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UNITED STATES DISTRICT COURT 

FOR SOUTHERN DISTRICT OF NEW YORK 

FEDERAL TRADE COMMISSION, 

Plaintiff, Case No. ;, J (!, ·~. qt.,-; 

v. STIPULATED ORDER FOR 

PERMANENT INJUNCTION, 

BRIDGE IT, INC., a corporation, also d/b/a Brigit; MONETARY JUDGMENT, AND 

OTHER RELIEF 

Defendant. 

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. The Commission 

and Defendant stipulate to the entry of this ("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. 

2. The Complaint charges that Defendant participated in deceptive and unfair acts or 

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

§ 8404, by offering its mobile application over the internet using a negative option feature and 

failing to disclose material transaction terms before obtaining consumers' billing information, 

charging consumers without consent, and failing to provide a simple method for consumers to 

cancel their monthly subscription. 

3. Defendant neither admits nor denies any of the allegations in the Complaint, 

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except as specifically stated in this Order. Only for purposes of this action, Defendant admits the 

facts necessary to establish jurisdiction. 

4. Defendant waives any claim that it 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 agrees to bear its own costs and attorney fees. 

5. Defendant 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. "Billing Information" means any data that enables any person to access a 

customer's account, such as a credit card, checking, savings, share or similar account, utility bill, 

mortgage loan account, or debit card. 

B. "Charge," "Charged," or "Charging" means any attempt to collect money or 

other consideration from a consumer, including causing Billing Information to be submitted for 

payment, including against the consumer's credit card, debit card, bank account, telephone bill, 

or other account. 

C. "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 connnunication that is solely visual or solely audible, the disclosure 

must be made through the same means through which the connnunication is presented. 

In any communication made through both visual and audible means, such as a television 

advertisement, the disclosure must be presented simultaneously in both the visual and 

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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. 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. 

D. "Defendant" means BRIDGE IT, INC., d/b/a "Brigit," and its successors and 

assigns. 

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E. "Negative Option Feature" means, in an offer or agreement to sell or provide 

any good or service, a provision under which the consumer's silence or failure to take affirmative 

action to reject a good or service or to cancel the agreement is interpreted by the seller or 

provider as acceptance or continuing acceptance of the offer. 

ORDER 

I. CLAIMS PROHIBITION 

IT IS ORDERED that Defendant, Defendant's 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 or 

offering for sale any good or service are permanently restrained and enjoined from: 

A. Misrepresenting, expressly or by implication: 

1. The amount of funds available to a consumer; 

2. When funds will be available to a consumer; 

3. Any fees, including for delivery; 

4. Consumers' ability to cancel, or obtain a refund for any charges; or 

5. 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. 

B. Making any representation, expressly or by implication, regarding the amount of 

funds available to a consumer, when funds will be available to a consumer, and the timing or 

cost of disbursement unless at the time such representation is made, Defendant possesses and 

relies upon competent and reliable evidence that is sufficient in quality and quantity to 

substantiate that the representation is true. 

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II. PROHIBITION AGAINST MISREPRESENTATIONS 

IN NEGATIVE OPTION PRODUCTS OR SERVICES 

IT IS FURTHER ORDERED that Defendant, Defendant's 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 or 

offering for sale any good or service with a Negative Option Feature, are permanently restrained 

and enjoined from misrepresenting, expressly or by implication: 

A. Any cost to the consumer to purchase, receive, use, or return the initial good or 

service; 

B. That the consumer will not be Charged for any good or service; 

C. That a good or service is offered on a "free," "trial," "sample," "bonus," "gift," 

"no obligation," "discounted" basis, or words of similar import, denoting or implying the 

absence of an obligation on the part of the recipient of the offer to affirmatively act in order to 

avoid Charges, including where a Charge will be assessed pursuant to the offer unless the 

consumer takes affirmative steps to prevent or stop such a Charge; 

D. That the consumer can obtain a good or service for a processing, service, 

shipping, handling, or administrative fee with no further obligation; 

E. Any purpose for which the consumer's Billing Information will be used; 

F. The date by which the consumer will incur any obligation or be Charged unless 

the consumer takes an affirmative action on the Negative Option Feature; 

G. That a transaction has been authorized by the consumer; 

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

repurchase policy for the good or service; or 

I. Any other material fact. 

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III. REQUIRED DISCLOSURES RELATING TO 

NEGATIVE OPTION FEATURE 

IT IS FURTHER ORDERED that Defendant, Defendant's 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 or offering for sale any good or service with a Negative Option Feature, are 

permanently restrained and enjoined from: 

A. Representing directly or indirectly, expressly or by implication, that any good or 

service that includes a Negative Option Feature is being offered on a free, trial, no obligation, 

reduced, or discounted basis, without disclosing Clearly and Conspicuously, and immediately 

adjacent to, any such representation: 

1. The extent to which the consumer must take any affirmative action to 

avoid any Charges: a) for the offered good or service, b) ofan increased amount after the 

trial or promotional period ends, and c) on a recurring basis; 

2. The total cost ( or range of costs) the consumer will be Charged and, if 

applicable, the frequency of such Charges unless the consumer timely takes steps to 

prevent or stop such Charges; and 

3. The deadline(s) (by date or frequency) by which the consumer must 

affirmatively act in order to stop all recurring Charges. 

B. Obtaining Billing Information from a consumer for any transaction involving a 

good or service that includes a Negative Option Feature, without first disclosing Clearly and 

Conspicuously, and immediately adjacent to where a consumer provides Billing Information: 

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1. The extent to which the consumer must take affirmative action to avoid 

any Charges: a) for the offered good or service, b) of an increased amount after the trial 

or promotional period ends, and c) on a recurring basis; 

2. The total cost ( or range of costs) the consumer will be Charged, the date 

the initial Charge will be submitted for payment, and, if applicable, the frequency of such 

Charges unless the consumer timely takes affirmative steps to prevent or stop such 

Charges; 

3. The deadline(s) (by date or frequency) by which the consumer must 

affirmatively act in order to stop all recurring Charges; 

4. The name of the seller or provider of the good or service and, if the name 

of the seller or provider will not appear on billing statements, the billing descriptor that 

will appear on such statements; 

5. A description of the good or service; 

6. Any Charge or cost for which the consumer is responsible in connection 

with the cancellation of an order, any service or the return of any good; 

7. The simple cancellation mechanism to stop any recurring Charges, as 

required by this Order. 

C. Failing to send the consumer: 

1. Immediately after the consumer's submission of an online order, written 

confirmation of the transaction by email. The email must Clearly and Conspicuously 

disclose all the information required by Subsection B, and contain a subject line reading 

"Order Confirmation" along with the name of the good or service, and no additional 

information; or 

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2. Within 2 days after receipt of the consumer's order by mail or telephone, a 

written confirmation of the transaction, either by email or first class mail. The email or 

letter must Clearly and Conspicuously disclose all the information required by Subsection 

B. The subject line of the email must Clearly and Conspicuously state "Order 

Confirmation" along with the name of the good or service, and nothing else. The outside 

of the envelope must Clearly and Conspicuously state "Order Confinnation" along with 

the name of the product or service, and no additional information other than the 

consumer's address, the Defendant's return address, and postage. 

IV. OBTAINING EXPRESS INFORMED CONSENT 

FOR A NEGATIVE OPTION 

IT IS FURTHER ORDERED that Defendant, Defendant's 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 or offering for sale any good or service with a Negative Option Feature, are 

permanently restrained and enjoined from using Billing Information to obtain payment from a 

consumer, unless Defendant first obtains the express informed consent of the consumer to do so. 

To obtain express informed consent, Defendant must: 

A. For all written offers (including over the Internet, such as through a web-based 

application), obtain consent through a check box, signature, or other substantially similar 

method, which the consumer must affirmatively select or sign to accept the Negative Option 

Feature, and no other portion of the offer. Defendant shall disclose Clearly and Conspicuously, 

and immediately adjacent to such check box, signature, or substantially similar method of 

affirmative consent, only the following, with no additional information: 

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1. The extent to which the consumer must take affirmative action to avoid 

any Charges: a) for the offered good or service, b) of an increased amount after the trial 

or promotional period ends, and c) on a recurring basis; 

2. The total cost ( or range of costs) the consumer will be Charged and, if 

applicable, the frequency of such Charges unless the consumer timely takes affirmative 

steps to prevent or stop such Charges; and 

3. The deadline(s) (by date or frequency) by which the consumer must 

affirmatively act in order to stop all recurring Charges. 

B. For all oral offers, prior to obtaining any Billing Information from the consumer: 

1. Clearly and Conspicuously disclose the information contained in 

Subsection B of the Section titled Required Disclosures Relating To Negative Option 

Feature; and 

2. Obtain affirmative unambiguous express oral confirmation that the 

consumer: a) consents to being Charged for any good or service, including providing, at 

a minimum, the last 4 digits of the consumer's account number to be Charged, b) 

understands that the transaction includes a Negative Option Feature, and c) understands 

the specific affirmative steps the consumer must take to prevent or stop further Charges. 

V. SIMPLE MECHANISM TO CANCEL NEGATIVE OPTION FEATURE 

IT IS FURTHER ORDERED that Defendant, Defendant's officers, agents, employees, 

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 or 

offering for sale any good or service with a Negative Option Feature, are permanently restrained 

and enjoined from: 

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A. Failing to provide a simple mechanism for the consumer to: (1) avoid being 

Charged, or Charged an increased amount, for a good or service through a Negative Option 

Feature and (2) immediately stop any recurring Charge through a Negative Option Feature. Such 

mechanism must: 

a. be easy to find; 

b. be easy to use to stop such Charge; 

c. not require the consumer to take any action that is objectively unnecessary 

to cancel, including using a user interface that has the effect of impeding consumers' 

expression of preference, manipulating consumers into taking certain action, or otherwise 

subverting consumers' choice. 

B. If any consumers entered into the agreement to purchase a good or service 

including a Negative Option Feature over the Internet or a mobile phone application, failing to 

provide the mechanism through the same website, email address or other application. 

C. If any consumers entered into the agreement to purchase a good or service 

including a Negative Option Feature through an oral offer or acceptance, failing to provide such 

mechanisms through the use of a telephone number and a postal address. 

VI. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Eighteen Million Dollars ($18,000,000) is entered in 

favor of the Commission against Defendant as monetary relief. 

B. Defendant is ordered to pay to the Commission, Eighteen Million Dollars 

($18,000,000), which, as Defendant stipulates, its undersigned counsel holds in escrow for no 

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

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

provided by a representative of the Commission. 

VII. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

A. Defendant relinquishes 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, such as a 

nondischargeability complaint in any bankruptcy case. 

C. 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. 

D. Defendant acknowledges that its Taxpayer Identification Numbers (Social 

Security Numbers or Employer Identification Numbers), which Defendant 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. 

E. All money received by the Commission pursuant to 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 (including consumer information remedies) as it 

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determines to be reasonably related to Defendant's practices alleged in the Complaint. Any 

money not used for relief is to be deposited to the U.S. Treasury. Defendant has no right to 

challenge any actions the Commission or its representatives may take pursuant to this 

Subsection. 

VIII. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendant, Defendant's officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice ofthis Order, whether acting directly or indirectly, 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, 

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

IX. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendant obtain acknowledgments ofreceipt of this 

Order: 

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

an acknowledgment ofreceipt of this Order sworn under penalty of perjury. 

B. For 5 years after entry of this Order, 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. 

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C. From each individual or entity to which Defendant delivered a copy of this Order, 

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this 

Order. 

X. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

Commission: 

A. One year after entry of this Order, Defendant must submit a compliance report, 

sworn under penalty of perjury, that: (a) identifies 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) identifies all of Defendant's 

businesses by all of their names, telephone numbers, and physical, postal, email, and Internet 

addresses; ( c) describes the activities of each business, including the goods and services offered, 

the means of advertising, marketing, and sales; ( d) describes in detail whether and how 

Defendant is in compliance with each Section of this Order; and ( e) provides a copy of each 

Order Acknowledgment obtained pursuant to this Order, unless previously submitted to the 

Commission. 

B. For 15 years after entry of this Order, Defendant must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in the following: (a) any 

designated point of contact; or (b) the structure of 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. 

C. Defendant must submit to the Commission notice of the filing of any bankruptcy 

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petition, insolvency proceeding, or similar proceeding by or against 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. Bridge It, Inc., FTC Matter No. 

2223051. 

XI. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendant must create certain records for 15 years 

after entry of the Order, and retain each such record for 5 years. Specifically, Defendant must 

create and retain the following records: 

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; 

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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. 

XII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant's compliance 

with this Order, including 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, 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 Defendant. Defendant 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 Defendant or any 

individual or entity affiliated with Defendant, 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-l. 

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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. 

'fl 

SO ORDERED this j_ day of 

I 

UNITED STμ\TES DISTRICT JUDGE 

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1.,ase 1:L.:l-CV-U~!b!Jl-ULL, uocumem .:l 1-1180 11/UL/L.:l t-'age l f OT l~ 

SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION 

'PATRICK ~~ Date; Nov. i ~D~3 ROY 

MARK GLASSMAN 

JAMES DOTY 

Attorneys 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Ave., NW 

Mailstop CC-10232 

Washington, DC 20580 

Telephone: (202) 326-3477 (Roy) 

Facsimile: (202) 326-3768 

proy@ftc.gov 

mglassman@ftc.gov 

jdoty@ftc.gov 

FOR DEFENDANT 

Allyson B. Baker 

Meredith Boylan 

Michael Marusak 

Paul Hastings LLP 

2050 M Street NW, 

Washington, DC 20036 

202-551-1830 

allysonbaker@paulhastings.com 

COUNSEL for Bridge It, Inc. 

DEFENDANT BRIDGE IT, INC. 

Date: _____ _ 

ZUBEN MATHEWS, AS AN OFFICER 

OF BRIDGE IT., INC. 

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Case 1:23-cv-09651-DLC Document 3 Filed 11/02/23 Page 18 of 19 

SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION 

Date: ------

PATRICK ROY 

MARK GLASSMAN 

JAMES DOTY 

Attorneys 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Ave., NW 

Mailstop CC-10232 

Washington, DC 20580 

Telephone: (202) 326-34 77 (Roy) 

Facsimile: (202) 326-3768 

proy@ftc.gov 

mglassman@ftc.gov 

jdoty@ftc.gov 

FOR DEFENDANT 

Date: October 18 2023 

Allyson B. Baker 

Meredith Boylan 

Michael Marusak 

Paul Hastings LLP 

2050 M Street NW, 

Washington, DC 20036 

202-551-1830 

allysonbaker@paulhastings.com 

COUNSEL for Bridge It, Inc. 

DEFENDANT BRIDGE IT, INC. 

Date: ------

ZUBEN MATHEWS, AS AN OFFICER 

OF BRIDGE IT., INC. 

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DocuSign Envelope ID: CE~1if!8i~2j1&!:\'.l~~'.!1'51:'.:~0'[)ocument 3 Filed 11/02/23 Page 19 of 19 

SO STIPULATED AND AGREED: 

FEDERAL TRADE COMMISSION 

Date: ------

PATRICK ROY 

MARK GLASSMAN 

JAMES DOTY 

Attorneys 

FEDERAL TRADE COMMISSION 

600 Pennsylvania Ave., NW 

Mailstop CC-10232 

Washington, DC 20580 

Telephone: (202) 326-3477 (Roy) 

Facsimile: (202) 326-3768 

proy@ftc.gov 

mglassman@ftc.gov 

jdoty@ftc.gov 

FOR DEFENDANT 

Date: ------

Allyson B. Baker 

Meredith Boylan 

Michael Marusak 

Paul Hastings LLP 

2050 M Street NW, 

Washington, DC 20036 

202-551-1830 

allysonbaker@paulhastings.com 

COUNSEL for Bridge It, Inc. 

DEFENDANT BRIDGE IT, INC. 

10/19/2023 

Date: ------

ZUBEN MATHEWS, AS AN OFFICER 

OF BRIDGE IT., INC. 

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