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

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF MARYLAND 

FEDERAL TRADE COMMISSION, 

Plaintiff, 

v. 

LURN, INC., 

2098 Gaither Road Rockville, Maryland 20850 

ANIK SINGAL, a resident of Gaithersburg, 

Montgomery County, Maryland, individually and 

as an officer of LURN, INC., 

TYRONE COHEN, individually, and 

DAVID KETTNER, individually 

Defendants. 

Case No. ____________ 

COMPLAINT FOR PERMANENT 

INJUNCTION, MONETARY 

RELIEF, AND OTHER RELIEF 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 

1. The FTC brings this action under Sections 13(b), and 19 of the Federal Trade 

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

Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. §§ 6101-6108, which 

authorize the FTC to seek, and the Court to order, temporary, preliminary, and permanent 

injunctive relief, monetary relief, and other relief against Defendants for engaging in acts or 

practices that violate Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), 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 sale and marketing of Defendants’ 

goods and services. 

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Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 2 of 27 

SUMMARY OF CASE 

2. Since 2019, Defendants have sold programs that purport to teach consumers how 

to earn substantial income online. From 2019 through May 2022, Defendants took approximately 

$65,000,000 from consumers using deceptive earnings claims. 

3. Defendants claim that their programs can teach consumers how to make money 

through a wide range of activities. For example, Defendants offer to teach consumers how to 

make six to seven figures a year through email-based affiliate marketing, how to make $1,000 a 

day selling eBooks, and how to make six figures a year by selling customizable mugs. 

4. Defendants also sell expensive business coaching programs that purport to allow 

consumers to make hundreds of thousands of dollars and replace their day jobs. 

5. Defendants lack substantiation for their earnings claims, which are often flatly 

fabricated. 

6. In an attempt to pressure consumers to purchase their courses, Defendants 

routinely state falsely, that Lurn has limited capacity to work with new customers (or 

“students”), and due to high demand, the courses are filling up quickly. Defendants falsely tell 

consumers that they must act fast if they want an opportunity to purchase Lurn’s programs. 

7. Defendants’ deceptive practices, as described in this Complaint, violate the FTC 

Act and the TSR. 

8. On October 26, 2021, the FTC sent Lurn Notices of Penalty Offenses Concerning 

Money-Making Opportunities and Testimonials (the “Notices”), noting that Lurn could be 

subject to civil penalties for violations of the FTC Act in connection with their marketing claims, 

pursuant to 15 U.S.C. § 45(m)(1)(B); 16 C.F.R. § 1.98(e). The Notices stated that it is an unfair 

2 
or deceptive trade practice to make false, misleading, or deceptive representations concerning the 

profits or earnings a participant in a money-making opportunity can expect or to engage in 

certain acts or practices related to consumer testimonials. Defendants Lurn and Singal have 

continued to use deceptive or unsubstantiated earnings claims in their marketing even after 

receiving the Notices. 

JURISDICTION AND VENUE 

9. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

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

(c)(2), and 15 U.S.C. § 53(b). 

PLAINTIFF 

11. 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. 

The FTC also enforces the Telemarketing Act. In accordance with the Telemarketing Act, the 

FTC promulgated and enforces the TSR, 16 C.F.R. Part 310, which prohibits deceptive and 

abusive telemarketing acts or practices. 

DEFENDANTS 

12. Defendant Lurn, Inc. (“Lurn”), is a Maryland corporation with its principal place 

of business at 2098 Gaither Rd., Rockville, MD 20850-4017. Lurn transacts or has transacted 

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

Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 3 of 27 

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Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 4 of 27 

acting alone or in concert with others, Lurn has advertised, marketed, distributed, and sold ecommerce programs to consumers throughout the United States and abroad. 

13. Defendant Anik Singal (“Singal”) is the Chief Executive Officer and sole owner 

of Lurn. At all times relevant to this Complaint, acting alone or in concert with others, he has 

formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices set forth in this Complaint. Singal is the face of Lurn. He features prominently in 

Lurn’s advertising and webinars and plays a key role in developing Lurn’s offerings and 

marketing. Singal resides in Gaithersburg, Maryland, and in connection with the matters alleged 

herein, transacts or has transacted business in this District and throughout the United States. 

14. Defendant Tyrone Cohen (“Cohen”) is the creator and spokesperson for Kindle 

Cashflow University, one of Lurn’s most popular programs. At all times relevant to this 

Complaint, acting alone or in concert with others, he has formulated, directed, controlled, had 

authority to control, or participated in the acts and practices set forth in this Complaint. Cohen 

resides in Apex, North Carolina, and in in connection with the matters alleged herein, transacts 

or has transacted business in this District and throughout the United States. 

15. Defendant David Kettner (“Kettner”) is the creator and spokesperson of Printable 

Profits, one of Lurn’s most popular programs. At all times relevant to this Complaint, acting 

alone or in concert with others, he has formulated, directed, controlled, had authority to control, 

or participated in the acts and practices set forth in this Complaint. Kettner resides in Peoria, 

Arizona, and in connection with the matters alleged herein, transacts or has transacted business 

in this District and throughout the United States. 

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Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 5 of 27 

COMMERCE 

16. At all times relevant to this Complaint, Defendants have 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. 

DEFENDANTS’ BUSINESS ACTIVITIES 

17. Since at least 2009, and continuing through the present day, Defendants have 

engaged in a scheme to sell e-commerce programs and related products and services. From 2019 

through May 2022 Defendants took more than $65,000,000 from consumers. 

18. Defendants market their programs and related products and services to consumers 

around the country through the internet, email, YouTube, social media, and telemarketing. 

19. Defendants represent that their e-commerce programs are tested and profitable 

systems consumers can easily use to generate significant income. Defendants claim that 

consumers will be able to make thousands, and sometimes millions, of dollars in profit, 

regardless of their experience, knowledge, or investment. These representations are false or 

misleading and unsubstantiated. 

20. Defendants do not track their customers’ earnings and do not know what those 

earnings amount to. Defendants’ only substantiation for their lavish earnings claims are a handful 

of anecdotal testimonials from former customers or Lurn coaches who purport to have earned 

substantial income with Defendants’ e-commerce programs. 

21. Defendants sell a variety of e-commerce programs, with a handful of those 

accounting for more than half of Lurn’s income. From 2019 to November 2022, Defendants 

generated approximately $24 million from the sale of their “Email Startup Incubator” program, 

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Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 6 of 27 

$5 million from the sale of a “Printable Profits” program, and $4 million from a “Kindle Cash 

Flow University” program. As explained below, Defendants use deceptive practices to sell each 

of these programs. 

Deceptive Marketing of the Email Startup Incubator Program 

22. Defendants’ Email Startup Incubator purports to teach consumers how to make 

substantial income through e-mail advertising and affiliate marketing. Email Startup Incubator 

costs $1,995, though Defendants claim the course offers over $37,710 of value. 

23. Defendants’ advertisements invite consumers to a “FREE training workshop” that 

will walk them “through the exact steps [Singal] used to generate millions of dollars online by 

using just an email and other people’s products.” Consumers can then click on a link that brings 

them to a registration page at a Lurn.com domain. 

24. After following the link, consumers see the screen in the image below. In that 

image, Defendants claim to have a “5 - Step System” to become a “Stay-At-Home 

Millionaire.” Defendants also claim that Singal has used this 5-Step System for the last twenty 

years, and that he currently uses this system to generate over $1 million “PER MONTH!” 

6 
Discover My 5-Step System 

For Becoming A Stay-AtHome Millionaire ... 

9.4 MILLl10N Americans Have Taken Control 

Of Their Lives & Futures In The Past 2 Years -

Here's The Fastest Way To Join Them! 

Save My FREE Seat For The Workshop 

Multiple Time & Date Options Available 

HURRY. We Can Only Fit 100 Attendees Per Session, and Seats Are Filling Fast! 

• 

In this Workshop+ FREE Book, you' ll learn ... 

• • Simple 5 Step System: 

The complete system 

I use to generate over $1M 

PER MONTH! 

Network of Opportunities: 

How to connect with over 100,000+ product 

owners who want you to sell their product for 

them! This Is the FASTEST path to getting 

your first sales. 

#1 Traffic Source For 

Building an Email List: 

The only traffic source you 

really need today to start 

building your email business! 

Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 7 of 27 

25. These claims are false and unsubstantiated. Defendants do not track their 

customers’ earnings, and thus do not know how their customers fare. Furthermore, Singal does 

not use this e-commerce program to generate over $1 million per month. 

26. Consumers who click on the registration link are prompted to enter their name 

and email information. They are then directed to a website that purports to have a countdown to 

the next webinar. The webinars are typically between two and three hours in length, follow a 

PowerPoint presentation, and are narrated by Singal. 

7 
In This Training, I'll Show You A Simple, Time-Tested, 

& Proven Way You Can Use To Build A $1,000/Week 

Business - And I'm Going To Give You The Entire 

System FOR FREE! 

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

27. The introductory slide for the Email Startup Incubator webinar claims that Singal 

uses this e-commerce program to “Make More Than $13,700 Per Day,” and states that the 

presentation was authored by Singal. 

28. Throughout the presentation Singal touts his success in business. For example, 

Singal claims to have generated over $250,000,000 in sales in the last 16 years. He claims that he 

made $16 million in one ten-month period, and he claims to be the principal of six different 

companies with a combined revenue of $30,000,000. Singal also claims to be a best-selling 

author, though the three books Singal claims to have written have only sold a little over a 

thousand copies and grossed less than $10,000 in revenue. 

29. Defendants falsely claim consumers can use the program to make at least $1,000 a 

week. Singal states that “minimum, [his] goal for [consumers] is to get $1,000 a day.” 

Additionally, Singal claims that he “want[s] [consumers] to get to a place where as a minimum 

[consumers] can replace their income,” and he “want[s] [consumers] to be able to replace their 

job[s]” using the program. 

8 
Time-Tested & Proven Step-By-Step System For Making 

$500+ Per Day Using Nothing But A Simple 1-Page 

Website & Email ... 

EMAIL STARTUP 

INCUBATOR 

FEATURING : i. 0 x I LAUNCH PAD I JJ 

Training - Technology - Community - Resources - Success 

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

30. Other false or unsubstantiated earnings claims include: 

 Singal will teach consumers “How To Start Making Over $400 Within 24 hours 

After This Training Is Over.” 

 Consumers who finish the webinar will receive “a copy of the simple 1-page 

website [Singal] personally use[s] to generate OVER $13,700 per day,” and 

consumers can receive access “to literally EVERYTHING [Singal] use[s] to 

generate millions each year – for FREE.” 

 Defendants claim the Email Startup Incubator is a tested, reliable, and easy way 

for consumers to make over $500 per day, as seen in the image below: 

 After displaying the image above at the webinar, Singal states: 

And honestly this slide needs to be updated because I recently . . . 

updated the goal for the students because we have so many students 

doing so well that my goal for you is $1,000 per day it’s not $500, 

$1,000 per day, because I’m seeing the results from our students 

using nothing but a simple one-page website and email. 

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31. Defendants also claim that the program allows consumers to make thousands of 

dollars while only working a few hours a week: 

 “Create A Side Business With Just A Few Hours A Week, And Turn It Into 5, 6, 

And Maybe even 7 Figures Per Year.” 

 A former student is “making 5-6 figures a week, sometimes now, working 20-30 

minutes tops.” 

32. Defendants also claim to limit the number of people who will be able to purchase 

the Email Sales Incubator and work closely with them. For example, during the webinar, Singal 

claims that Lurn must limit the number of customers because Lurn staff work with customers on 

a daily basis. Singal claims to have room only for 75 additional customers and repeatedly 

mentions the limited capacity of the program throughout the webinar. 

33. These claims are false. The webinars are prerecorded and Defendants replay them 

for months at a time. These webinars make the same claims about nearing capacity, and about 

customers needing to act quickly to secure their spots regardless of when the webinar plays and 

how many consumers have enrolled at a particular time. 

34. Throughout the webinar, Defendants present testimonials from purportedly 

successful users of the Email Startup Incubator, such as: 

 Rosalee Maquinay was able to achieve “Life-Changing Income – In Just Weeks!” 

with “ZERO Business Background or Tech Skills.” She generated over 10,000 

email leads and $360,000 in sales. Defendants then display a screenshot of a 

Facebook post from Rosalee displaying purported sales of $40,048.37 over a fourmonth period. 

 Laura Noel purportedly used the program to build a “6-Figure Business Helping 

Those in Need,” was able to retire three months after working with Defendants, 

and now makes “$10,000 - $15,000 a month” from using the program for 

Facebook advertising and list building. Defendants display a screenshot of 

$66,056.46 in purported profits. 

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 Defendants claim Dori Friend used Defendants’ e-commerce program to generate 

$925,000 in sales and sell over $1 million dollars in products in one year. 

 Andy Brackpool made $300,000 while traveling the world. According to Singal, 

Andy is “living in a very, very, nice house with his Jaguar and Aston Martin, you 

know about to marry his dream woman, living, and you know working about 

three hours a day. Doing $600,000 a year, he’s 24 years old, using the exact 

system I’ve shared with you.” 

35. These testimonials, to the extent they include any truthful earnings claims, are 

misleading. As Defendants themselves admit in poorly and briefly disclosed disclaimers that do 

not appear concurrently with the testimonials, the purported results are exceptional. 

36. Defendants’ website contains the following Earnings Disclaimer: 

Many of our products and promotions provide information about potential income 

you may earn. These representations are not intended to describe a certain outcome 

or even a typical outcome, but rather actual results from those who have had 

exceptional success. Some of these students have relevant prior experience or other 

advantages that helped them make the most of our course. Lurn offers no guarantee 

or warranty that you will realize the amount of income or revenue referenced in the 

promotions or the courses themselves. Lurn generally provides message boards and 

forums where students can share their successes but does not actively conduct 

research as to what is the typical outcome for individual offerings. 

37. Defendants also offer a disclaimer approximately 20 minutes into the webinar 

titled “The LEGAL Stuff” that states in a slide: 

 I Can’t Guarantee That You’ll Make $13,700+ Per Day Like I Do – Or Even $1. I 

simply Don’t Know Your Life And Work Habits. . . 

 This Is NOT Some “Get Rich Quick” Scheme – This Is The “Make Money The 

Smart Way” System. . . 

 My Results – And The Results Of My Students – Aren’t Typical. There Are 16 

Years Of Hard Work, Investment, And Failure Behind My Success. . . 

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38. Defendants’ disclaimers directly contradict the messages conveyed repeatedly in 

their marketing – that purchasers are likely to earn substantial income utilizing Defendants’ 

program. Defendants have no basis for their earnings claims, which are often wholly fabricated. 

Deceptive Marketing of the Kindle Cashflow University and Printable Profits Programs 

39. The types of misleading and unsubstantiated claims Defendants make to sell the 

Email Startup Incubator program are not unique. Defendants engage in similar deceptive 

practices to sell their other online courses as well. 

Kindle Cashflow University 

40. Defendants’ second most profitable course is Kindle Cashflow University, a $947 

course which Defendants claim has a total value of $8,043. The course is sold through a twohour-and-forty-minute webinar. Singal presents at the beginning and end of the webinar and the 

rest of the content is presented by Defendant Tyrone Cohen, a purported “internationally 

renowned internet marketer.” 

41. Cohen claims that he will teach a “tried, tested and proven step by step system 

that’s backed by ten plus years of teaching thousands of successful students of all backgrounds 

and ages across the planet how to make life changing money.” 

42. Cohen says that customers can get started in “less than 1 hour a week” and the 

system is “easier than you think.” 

43. Cohen instructs consumers to look for ebooks on Amazon with thousands of 

reviews, a favorable consumer rating, and a best seller ranking of 20,000 or less. Once 

consumers find a book that meets those criteria, they should emulate the content of that book to 

create their own ebook that they can sell on Amazon. 

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44. Cohen tells consumers that they only need a 10-35 page document for the ebook. 

He also advises that consumers can either write their own 10-35-page document, use an audio 

transcription service to narrate a similar book, or pay a ghostwriter $150 to write a similar book. 

Cohen advises consumers to provide the ghostwriters a copy of the book they would like to be 

emulated and to instruct the writers that they should not copy the content of the book. 

45. Once the book is created, consumers can, according to Cohen, sell it on Amazon 

and have an “evergreen” and “passive” source of income. 

46. Cohen claims that more than 10,000 people have used his program to “change 

their lives,” and “tens of thousands of my students make huge amounts of money.” During the 

webinar he displays a slide of 52 people whom he claims are making $1,000 a day using his 

system to sell ebooks on Amazon. 

47. Cohen mentions that the results he describes are not typical and will vary based 

on skill, knowledge, and experience, but he does not disclose the typical results of consumers 

who purchase this system. 

48. During the webinar, Singal claims that he has used Cohen’s system and is 

personally receiving checks from Amazon every month that pay his mortgage and car insurance. 

Singal also claims that failing to start using Cohen’s system earlier cost him $1.2 to $1.3 million 

dollars. 

49. Singal further claims that Lurn “can’t take everyone” who wants to purchase the 

program, that they will run out of space “any minute,” and he urges consumers to act quickly 

before the program reaches capacity. These false claims were made in a pre-recorded webinar 

that ran for nearly two years. 

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Printable Profits 

50. Defendants’ third most lucrative course is called Printable Profits, a $1,588 course 

which Defendants claim is worth $20,976. Consumers who click on a link in Defendants’ 

advertisements are directed to a website to sign up for a webinar. The website states that 

consumers can “Fail 98% of the Time & Still Be Able to Make $11,453 Per Month.” 

51. The website instructs consumers to watch a video in which Singal interviews 

Dave Kettner, a so-called “mugpreneur” who promotes the course. In a podcast that Singal 

instructs consumers to watch before attending the webinar, Singal claims that purchasers have a 

“very good chance at a six-figure income.” 

52. During the webinar, Kettner explains that he has a “simple easy and proven 

system” that has helped over 17,000 people start an online business. Kettner instructs consumers 

to search Amazon for mugs that have sold in high volumes. Consumers can then use an app to 

create similar designs for new mugs to sell on Amazon. Consumers can also work with a “dropshipping” company that will create the mugs and mail those directly to customers. 

53. Kettner claims that even if 98% of the designs are not successful, 2% of the mug 

designs being successful means that consumers can still make $11,453 per month based on the 

amount of overall mug sales made online. 

54. Kettner also claims to have a “tested proven system[,]” a business model with 

“almost zero risk[,]” and boasts that the $11,453 per month projection is “very conservative to be 

honest with you.” 

55. A PowerPoint slide entitled “legal stuff” states that results are not typical and will 

depend on consumers’ work ethic and motivation. It further states that Defendants “Can’t 

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promise” purchasers will make money but that they “Can promise” to show purchasers “the 

EXACT Same System [Kettner’s] Students and [Kettner] Use to Build Successful Businesses.” 

56. Viewers are instructed to use a particular third-party drop shipper to print and ship 

the mugs they sell. Lurn customers who use this drop shipper receive a discount. Data from the 

drop shipper make clear that consumers did not earn significant income through the program. 

57. Specifically, between 2019 and May 2022, Lurn sold the Printable Profits course 

to nearly 6,000 consumers. Fewer than a thousand of those consumers ordered any product from 

the drop shipper through a linked account. Of the nearly 1,000 consumers who purchased any 

products from the recommended drop shipper: 

 50% ordered 10 or fewer items; 

 90% ordered 124 or fewer items; 

 82% spent less than $1,000 on mugs; 

 98% spent less than $10,000 on mugs; 

 More than half of consumers sold products for less than 4 months; and 

 99% of consumers sold products for less than 13 months. 

Deceptive Telemarketing Practices 

58. Lurn sells expensive “consulting programs” often to consumers who have 

purchased courses, such as those described above. These programs are sold by telephone and 

over Zoom meetings. Lurn has sold programs called “Digital Business Accelerator,” “Digital 

Empire,” and “Marketplace Mastery” among others. 

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59. The consulting programs cost as much as $10,000 each. They purport to offer 

coaching sessions, access to weekly group coaching calls, and access to “forums” where 

purchasers can connect with other Lurn customers. 

60. Lurn’s telemarketers follow scripts to sell the consulting programs, and the scripts 

are consistent between the programs. Telemarketers are instructed to ask consumers about their 

current income, how much they would like to make, and how the increased income would affect 

the consumers’ lives. 

61. After the initial interview, the script directs the telemarketers to say “I’m 100% 

confident we can help you” get the results that the consumers wish for. The telemarketers are 

instructed to confirm that consumers can achieve the desired earnings regardless of the program, 

the consumer’s experience, or the amount of money the consumer hopes to attain. 

62. Consumers have frequently told Lurn’s telemarketers that they hope to earn six 

figures a year or enough to provide a full-time income. Lurn’s telemarketers have routinely 

assured consumers they are 100% confident that Lurn can help the consumers get there. 

63. These claims are false or unsubstantiated. Lurn does not track the results of 

consumers who purchase consulting programs and has no basis to claim to be 100% confident it 

can help consumers achieve any earning results, let alone six figures in annual income. 

64. In early 2021, Lurn undertook a “Sales Compliance Review” in which Lurn’s 

Compliance Manger reviewed and scored telemarketing calls for compliance, including whether 

the telemarketer made earnings claims. 

65. The Compliance Review concluded that Lurn’s telemarketers are “doing a great 

job!,” even though the calls routinely included false or unsubstantiated lavish earnings claims. 

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For example, the following statements were made on calls with three separate consumers that 

received a perfect score in the review: 

 “You obviously want to get to six figures. Even in a year or a month whatever it 

may be. You’re investing this one time to make that future investment to have the 

capability of making that in a month or at least that in a month in perpetuity. . . This 

could be the best decision you ever make in your life. It’s going to allow you to 

have a vehicle for passive income. It’s going to allow you to get away from a job 

that you don’t really like and take control of your time.” 

 A telemarketer told a consumer who hoped to earn enough income so that her 

fiancé would not need to spend six months of the year working on a boat: 

“There’s so much value to be made and obviously that growth is going to translate 

to more success and more revenue and you helping to bring your fiancé home and 

having financial freedom without the struggle and the failure.” 

 Customers who purchase the consulting program “are getting about a 73% 

accelerated rate of growth and success” compared with customers who do not 

purchase the program. When that consumer expressed concern about the interest 

payments he could face if he put the program on his credit card, the telemarketer 

responded: “[Y]ou have to ask yourself if a little bit of interest, let’s just say a 

couple hundred dollars, if that’s going to basically derail you from doing this 

program and benefitting from all of the money you’re going to make, just a little 

bit of interest, you have to tell yourself that this is a cost of doing business.” 

Lurn and Singal Have Knowingly Violated the Law 

66. On October 26, 2021, FTC staff sent a letter to Lurn via its registered agent along 

with copies of documents entitled “Notice of Penalty Offenses Concerning Money-Making 

Opportunities and Notice of Penalty Offenses Around Endorsements and Testimonials.” The 

letter and Notices identified specific acts or practices that the FTC has determined are unfair or 

deceptive under Section 5 of the FTC Act. Lurn’s registered agent received the letter and Notices 

on October 27, 2021. 

67. As detailed in the Notices enclosed with the letters, in a series of litigated 

decisions the FTC determined that it is an unfair or deceptive trade practice to make false, 

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misleading, or deceptive representations concerning the profits or earnings that may be 

anticipated by a participant in a money-making opportunity (i.e., a person who has been accepted 

or hired for, has purchased, or otherwise is engaging in the money-making opportunity). 

68. As the Notices stated, in a series of litigated decisions issued in the cases cited in 

the Notices, the FTC determined, among other things, that it is an unfair or deceptive trade 

practice to make false, misleading, or deceptive representations concerning the profits or 

earnings that may be anticipated by a participant in a money-making opportunity. The Notices 

warned Defendants of their potential liability for civil penalties under Section 5(m)(1)(B) of the 

FTC Act, 15 U.S.C. § 45(m)(1)(B), for knowingly engaging in acts or practices determined by 

the Commission to be unfair or deceptive and unlawful. The Notices stated, among other things, 

that it is an unfair or deceptive practice to: 

 “make false, misleading or deceptive representations concerning the profits or 

earnings that may be anticipated by a participant in a money-making opportunity; 

 represent, explicitly or implicitly, the earnings which may be secured by 

participants, when the representation is made without knowledge, or with only 

limited knowledge, of the actual profits or earnings usually and ordinarily 

received by participants; and 

 misrepresent, explicitly or implicitly, that sales of a money-making opportunity 

will be made to only a limited number of prospective participants. . . when sales 

will be made to any person who is willing and able to pay.” 

Nonetheless, Lurn and Singal continued to make misleading or deceptive representations after 

receiving these notices. 

69. On May 20, 2022, FTC staff sent Lurn and Singal Civil Investigative Demands 

(“CIDs”) seeking documents and information pertaining to the marketing and sale of investment 

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

FTC’s Notice of Penalty Offenses Concerning Money-Making Opportunities and Concerning 

Deceptive or Unfair Conduct around Endorsements and Testimonials. The CIDs stated that the 

FTC was investigating Lurn and related parties engaged in deceptive or unfair conduct and 

attached copies of the notices referenced above. FTC staff served the CIDs and Notices on Lurn 

through counsel on May 20, 2022. 

70. In fact, Lurn and Singal have known for years that their conduct violates the law. 

For example, as early as May 29, 2019, Singal posted an interview entitled “10 Legal Things 

Every Entrepreneur Needs to Stay Out of Trouble!” on his YouTube channel. The interview 

contained hyperlinks to Lurn’s e-commerce offers. 

71. In the interview, Singal and an attorney discussed several potential law violations, 

including “[o]verpromising the amount of earnings that people are likely to get. Giving, ugh, 

very unusual claims and holding them out as representative.” 

72. When Singal asked whether it was permissible to share success stories in 

advertising and marketing, counsel responded: “You can tell their story if you are super clear 

about how unusual it is, and the FTC is also going to want you to alongside it give an example of 

what the usual outcome is. . . ” 

73. In February 2021, before receiving the Notices, when discussing compliance with 

FTC law in the company’s Slack channel, Lurn’s Copy Chief complained about struggling to 

make testimonials and typicality claims that comply with the law. He stated that the testimonials 

used in the webinar for Printable Profits were not real, and a Lurn marketing employee added, “I 

19 
The FTC Strikes Again ... 

Operation FTC Puts Hundreds of Businesses on Notice about Fake 

Reviews and Other Misleading Endorsements 

October 13, 2021 

Notice of Penalty Offenses can trigger steep penalties for recipients who use 

endorsements to deceive consumers 

Lum Proprietary and Conf1cfent1a! J!urn" 

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

hate to say it, but typical results will suck for all programs. Typically, people don’t do anything, 

and get no results.” 

74. On December 2, 2021, after receiving the Notices, as seen in the image below, 

Lurn launched a new “Insider Alert” for one of its e-commerce programs, the Copywriting 

Academy. This alert was specifically related to the Notices the FTC had distributed in October 

2021. The alert promised to share guidance on “the recent FTC letter that went out to over 1,000 

online business. . . ” 

75. A twenty-two slide PowerPoint presentation was distributed for this Insider Alert. 

As seen in the images below, the presentation discussed compliance with the FTC Act and the 

Notices sent out earlier that year. 

20 
Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 21 of 27 

76. Lurn gave its customers extensive advice on how to market and sell their products 

without violating the FTC Act or the content of the Notices. Among other things, Lurn provided 

the following compliance advice: 

 “You cannot make any representation of potential profitability of earnings without 

any knowledge of the actual earnings or profits usually and ordinarily received by 

participants.” 

 “You cannot misrepresent, explicitly or implicitly, that the average amount of 

earnings or profit are ordinary, typical or average profits without also. . . . 

o Disclosing the # and % of participants who make these earnings. . . 

o Disclosing the earnings or profits that actually ARE typical and 

ordinary[.]” 

 “You cannot misrepresent, explicitly or implicitly, that sales will be made only to 

a limited number of participants if they are in fact made to anyone able and 

willing to pay.” 

77. Lurn also told consumers that it is, “Not enough to just label as ‘not typical’ must 

also report what are typical results,” And “Put in place a way to make it easier to track student 

results.” 

78. Notwithstanding the lengthy training on how to comply with FTC law, Lurn 

advised its customers at the end of the presentation: “Legal doesn’t sell – never simply write 

‘compliant copy.’” 

79. Despite learning of the FTC’s investigation, and despite receiving the Notices and 

even providing advice to their customers based on the Notices, Lurn and Singal have continued 

to make false or unsubstantiated earnings claims, and misleading claims, including through 

testimonials. 

21 
Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 22 of 27 

80. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission. 

VIOLATIONS OF THE FTC ACT 

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

or practices in or affecting commerce.” 

82. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

Count I – Misrepresentations Regarding Earnings 

(All Defendants) 

83. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of e-commerce programs, Defendants represent, directly or indirectly, 

expressly or by implication, that purchasers of Defendants’ programs are likely to earn 

substantial income. 

84. Defendants’ representations set forth in Paragraph 83 are false, misleading, or 

were not substantiated at the time the representations were made. 

85. Therefore, the making of the representations, as set forth in Paragraph 83 of this 

Complaint, constitutes deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a). 

VIOLATIONS OF THE TELEMARKETING SALES RULE 

86. In 1994, Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101– 

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

6108. The FTC adopted the original TSR in 1995, extensively amended it in 2003, and amended 

certain sections thereafter. 16 C.F.R. Part 310. 

87. Defendants are “seller[s]” or “telemarketer[s]” engaged in “telemarketing” as 

defined by the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg). 

88. Defendants’ goods and services, including Defendants’ trade recommendation 

services, are “Investment opportunit[ies]” as defined in the TSR, 16 C.F.R. § 310.2(s). The TSR 

defines an “Investment opportunity” as “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.” 16 C.F.R. § 310.2(s). 

89. The TSR prohibits sellers and telemarketers from “[m]isrepresenting, directly or 

by implication, in the sale of goods or services. . . [a]ny material aspect of an investment 

opportunity including, but not limited to, risk, liquidity, earnings potential, or profitability.” 16 

C.F.R. § 310.3(a)(2)(vi). 

90. The TSR prohibits sellers and telemarketers from “[m]isrepresenting, directly or 

by implication, in the sale of goods or services. . . [a]ny material aspect of the performance, 

efficacy, nature, or central characteristics of goods or services that are the subject of a sales 

offer.” 16 C.F.R. § 310.3(a)(2)(iii). 

91. The TSR prohibits sellers and telemarketers from “[m]aking a false or misleading 

statement to induce any person to pay for goods or services. . . ” 16 C.F.R. § 310.3(a)(4). 

92. The TSR applies to “[c]alls initiated by a customer or donor in response to an 

advertisement relating to investment opportunities, debt relief services, business opportunities 

other than business arrangements covered by the Franchise Rule or Business Opportunity Rule, 

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

or advertisements involving offers for goods or services described in § 310.3(a)(1)(vi) or § 

310.4(a)(2) through (4). . . ” 16 C.F.R. § 310.6(b)(5)(i). 

93. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and 

Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an 

unfair or 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 – TSR Violations 

(Lurn and Singal) 

94. In numerous instances, in connection with telemarketing, Defendants Lurn and 

Singal mispresent, directly or by implication, material aspects of investment opportunities, 

including, but not limited to the earnings potential or profitability of Defendants’ programs. 

95. Lurn and Singal’s acts and practices, as described in Paragraph 94 violate the TSR 

prohibition on misrepresenting any material aspect of an investment opportunity, 16 C.F.R. § 

310.3(a)(2)(vi). 

96. Lurn and Singal’s acts and practices, as described in Paragraph 94, also violate 

the TSR prohibition on misrepresenting any material aspect of the performance, efficacy, nature, 

or central characteristics of goods or services that are the subject of a sales offer, 16 C.F.R. § 

310.3(a)(2)(iii). 

97. Lurn and Singal’s acts and practices, as described in Paragraph 94, also violate 

the TSR prohibition on making a false or misleading statement to induce any person to pay for 

goods or services, 16 C.F.R. § 310.3(a)(4). 

24 
Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 25 of 27 

VIOLATIONS OF PRIOR COMMISSION DETERMINATIONS CONCERNING 

UNFAIR OR DECEPTIVE ACTS OR PRACTICES 

98. Pursuant to Section 5(m)(1)(B) of the FTC Act, 15 U.S.C. § 45(m)(1)(B), if the 

Commission has determined in a proceeding under Section 5(b) of the FTC Act, 15 U.S.C. § 

45(b), that an act or practice is unfair or deceptive and issued a final cease and desist order, other 

than a consent order, with respect to the act or practice, then a person, partnership, or corporation 

that engages in such act or practice with actual knowledge that such act or practice is unfair or 

deceptive and is unlawful under Section 5(a)(1) of the FTC Act shall be liable under the FTC Act 

for such relief as may be appropriate. 

99. In prior litigated decisions the Commission has determined that the acts or 

practices described in Paragraphs 67-68, above, are unfair or deceptive and violate Section 

5(a)(1) of the FTC Act and issued final cease and desist orders, other than consent orders, with 

respect to those acts or practices. 

Count III – Violations of Prior Commission Determinations Known to Defendants 

(Lurn and Singal) 

100. As set forth in Paragraphs 66 to 78, at least since receiving the letter and Notices, 

Lurn and Singal had actual knowledge that, in connection with the advertising or promotion of 

money-making opportunities, making false, misleading, or deceptive earnings claims is an unfair 

or deceptive act or practice, unlawful under Section 5(a)(1) of the FTC Act. 

101. In numerous instances, as set forth in Paragraphs 17 to 78, Lurn and Singal 

represent, directly, or indirectly, expressly or by implication, that purchasers of Defendants’ ecommerce programs are likely to make substantial profits. 

25 
 

 

Case 8:23-cv-02622-AAQ Document 1 Filed 09/27/23 Page 26 of 27 

102. In truth and in fact, in numerous instances in which Lurn and Singal made the 

representations set out in Paragraph 101, purchasers of Defendants’ e-commerce programs were 

not likely to make substantial profits. 

103. Lurn and Singal engage in the acts and practices described in Paragraphs 100 to 

101 with the actual knowledge, as set forth in Paragraph 100, that in prior litigated decisions the 

Commission has determined that the acts or practices are unfair or deceptive and violate Section 

5(a)(1) of the FTC Act and issued final cease and desist orders, other than consent orders, with 

respect to those acts or practices. 

CONSUMER INJURY 

104. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act, and the TSR. Absent injunctive relief 

by this Court, Defendants are likely to continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF

 Wherefore, Plaintiff requests that the Court: 

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

by Defendants; 

B. Grant preliminary injunctive and ancillary relief; 

C. Award monetary and other relief against Defendants Lurn and Singal in 

accordance with Section 19 of the FTC Act, 15 U.S.C. § 57b; 

D. Award any additional relief as the Court determines to be just and proper. 

26 
Respectfully submitted, 

Dated: September 27, 2023 __ ,Jf_f_J__= .. -,_,_-----·---~/9_/ 1

_-_~_·-;:_·_·· ,_·------~-­

Benjamin R. Davidson 

(202) 326-3055 I bdavidson@ftc.gov 

Joshua Doan 

(202) 326-3187 I jdoan@ftc.gov 

Ryan A. McAuliffe 

(202) 326-3044 I rrncauliffe@ftc.gov 

Federal Trade Commission 

600 Pennsylvania Ave., NW CC-6316 

Washington, DC 20580 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

27 

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