy status of the 

Mountain Express Properties and related issues. 

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 Attestations 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 consumer injury alleged in the 

Complaint), less any payment previously made pursuant to this Section, plus interest computed 

from the date of entry of this Order. 

V. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

Corporate Defendant and Defendant Singal 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. 

The facts alleged in the Complaint will be taken as true, without further proof, in 

11 
C. 

D. 

E. 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 13 of 39 

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. 

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. 

Corporate Defendant and Defendant Singal acknowledge that their Taxpayer 

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

they 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. 

All money received by the Commission pursuant to Section IV.A of this Order 

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

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

fund. If a representative of the Commission decides that direct redress to consumers is wholly or 

partially impracticable or money remains after such redress is completed, the Commission may 

apply any remaining money for such related relief as it determines to be reasonably related to 

Corporate Defendant and Defendant Singal’s practices alleged in the Complaint. Any money not 

used for relief is to be deposited to the U.S. Treasury. Corporate Defendant and Defendant Singal 

have no right to challenge any actions the Commission or its representatives may take pursuant 

to this Subsection. 

VI. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal, their 

officers, agents, employees, attorneys, and all other persons in active concert or participation 

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Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 14 of 39 

with any of them, who receive actual notice of this Order, are permanently restrained and 

enjoined from directly or indirectly failing to provide sufficient customer information to enable 

the Commission to efficiently administer consumer redress. If a representative of the 

Commission requests in writing any information related to redress, Corporate Defendant and 

Defendant Singal must provide it, in the form prescribed by the Commission, within 14 days. 

VII. NOTICE TO CUSTOMERS 

IT IS FURTHER ORDERED that, within 7 days of entry of this Order, Corporate 

Defendant and Defendant Singal shall email notice in the form shown in Attachment A to all 

persons who purchased goods or services marketed or sold by Corporate Defendant, of any type 

at any time between May 1, 2019, and the date of the entry of this Order, with the subject line, 

“What the FTC Settlement Means for Lurn Customers.” Notices sent by email shall be sent from 

an email address that Corporate Defendant regularly uses for communicating with consumers 

and Corporate Defendant and Defendant Singal shall make commercially reasonable efforts to 

leverage technologies to ensure the deliverability of emails (for example, but not limited to, SPF, 

DKIM, and use of sending IP addresses with known good reputations). Within 15 days of entry 

of this Order, Corporate Defendant and Defendant Singal shall mail the form shown in 

Attachment A via first-class mail, postage prepaid with address forwarding requested, to the last 

known mailing address of any intended email recipient whose emailed message delivery fails. 

No information other than that contained in Attachment A shall be included in or added to the 

notice required by this Section, nor shall any other materials be transmitted with the notice. 

VIII. COOPERATION 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal must fully 

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

or associated with the transactions or the occurrences that are the subject of the Complaint. 

13 
 

A. 

B. 

C. 

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Corporate Defendant and Defendant Singal must provide truthful and complete information, 

evidence, and testimony. Defendant Singal 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. 

IX. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal obtain 

acknowledgments of receipt of this Order: 

Corporate Defendant and Defendant Singal, within 7 days of entry of this Order, 

must each submit to the Commission an acknowledgment of receipt of this Order sworn under 

penalty of perjury. 

For 10 years after entry of this Order, Defendant Singal, for any business he 

individually or collectively with any other Defendants, 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 days of entry of this Order for current 

personnel. For all others, delivery must occur before they assume their responsibilities. 

From each individual or entity to which Corporate Defendant or Defendant Singal 

delivered a copy of this Order, that Defendant must obtain, within 30 days, a signed and dated 

14 
A. 

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acknowledgment of receipt of this Order. 

X. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal make 

timely submissions to the Commission: 

One year after entry of this Order, Corporate Defendant and Defendant Singal 

must each submit a compliance report, sworn under penalty of perjury: 

1. Corporate Defendant and Defendant Singal 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 that 

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 Defendant 

Singal 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 Order Acknowledgment obtained pursuant to 

this Order, unless previously submitted to the Commission. 

2. Additionally, Defendant Singal 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 such 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 such Defendant’s involvement in 

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

15 
B. 

C. 

D. 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 17 of 39 

and any ownership. 

For ten years after entry of this Order, Corporate Defendant and Defendant Singal 

must each submit a compliance notice, sworn under penalty of perjury, within 14 days of any 

change in the following: 

1. Corporate Defendant and Defendant Singal must report any change in: (a) 

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

that Corporate Defendant or Defendant Singal has any ownership interest in or controls 

directly or indirectly that may affect compliance obligations arising under this Order, 

including: creation, merger, sale, or dissolution of the entity or any subsidiary, parent, or 

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

2. Additionally, Defendant Singal 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 such Defendant performs services 

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

ownership interest, and identify the name, physical address, and any Internet address of 

the business or entity. 

Corporate Defendant and Defendant Singal 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. 

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 

16 
E. 

A. 

B. 

C. 

D. 

E. 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 18 of 39 

full name, title (if applicable), and signature. 

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. Lurn, Inc., Matter No. 2223056. 

XI. RECORDKEEPING 

IT IS FURTHER ORDERED that Corporate Defendant and Defendant Singal must 

create certain records for ten years after entry of the Order and retain each such record for 5 

years. Specifically, Corporate Defendant and Defendant Singal, 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: 

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

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; 

records of all consumer complaints and refund requests, whether received directly 

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

all records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission; and 

a copy of each unique advertisement or other marketing material. 

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XII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Corporate Defendant 

and Defendant Singal’s compliance with this Order and any failure to transfer any assets as 

required by this Order: 

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

Commission, Corporate Defendant and Defendant Singal 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 Corporate Defendant and Defendant Singal. Corporate Defendant and Defendant 

Singal must permit representatives of the Commission 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 may use all other lawful means, including posing, through its 

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

and Defendant Singal or any individual or entity affiliated with such 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, 57b1. 

18 
_______________________________ 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 20 of 39 

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

reporting agency must furnish consumer reports concerning Defendant Singal, pursuant to 

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

XIII. 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. 

SO ORDERED this day of , 2023. 

UNITED STATES DISTRICT JUDGE 

19 
SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION 

Date: 

Benjamin R. Davidson 

bdavidson@ftc.gov 

Joshua Doan 

jdoan@ftc.gov 

Ryan McAuliffe 

rmcauliffe@ftc.gov 

Attorneys 

Federal Trade Commission 

600 Pennsylvania Ave NW 

Mailstop CC-63 16 

Washington, DC 20580 

(202) 326-3055 

FOR DEFENDANTS: 

Date: July 28, 2023 

Michael Carrigan, Esq. 

mcarrigan@hollandhart.com 

Holland & Hart LLP 

555 17th Street, Suite 3200 

Denver, CO 80202 

(303) 295-8384 

G James Christiansen 

greg@guardian law .com 

Guardian Law LLC 

833 E. Pioneer Road, Suite I 02 

Draper, UT 84020 

(844) 409-1122 

Counsel for Lurn, Inc., and Anik Singal 

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DEFENDANTS: Lum, Inc., and Anilc Singal 

Date: 

Anik Singal, individually 

and as an officer of Lum, Inc. 

23 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 22 of 39 
 

 

 

 

 

 

 

 

 

Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 23 of 39 

ATTACHMENT A 

Subject: Lurn, Inc. Settlement of FTC Deception Case 

Dear <Customer>: 

Because our records show you’ve been a customer of our company, we’re writing to let you 

know that the Federal Trade Commission, the nation’s consumer protection agency, has sued 

and reached a settlement with Lurn, Inc., Anik Singal, and others. 

What happened? 

The FTC sued us and said that our claims about how much people could earn using our 

programs were deceptive because we didn’t have sufficient evidence that customers were 

likely to earn what we said they could. 

What we’re doing in response 

To settle the lawsuit with the FTC 

• We won’t make claims about earnings without written proof. If we make claims about 

how much people can earn, we must have written proof that a typical customer is likely 

to get that kind of result. It also means we can’t use testimonials, like those we have 

featured in our webinars, that would lead you to believe those experiences are typical 

unless we have written proof that they are. 

• We won’t make claims about the typical experience our customers have without 

written proof. That includes what you’d need to participate in our program, like the 

time commitment and the amount of money or experience required to be successful. 

What you should know about money-making offers 

Before you pay for any offer that includes claims about how much money you can make as a 

participant, we and the FTC encourage you to 

• Take your time. 

• Avoid high-pressure sales pitches that require you to act now or risk losing out. 

• Be skeptical about success stories and testimonials. 

• Do your research. Search online for the company’s name plus words like “review,” 

“scam,” or “complaint.” 

We are pleased with the settlement with the FTC and are committed to following its 

requirements. We believe that ultimately it will result in a better experience for all our 

customers. 
Case 8:23-cv-02622-AAQ Document 9-1 Filed 09/27/23 Page 24 of 39 

For more information about Lurn’s settlement with the FTC, visit [FTC URL]. 

Sincerely, 

[signature for Lurn] 

Lurn, Inc.