Case 2:22-cv-04260 Document 2-5 Filed 07/20/22 Page 1 of 4 PageID #: 240 

ATTACHMENT E 
 

 

 

 

 

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No later than 30 days after entry of this Order, Defendants shall pay One Million Dollars 

($1,000,000) to the State Attorneys General (as previously defined), which is to be divided among 

the State Attorneys General as follows: 

California: Defendants shall pay Fifty Thousand Dollars ($50,000) to the California Attorney 

General. These funds shall be used and allocated in accordance with Section 17206 of the Business 

and Professions Code. 

Connecticut: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Connecticut Attorney 

General. The payment shall be used at the sole discretion of the Attorney General, including but 

not limited to consumer protection enforcement or consumer education, to defray the costs of the 

inquiry leading hereto, monitoring and potential enforcement of this Order, or for any other public 

purpose permitted by applicable state law. 

Delaware: Defendant shall pay Fifty Thousand Dollars ($50,000) to the Delaware Attorney 

General. All payments to Delaware shall go to the Consumer Protection Unit of the Delaware 

Department of Justice (“DE CPU”). DE CPU shall place funds received in the State of 

Delaware’s Consumer Protection Fund, and such funds may be used for any lawful purpose. 

Florida: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Florida Attorney General. 

The payment shall be used at the sole discretion of the Attorney General, including but not limited 

to consumer protection enforcement or consumer education, to defray the costs of the inquiry 

leading hereto, monitoring and potential enforcement of this Order, or for any other public purpose 

permitted by applicable state law. 

Georgia: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Georgia Attorney General. 

The payment shall be used at the sole discretion of the Attorney General, including but not limited 

to consumer protection enforcement or consumer education, to defray the costs of the inquiry 

leading hereto, monitoring and potential enforcement of this Order, or for any other public purpose 

permitted by applicable state law. 

Hawaii: Defendants shall pay Fifty Thousand Dollars ($50,000) to the State of Hawaii Office of 

Consumer Protection. The payment shall be used at the discretion of the Executive Director of 

the Office of Consumer Protection. 

Idaho: Defendant shall distribute Fifty Thousand Dollars ($50,000) to the Attorney General of 

Idaho pursuant to instructions provided by the Idaho Attorney General's Office. These funds 

shall be deposited into the Idaho Consumer Protection Fund pursuant to Idaho Code § 48-606(5). 

Illinois: Defendant shall distribute Fifty Thousand Dollars ($50,000) to the Attorney General of 

Illinois pursuant to instructions provided by the Illinois Attorney General's Office. These funds 

shall be deposited into the Attorney General Court Ordered and Voluntary Compliance Payment 

Projects Fund for subsequent expenditure as authorized by the Attorney General. Defendants are 

not entitled to any further accounting regarding the money deposited into the Attorney General 

Court Ordered and Voluntary Compliance Payment Projects Fund. 
 

 

 

 

 

 

 

 

 

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Iowa: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Iowa Attorney General. The 

payment shall be used at the sole discretion of the Attorney General, including but not limited to 

consumer protection enforcement or consumer education, to defray the costs of the inquiry 

leading hereto, monitoring and potential enforcement of this Order, or for any other public 

purpose permitted by applicable state law. 

Kansas: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Kansas Attorney General. 

The payment shall be used at the sole discretion of the Attorney General, including but not limited 

to consumer protection enforcement or consumer education, to defray the costs of the inquiry 

leading hereto, monitoring and potential enforcement of this Order, or for any other public purpose 

permitted by applicable state law. 

Louisiana: Defendants shall pay Fifty Thousand ($50,000) to the Attorney General of Louisiana. 

Parties acknowledge that no portion of the payment is a fine or penalty. Said payment shall be used 

by the Louisiana Attorney General for such purposes that may include, but are not limited to, 

attorneys’ fees and other costs of investigation and litigation, or to be placed in, or applied to, the 

consumer protection law enforcement fund, including future consumer protection enforcement, 

consumer education, litigation, or local consumer aid fund or revolving fund, used to defray the 

costs of the inquiry leading hereto, or for other uses permitted by state law, at the sole discretion 

of the Attorney General. 

Maryland: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Maryland Attorney 

General. The payment shall be used at the sole discretion of the Attorney General, including but 

not limited to consumer protection enforcement or consumer education, to defray the costs of the 

inquiry leading hereto, monitoring and potential enforcement of this Order, or for any other public 

purpose permitted by applicable state law. 

Nevada: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Nevada Attorney 

General. The payment shall be deposited in the Consumer Protection Administrative Fund to be 

used consistent with the purposes of that fund at the sole discretion of the Attorney General by 

and through his Consumer Advocate, including but not limited to consumer protection 

enforcement and costs associated thereto, or consumer education. 

New York: Defendants shall pay One Hundred and Fifty Thousand Dollars ($150,000) to the 

New York Attorney General. The payment shall be used at the sole discretion of the Attorney 

General, including but not limited to consumer protection enforcement or consumer education, to 

defray the costs of the inquiry leading hereto, monitoring and potential enforcement of this 

Order, or for any other public purpose permitted by applicable state law including, at her 

discretion, directing the funds to a federal government agency or program, or to local 

government. 

North Carolina: Defendants shall pay Fifty Thousand Dollars ($50,000) to the North Carolina 

Attorney General. This payment shall be used for restitution, attorney fees, investigative costs, 

consumer protection enforcement, other consumer protection purposes, and other purposes 

allowed by law, at the discretion of the Attorney General. 
 

 

 

 

 

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Pennsylvania: Defendants shall pay Fifty Thousand Dollars ($50,000) to the Pennsylvania Office 

of Attorney General for future public protection purposes. The payment shall be used at the sole 

discretion of the Attorney General, including but not limited to consumer protection enforcement 

or consumer education, to defray the costs of the inquiry leading hereto, monitoring and potential 

enforcement of this Order, or for any other public purpose permitted by applicable state law. 

Virginia: The Virginia portion of the aggregate settlement amount is Fifty Thousand Dollars 

($50,000). All funds paid to the Virginia Attorney General pursuant to this paragraph of the 

Consent Order shall be deposited to the Attorney General’s Regulatory, Consumer Advocacy, 

Litigation and Enforcement Revolving Trust Fund (the “Revolving Fund”). Amounts deposited 

to the Revolving Fund may be used for costs of the Attorney General associated with his 

consumer protection advocacy and enforcement efforts and other delineated purposes permitted 

by state law. 

Washington: Pursuant to RCW 19.86.080, Defendants agree to pay Washington the amount of 

Fifty Thousand Dollars ($50,000) for consumer restitution, for costs and reasonable attorney’s 

fees incurred by Washington in pursuing this matter, for monitoring and potential enforcement of 

this Consent Decree, for future enforcement of RCW 19.86, or for any lawful purpose in the 

discharge of the Attorney General’s duties at the sole discretion of the Attorney General.