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Case 8:19-cv-01165-AG-KES Document 2 Filed 06/12/19 Page 1 of 63 Page ID #:7 

P. Connell McNulty (PA Bar No. 87966) 

(202) 326-2061 I pmcnulty@ftc.gov 

Thomas L. Harris (CA Bar. No. 266271) 

(202) 326-3620 I tharrisl@ftc.gov 

(202) 326-3395 (fax) 

600 Pennsylvania Ave., NW, CC-8528 

Washington, D.C. 20580 

D. Emily Wu (CA Bar No. 293670) 

(310) 824-4324 I ewu@ftc.gov 

(310) 824-4380 (fax) 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Local Counsel 

Attorneys for Plaintiff 

Federal Trade Commission 

UNITED STATES DISTRICT COURT 

FOR THE CENTRAL DISTRICT OF CALIFORNIA > 

Federal Trade Commission, 

Plaintiff, 

v. 

8 Figure Dream Lifestyle LLC, a 

Wyoming limited liability company, 

JL Net Bargains, Inc., a New York 

corporation, 

Kappy Enterprises, LLC, a Colorado 

limited liability company, 

Millionaire Mind Enterprises LLC, a 

Delaware limited liability company, 

Filed Under Seal 

·sACV 19 - 01165 AG (KESx) 

No. :19-CV------

COMPLAINT FOR 

PERMANENT INJUNCTION 

AND OTHER EQUITABLE 

RELIEF 
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OEA, LLC, also d/b/a Online 

Entrepreneur Academy, d/b/a 14 Day 

Champion Challenge, d/b/a 14 Day 

Challenge, an Arizona limited liability 

company, 

Spirit Consulting Group, Inc., a Texas 

corporation, 

John A. Bain, individually and as an 

officer, member, and/or manager of 8 

Figure Dream Lifestyle, LLC, 

Alex Dee, f/k/a Alex S. Dowlatshahi, 

individually and as an officer, member 

and/or manager of 8 Figure Dream 

Lifestyle LLC, Spirit Consulting Group, 

Inc., and OEA, LLC, 

Brian M. Kaplan, individually and as an 

officer, member and/or manager of 8 

Figure Dream Lifestyle LLC, Kappy 

Enterprises, LLC, Millionaire Mind 

Enterprises, LLC, and OEA, LLC, 

Jerrold S. Maurer, a/k/a Jerry Maurer, 

individually and as an officer, member 

and/or manager of 8 Figure Dream 

Lifestyle LLC, JL Net Bargains, Inc., and 

OEA, LLC, 

Defendants. 

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25 Plaintiff, the Federal Trade Commission ("FTC"), for its Complaint alleges: 

1. The FTC brings this action under Sections 13(b) and 19 ofthe Federal

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

Telemarketing and Consumer Fraud and Abuse Prevention Act ("Telemarketing 

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Act"), 15 U.S.C. §§ 6101-6108, to obtain temporary, preliminary, and permanent 

injunctive relief, rescission or reformation of contracts, restitution, the refund of 

monies paid, disgorgement of ill-gotten monies, and other equitable relief for 

Defendants' acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.

§ 45(a), and the FTC's Telemarketing Sales Rule ("TSR"), 16 C.F.R. Part 310, as 

amended. 

SUMMARY OF THE CASE 

2. Since at least January 2017, Defendants have used a combination of 

unlawful, pre-recorded telephone calls ("robocalls"), live telephone calls, text 

messaging, internet ads, emails, social media, and live events to market and sell 

fraudulent money-making opportunities to consumers under the names 8 Figure 

Dream Lifestyle or Online Entrepreneur Academy. Throughout their marketing, 

Defendants have consistently made false or unsubstantiated earnings claims. 

3. The Defendants who have promoted the 8 Figure Dream Lifestyle 

scheme have claimed that typical consumers with no prior skills or experience wil

earn $5,000 to $10,000 in 10 to 14 days, and earn $10,000 or more on a consistent

basis within 60-90 days of buying into the program. They have touted 8 Figure 

Dream Lifestyle as a "franchise-like" opportunity and told consumers that they 

need only follow Defendants' "proven business model" or "blueprint for success" 

to make money. These Defendants have made unlawful robocalls or caused others

to do so in an attempt to attract new victims to the 8 Figure Dream Lifestyle 

program. In fact, the majority of the consumers who joined 8 Figure Dream 

Lifestyle- at a cost of $2,395 to $22,495- never earned substantial income, much

less attained an "8 figure" lifestyle. They have lost their money, and many have 

incurred significant loans and credit card debt. 

4. The marketing for the Online Entrepreneur Academy programwhich Defendants Alex Dee, Brian M. Kaplan, and Jerrold S. Maurer launched in 

ovember 2018 when they announced that they had left the 8 Figure Dream 

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Lifestyle program-is no different. The Defendants who promote the program say 

that those who join it will make tens of thousands of dollars within 60 to 90 days. 

No substantiation exists for this and other similar claims used to pitch Online 

Entrepreneur Academy. In fact, an inconspicuous and purported disclaimer linked 

at the bottom of some websites contains this admission: 

While we're proud of our opportunity, it's important to understand that 

the vast majority of Members will not derive an income from [Online 

Entrepreneur Academy]. . .. Since [Online Entrepreneur Academy] has 

recently launched, it lacks enough statistical data to prepare reliable 

income disclosures . . . . 

5. Defendants are causing, have caused, and will continue to cause 

substantial injury to consumers. Defendant Dee bragged in an early 2018 

marketing video for 8 Figure Dream Lifestyle that he and Defendants Kaplan and 

Maurer had themselves received more than $6.5 million from over 500 consumers 

in less than two years, and further stated that the program as a whole had paid out 

"over $25 million in commissions" and had over 1,800 customers. When 

launching Online Entrepreneur Academy in November 2018, Defendant Dee 

claimed that 8 Figure Dream Lifestyle had paid out "close to $30 Million in 

commissions." Through the spring of 2019, Defendants have continued to profit 

from the 8 Figure Dream Lifestyle and Online Entrepreneur Academy schemes. 

JURISDICTION AND VENUE 

6. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 

§§ 1331, 1337(a), and 1345. 

7. Venue is proper in this District under 28 U.S.C. § 1391(b)(2), (b)(3), 

(c)(l), (c)(2), and (d), and 15 U.S.C. § 53.(b). 

PLAINTIFF 

8. The FTC is an independent agency of the United States Government 

created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 

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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, 15 U.S.C. 

§§ 6101-6108. Pursuant to 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. 

9. The FTC is authorized to initiate federal district court proceedings, by 

its own attorneys, to enjoin violations of the FTC Act and the TSR and to secure 

such equitable relief as may be appropriate in each case, including rescission or 

reformation of contracts, restitution, the refund of monies paid, and the 

disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b), 57b, 6102(c), and 6105(b). 

DEFENDANTS 

Corporate Defendants 

10. Defendant 8 Figure Dream Lifestyle LLC ("8 Figure Dream 

Lifestyle") is a Wyoming limited liability company with its principal place of 

business at P.O. Box 3832, Cookeville, TN 38502. Defendant John A. Bain 

("Bain") is a member and principal of 8 Figure Dream Lifestyle. Until late 2018, 

Defendants Alex Dee ("Dee"), Brian M. Kaplan ("Kaplan"), and Jerrold S. Maurer 

("Maurer") were also senior principals of 8 Figure Dream Lifestyle and held 

themselves out to the public as its "founders." 8 Figure Dream Lifestyle transacts 

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

times material to this Complaint, acting alone or in concert with others, 8 Figure 

Dream Lifestyle has advertised, marketed, distributed, or sold fraudulent moneymaking opportunities to consumers throughout the United States. 

11. Defendant JL Net Bargains, Inc. ("JL Net Bargains") is a New York 

corporation with its principal place of business at , North 

Bellmore, NY •. Defendant Maurer is the president and sole shareholder of 

JL Net Bargains. Maurer transacts or has transacted business through JL Net 

Bargains at all times material to this Complaint, and JL Net Bargains transacts or 

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

times material to this Complaint, acting alone or in concert with others, JL Net 

Bargains has advertised, marketed, distributed, or sold fraudulent money-making 

opportunities to consumers throughout the United States. 

12. Defendant Kappy Enterprises, LLC ("Kappy Enterprises") is a 

Colorado limited liability company with its principal place of business at-

, Fort Collins, CO • . Defendant Kaplan organized and is the sole 

member or a member of Kappy Enterprises. Defendant Kaplan transacts or has 

transacted business through Kappy Enterprises at all times material to this 

Complaint, and Kappy Enterprises transacts or has transacted business in this 

District and throughout the United States. At all times material to this Complaint, 

acting alone or in concert with others, Kappy Enterprises has advertised, marketed, 

distributed, or sold fraudulent money-making opportunities to consumers 

throughout the United States. 

13. Defendant Millionaire Mind Enterprises LLC ("Millionaire Mind") is 

a Delaware limited liability company with its principal place of business at-

, Fort Collins, CO • . Defendant Kaplan is a member of 

Millionaire Mind and serves as its registered agent in Colorado. Kaplan transacts 

or has transacted business through Millionaire Mind at all times material to this 

Complaint, and Millionaire Mind transacts or has transacted business in this 

District and throughout the United States. At all times material to this Complaint, 

acting alone or in concert with others, Millionaire Mind has advertised, marketed, 

distributed, or sold fraudulent money-making opportunities to consumers 

throughout the United States. 

14. Defendant OEA LLC ("OEA"), also doing business as Online 

Entrepreneur Academy, 14 Day Champion Challenge, and 14 Day Challenge, is an 

Arizona limited liability company that has identified its place of business as 4400 

N. Scottsdale Road, Suite 309, Scottsdale, AZ 85251. OEA was organized in 

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November 2018 with Defendants JL Net Bargains and Kappy Enterprises among 

its members. Amended OEA Articles of Organization filed in December 2018 

identified Defendant Kaplan as the sole member, while another amended version 

filed in January 2019 omits any reference to Defendants Kaplan, JL Net Bargains, 

and Kappy Enterprises. OEA transacts or has transacted business in this District 

and throughout the United States. At times material to this Complaint, acting alone

or in concert with others, OEA has advertised, marketed, distributed, or sold 

fraudulent money-making opportunities to consumers throughout the United 

States. 

15. Defendant Spirit Consulting Group, Inc. ("Spirit Consulting") is a 

Texas corporation that was incorporated in June 2011 by Sean Dowlatshahi, 

possibly a relative of Defendant Dee, who was formerly known as Alex S. 

Dowlatshahi. The Texas Secretary of State placed Spirit Consulting's charter in 

forfeiture status in February 2014. Spirit Consulting's last-registered business 

address was , Wylie, TX - . Despite its status in 

forfeiture, Dee transacts or has transacted business through Spirit Consulting at all 

times material to this Complaint, and Spirit Consulting transacts or has transacted 

business in this District and throughout the United States. Spirit Consulting's 

principal place of business is , Laguna Hills, CA -

, which is an address associated with Dee. At all times material to this 

Complaint, acting alone or in concert with others, Spirit Consulting has advertised, 

marketed, distributed, or sold fraudulent money-making opportunities to 

consumers throughout the United States. 

Individual Defendants 

16. Defendant Bain is a Cookeville, Tennessee resident who formed the 

LLC for Defendant 8 Figure Dream Lifestyle in February 2017. He registered the 

website 8figuredreamlifestyle.us, licensed the "digital products" included with the 

8 Figure Dream Lifestyle program, and handled key back-end administrative 

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responsibilities for operation of the program. On a December 2018 conference 

call, Bain said that he had been working on 8 Figure Dream Lifestyle "every day, 

since its inception," although his work was "mostly behind-the-scenes." During all

times material to this Complaint, acting alone or in concert with others, Bain has 

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

acts and practices of Defendant 8 Figure Dream Lifestyle set forth in this 

Complaint. Bain, in connection with the matters alleged herein regarding 8 Figure 

Dream Lifestyle, transacts or has transacted business in this District and 

throughout the United States. 

17. Defendant Dee is a resident of Laguna Hills, California. In November

2018, he obtained a decree from the Superior Court of California, County of 

Orange, changing his legal name from Alex Sarni Dowlatshahi to Alex Dee. Dee 

has held himself out to consumers as a founder and the ''Visionary" for both 8 

Figure Dream Lifestyle and Online Entrepreneur Academy. Dee has conducted 8 

Figure Dream Lifestyle and Online Entrepreneur Academy business in his personal

capacity and through Defendant Spirit Consulting. He has represented himself as 

having a "corporate" background and touted his experience as a "serial 

entrepreneur for 15 years" but has not disclosed to consumers that he is a 

recidivist. In 2011, the U.S. Securities and Exchange Commission alleged that . 

Dee and companies he controlled were part of an $8.6 million Ponzi scheme. See 

SEC v. Allen, et al., No. 3:1 l-CV-882-O (N.D. Tex.). A federal district court 

enjoined Dee and his companies from violating the Securities Act of 1933 and the 

Securities Exchange Act of 1934 and ordered them to pay more than $800,000 in 

disgorgement, civil penalties, and prejudgment interest. Id., ECF No. 252. In 

2006, the State of California Business, Transportation, and Housing Agency found 

that Dee and others illegally offered securities for a purported gold mining 

operation while making material misrepresentations, including that the operation 

could take 1,000 tons of ore a day from the primary mine site when the operation 

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did not have legal permission to mine at all. In re Desist and Refrain Order Issued

To: Owen, et al., OAH No. N2006120566 (June 27, 2006). During all times 

material to this Complaint, acting alone or in concert with others, Dee has 

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

acts and practices set forth in this Complaint. Dee resides in this District and, in 

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

this District and throughout the United States. 

18. Defendant Kaplan is a resident of Fort Collins, Colorado. Kaplan has 

held himself out to consumers as a founder of 8 Figure Dream Lifestyle who made 

a fortune developing and using the scheme's "blueprint" and now wants to help 

others because he is, he says, "in give back mode." He has also held himself out to 

consumers as a founder of Online Entrepreneur Academy. Kaplan has conducted 8

Figure Dream Lifestyle and Online Entrepreneur Academy business in his personal 

capacity and through Defendants Millionaire Mind and Kappy Enterprises. During

all times material to this Complaint, acting alone or in concert with others, I 

Kaplan 

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

the acts and practices set forth in this Complaint. Kaplan, in connection with the 

matters alleged herein, transacts or has transacted business in this District and 

throughout the United States. 

19. Defendant Maurer, also known as Jerry Maurer, is a North Bellmore, 

New York resident. Maurer has held himself out to consumers as a founder of 8 

Figure Dream Lifestyle who tried many different multi-level-marketing programs 

and online businesses but did not achieve real success until he, Dee, Kaplan, and 

Bain developed the 8 Figure Dream Lifestyle blueprint. He has also held himself 

out to consumers as a founder of Online Entrepreneur Academy. Maurer has 

conducted 8 Figure Dream Lifestyle and Online Entrepreneur Academy business in 

his personal capacity and through Defendant JL Net Bargains. During all times 

material to this Complaint, acting alone or in concert with others, Maurer has 

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

acts and practices set forth in this Complaint. Maurer, in connection with the 

matters alleged herein, transacts or has transacted business in this District and 

throughout the United States. 

COMMON ENTERPRISE 

20. From no later than January 2017 through at least November 2018, 

Defendants 8 Figure Dream Lifestyle, JL Net Bargains, Kappy Enterprises, 

Millionaire Mind, and Spirit Consulting (collectively, the "8 Figure Dream 

Lifestyle Corporate Defendants") operated as a common enterprise while engaging 

in the deceptive acts or practices and other violations oflaw alleged below. The 8 

Figure Dream Lifestyle Corporate Defendants concerted and coordinated to design,

organize, manage, market, sell, and derive revenue and profit from the 8 Figure 

Dream Lifestyle scheme. This concerted and coordinated action was reflected in 

the unified management and marketing of 8 Figure Dream Lifestyle, including the 

tracking and accounting of sales across membership groups, the regular transfer of 

revenue among the common enterprise members, the sourcing of 8 Figure Dream 

ifestyle's digital products, the negotiation of vendor contracts to support 

robocalling and other aspects of the operation, and the creation and hosting of sales 

ebinars, purported training webinars, marketing videos, and live members-only 

etworking and marketing retreats in Colorado, Miami, San Diego, and San 

rancisco. In these and other activities, the 8 Figure Dream Lifestyle Corporate 

efendants operated an interrelated network of companies that pursued and 

enefited from a shared business scheme marked by interdependent economic 

nterests. Because the 8 Figure Dream Lifestyle Corporate Defendants operated as 

common enterprise, each of them is jointly and severally liable for the acts and 

ractices of the common enterprise alleged below. Defendants Dee, Kaplan, 

aurer, and Bain ( collectively, the "8 Figure Dream Lifestyle Individual 

efendants") formulated, directed, controlled, had the authority to control, or 

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participated in the acts and practices of the 8 Figure Dream Lifestyle Corporate 

Defendants that constituted the common enterprise. The 8 Figure Dream Lifestyle 

Corporate and Individual Defendants are referred to jointly as the "8 Figure Dream 

Lifestyle Defendants." 

21. Defendants OEA, JL Net Bargains, Kappy Enterprises, Millionaire 

Mind, and Spirit Consulting ( collectively, the "Online Entrepreneur Academy 

Corporate Defendants") have operated as a common enterprise while engaging in 

the deceptive acts and practices and other violations of law alleged below. The 

Online Entrepreneur Academy Corporate Defendants have concerted and 

coordinated to design, organize, manage, market, sell, and derive revenue and 

rofit from the Online Entrepreneur Academy scheme, and have benefited from a 

shared business scheme marked by interdependent economic interests and pooled 

esources. This concerted and coordinated action is reflected in the transfer of 

evenue among the common enterprise members, the creation and use of common 

arketing materials, the registration of domain names and the purchase of privacy 

rotection for those names, and the sharing of one or more merchant accounts to 

ccept credit card payments from consumers. Additionally, some members of this 

ommon enterprise were identified as past owners of OEA in the records of the 

rizona Corporation Commission. See Paragraph 14. Because these Online 

ntrepreneur Academy Corporate Defendants have operated as a common 

nterprise., each of them is jointly and severally liable for the acts and practices of 

he common enterprise alleged below. Defendants Dee, Kaplan, and Maurer 

collectively, the "Online Entrepreneur Academy Individual Defendants") have 

ormulated, directed, controlled, had the authority to control, or participated in the 

cts and practices of the Online Entrepreneur Academy Corporate Defendants that 

onstitute the common enterprise. The Online Entrepreneur Corporate and 

ndividual Defendants are referred to jointly as the "Online Entrepreneur Academy 

efendants." 

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COMMERCE 

22. At all times material 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 

Overview of the 8 Figure Dream Lifestyle Scheme 

23. The hallmark of the 8 Figure Dream Lifestyle scheme has been false 

or unsubstantiated earnings claims--claims that consumers with no prior skills or 

experience will earn thousands or tens of thousands of dollars starting within a few

short weeks by selling the program to other consumers like themselves and 

receiving substantial "commissions" on those sales. The name of the scheme itself

raises the same empty promise, evoking the lifestyle a consumer would enjoy after 

earning more than ten million dollars. 

24. The 8 Figure Dream Lifestyle Defendants have used numerous 

marketing methods to promote their program to consumers, including robocalls. 

They have expanded their marketing reach by having consumers who have 

purchased memberships in the scheme, known as "members," engage in marketing.

To that end, the 8 Figure Dream Lifestyle Defendants have provided their members

with sales scripts and templates full of false or unsubstantiated earnings claims and 

given them access to a voice broadcasting platform for robocalling. Members have

used these tools to grow 8 Figure Dream Lifestyle's membership. 

25. The 8 Figure Dream Lifestyle Defendants have charged consumers 

membership fees ranging from $2,000 to $21,000 to join their program. They have

pressured consumers to buy into the program at the highest membership levels 

with the promise that hefty sales commission will follow. And they have 

encouraged consumers to incur substantial loans and credit card debt to purchase 

these memberships. 

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26. Additionally, consumers have needed to draw on credit and loans to 

pay 8 Figure Dream Lifestyle's administrative fees (ranging from $395 to $1,495) 

and to purchase an array of add-on products and services that the 8 Figure Dream 

Lifestyle Defendants have characterized as necessary parts of 8 Figure Dream 

Lifestyle's "proven business model" or "blueprint for success," including 

telephone dialing, texting, and email services. 

27. Behind the scenes, the 8 Figure Dream Lifestyle Defendants have 

received ill-gotten gains directly from members and from members' purchases of 

add-on products and services. While the 8 Figure Dream Lifestyle Defendants 

have profited at every step, the majority of the consumers who purchased 8 Figure 

Dream Lifestyle memberships never earned substantial income, much less attained 

an "8 Figure" lifestyle. 

8 Figure Dream Lifestyle's False Earnings Claims 

28. The 8 Figure Dream Lifestyle Defendants have used false or 

unsubstantiated earnings claims to entice consumers to spend thousands of dollars 

to become 8 Figure Dream Lifestyle members. They have widely disseminated 

such earnings claims to consumers through robocalls, live telephone calls, text 

messages, emails, prerecorded audio messages, webinars, sales videos, internet 

ads, social media, and live events. And they have enlisted and instructed new 

members to disseminate the very same earnings claims through the same marketing

channels to reach even more consumers. . 

29. The 8 Figure Dream Lifestyle Defendants typically have made their 

first contact with consumers through robocalls, emails, or text messages. Followup contacts have also been initiated through these channels as well as live 

telephone calls. 

30. The 8 Figure Dream Lifestyle Defendants' initial marketing to 

consumers has been replete with false or unsubstantiated claims about the 

substantial amounts of money that consumers should expect to earn, often 

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buttressed by claims about how quickly they will earn those amounts after 

purchasing 8 Figure Dream Lifestyle memberships. The scripts and templates the 

8 Figure Dream Lifestyle Defendants have provided to members, and members 

have used to sell program memberships, are filled with the same false or 

unsubstantiated earnings claims. 

31. Examples of these claims include: 

a. Screen capture from email sent by Defendant Dee 

about what consumers would supposedly learn in an 8

Figure Dream Lifestyle webinar: 

• The #1 reason why 85% of our members say 

they've been successful and love our business! 

(and why other systems FAIL!) 

• EXACTLY what most members are doing to 

generate five figures CONSISTENTLY within 60-90 

days, starting with only 15-20 hours a week, 

while planning their make money online business 

around their current schedules! 

b. Screen capture from email sent by Defendant Dee to 

consumers answering "most commonly asked 

questions" about 8 Figure Dream Lifestyle: 

That said, this is not a pie in the sky program! 

It's a real online business! Most of our members are able to generate five figures online 

within 60-90 days and that's what you should expect. 

c. Screen capture from template for text messages that 

the 8 Figure Dream Lifestyle Defendants provided to 

members: 

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<Prospect Name>, just left you a VM! You requested information on how to generate $5,000-

$10,000 every 10 to 14 days! Watch this short video on how we generated $931,000 in The last 

nine months in our automated "franchise like" business! 

Http:t/www.heresoroofvideo com 

PLEASE NOTE: OUR ORGANIZATION PROVIDES FUNDING!!! 

We have a free webinar tomorrow sho.ving you how you can make $13,000 in next 45 days! 

You can RSVP in the morning or afternoon for tomorrow! Which one is better for you? 

d. Another screen capture from template for text 

messages that the 8 Figure Dream Lifestyle 

Defendants provided to members: 

Are you ready lo consider gene,ati119 a 6-f9n-name tis yea? Respond back so we can 

schedule a brief cal to see f this__.. be a good it b' )IOUt-i #Fi"st Name#. You resp011ded t> my ad Sid let )'Ola- contact inro regmdng mt business. Are 

you stil looking at income oppcx11nties? 

Serious opportunity to create 5-fig-• inanle anline in llhe next 60-QO dars. let me coach you k> 

success. Details here: [YOUR BFDL FUNNEL WEB SITE) 

Oiscove,- what we do every day 10 earn 6--fiigl.WeS, ~ - can mefl1l0r you 10 do it. too: 

httpJIBfdlscreen.share.oom - text me bad when i,ou f-irli5h wai::h~. 

e. Excerpt from audio recording by Defendant Dee 

regarding the 8 Figure Dream Lifestyle program: 

"Most of our members are averaging between $5-$10,000 in 10 to 14 days." 

f. Another excerpt from audio recording by Defendant 

Dee regarding the 8 Figure Dream Lifestyle program:

This means that if you simply plug into what we teach and how we show 

you the market, for you, it literally becomes nothing more than a numbers 

game. It's that simple. Next, you'll have a system that will call those leads 

to find people interested in our opportunity. This system can call 

thousands of people each week, and it will consistently find two to three 

buyers for you per week that will put anywhere from $2,000 to $22,000 in 

your pocket each time. 

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Next, your system includes a state-of-the-art website where your interested 

buyers will go and watch a video presentation that will give them all the 

facts they need to make a relaxed and intelligent decision to join you, and 

that same website will track your business prospects' sales for you. Folks, 

we have designed this system so that 90 percent of the work is done for 

you. It's a finely tuned, time-tested system, and all you need to do is plug 

into it. In fact, our numbers show that for every 20 people who go through 

your system, on average, one will buy. And I'll say it again, each of those 

sales pay you anywhere from $2,000 to $22,000. 

g. Screen capture from scripts for live-call follow-ups 

that the 8 Figure Dream Lifestyle Defendants 

provided to members to use to register consumer 

prospects to view webinars: 

Now FIRST NAME ... By attending the on-demand presentation you're going to find out: 

1. HOW TO MAKE five to $10K every 10-14 days, 

2. How t~ get started and make $10k in your first 30 days, and 

3. How to do it all in LESS THAN 10 HOURS A WEEK part time and fire your boss in 90 days! 

32. The 8 Figure Dream Lifestyle Defendants' marketing materials have 

driven consumers to a set of webinars that usually featured Defendants Dee, 

Kaplan, and Maurer on webcams presenting PowerPoint slides. Interspersed 

within some of these webinars were video testimonials from members who talked 

about how they had made life changing money from 8 Figure Dream Lifestyle. 

33. These webinars have been a key component of the 8 Figure Dream 

Lifestyle Defendants' sales process. The 8 Figure Dream Lifestyle Defendants 

have instructed members not to attempt to close a sale until after the consumer has 

viewed one of these webinars. 

34. While the 8 Figure Dream Lifestyle Defendants created a few versions 

of the webinars, each repeated and reinforced the claim that consumers would earn 

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Case 8:19-cv-01165-AG-KES Document 2 Filed 06/12/19 Page 16 of 63 Page ID #:22 
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I substantial amounts of money to induce consumers to purchase 8 Figure Dream 

Lifestyle memberships. 

35. The following are example screen captures of earnings claims the 8 

Figure Dream Lifestyle Defendants made during the webinars: 

You are going to discover how to make over 

$10k A Month online EACH AN EVERY MONTH 

even if you don't have a product or know how 

to market & without being a techie! 

Figure I: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant Dee 

on webcam. Attached as Ex. 1. 

The 2 SECRET WEALTH STRATEGJlS to generate 

$101< A Month and do it ,n less lhan 20 hours a w<>ek ! 

#1 Automation 

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Figure 2: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant 

Kaplan on webcam. Attached as Ex. 2. 

8 Figure Dream Lifestyle• Ten Reasons Why This System Works 

1. "'-bua!Maamodelltlat'afranc:hlNlk.e•W•haveabluepftntfor 

- alraedy In plac:a 

2. Mllllllli,o-20:f"t rt "i Plr lYIMID •1t·• alfflpll.wy,uHIN WI 

ct r•r1tale -W•hll¥e-ofunllnllled1Mdalnpilee 

I. ~-llar1 °""'°'""• off In 10 "-9 A WNII IO bullet up 10 I,..... In 

- Oare' ••••••• ,, • 

4. Stts-t·r, r 1:.,......,_.1J1111D-Doll0%ot1t1e-.ti1or,.,., 

' 

Figure 3: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant 

Maurer on webcam. Attached as Ex. 3. 

Figure 4: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant 

Maurer on webcam. Attached as Ex. 4. 

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Figure 5: Screen capture of the 8 Figure Dream Lifestyle webinar depicted in 

Figures 3-4, hosted byDefendant Maurer. Attached as Ex. 5. 

Figure 6: Screen capture of the 8 Figure Dream Lifestyle webinar depicted in 

Figures 3-5, hosted by Defendant Maurer. Attached as Ex. 6. 

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Figure 7: Screen capture of the 8 Figure Dream Lifestyle webinar depicted in 

Figures 3-6, hosted by Defendant Maurer. Attached as Ex. 7. 

36. The 8 Figure Dream Lifestyle Defendants' statements reinforced the 

earnings claims displayed on consumers' screens during the webinars. For 

example, during a webinar, Defendant Dee said: 

[W]e have a proven business model. It's franchise-like. What does that 

mean? Just like McDonald's, they give you the blueprint and the strategy. 

As long as you follow it, you 're going to get the same results we have and 

hundreds of our members have had. You 're going to be able to do it. The 

blueprint for success is already in place. All you're doing is duplicating, 

following exactly the same model that we've done, okay? 

37. The earnings claims the 8 Figure Dream Lifestyle Defendants made in

these webinars were false or unsubstantiated. In fact, the majority of consumers 

who purchased 8 Figure Dream Lifestyle memberships have not earned substantial 

amounts of money. 

Marketing Targeted to Older Consumers 

38. The 8 Figure Dream Lifestyle Defendants have marketed their scheme

broadly, but they have also directly targeted older consumers who may need extra 

money for living expenses or retirement. 

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39. During one webinar, Defendant Maurer claimed 8 Figure Dream 

Lifestyle memberships were especially "good" for "retirees" because through the 

memberships they could "[m]ake sure those golden years are actually 'Golden'!": 

SO THEN WHO WOULD OUR BUSINESS 

BE GOOD FOR? 

People who want to Fire Their Boss - Use all your 

experience and skills for yourself and build your own 

dream vs. someone else's! 

Business Owners that want to Build your Ideal 

Business - Build a business that matches your 

lifestyle! No headaches of having to manage 

employees, physical products, and office! 

Retirees - Extra income - Make sure those golden 

years are actually "Golden" ! 

Figure 8: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant 

Maurer on webcam. Attached as Ex. 8. 

40. Also during a webinar, Defendant Maurer claimed that a 72-year-old 

member made $44,000 in her first seven weeks even though she had no prior 

marketing skills. 

41. Similarly, one of the template text messages that the 8 Figure Dream 

Lifestyle Defendants have provided to members for use with consumers claims that 

a 69-year-old retiree had "already made $21,500 in his first 45 days with us using 

our unlimited lead sources and simple automated system" and that a webinar will 

explain how he did it. 

Inconspicuous and Ineffectual Earnings Disclaimers 

42. Occasionally the 8 Figure Dream Lifestyle Defendants have made 

purported disclaimers, stating, for example, that results they have touted as typical 

were not in fact typical or that five figure earnings were not guaranteed. 

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Case 8:19-cv-01165-AG-KES Document 2 Filed 06/12/19 Page 21 of 63 Page ID #:27 
I 43. During one webinar, Defendant Maurer stated that his personal 

experience- making millions- was not typical. Yet, during the very same 

webinar, Maurer claimed that the "number one proof' of the 8 Figure Dream 

Lifestyle system's success was his own story. This is a rare instance in which any 

sort of disclaimer was present in an 8 Figure Dream Lifestyle webinar. 

44. More generally, and in most cases, the 8 Figure Dream Lifestyle 

Defendants have made their earnings claims in marketing materials where 

disclaimers were non-existent or buried. The 8 Figure Dream Lifestyle Defendants

have included inconspicuous links to "Terms of Service" and an ''Earnings 

Disclaimer" in small type at the bottom of some websites related to the scheme. 

The Terms of Service link has also appeared when consumers clicked a box to 

receive marketing emails as pictured below (red emphasis notations added): 

.. get everything you know about online gunis, how to~ ~ online, 

biz opps! 

a,e 7 exact reasons why people fail online! And what you need is a 

EAL "franchise llke' Onllne business to succeed! 

No BS! 

Just Straight walk through on exactly how we got the marbling, pn,ducts, 

and the most Important thing that every other model is mis.sing to get you to 

the winner's circle! 

.. UL S[ Avr M~· Sl fl. ~81'-t 

igure 9: Screen capture from alex-dee.my8figuredreamlifestyle.com. Attached as 

x. 9. 

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Figure 10: Screen capture from alex-dee.my8figuredreamlifestyle.com. Attached 

as Ex. 10. 

45. In the example directly above, the 8 Figure Dream Lifestyle website 

emphasized the claim that ordinary consumers could learn to "mak[ e] 

extraordinary income" despite having "no money, no product, no marketing skills" 

and no "technical" skills. 

46. The Terms of Service and Earnings Disclaimer documents contain 

overlapping and very similar earnings disclaimers. Below is a screenshot of the 

purported disclaimer paragraph from the Terms of Service document: 

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2. NO INCOME GUARANTEES. You agree and warrant to us that you have not been lead to believe 

{by a ny express statement or in an implied manner) that you will make a significant amount of 

money, any specific amount of money, accomplish specific financial goals, or that you will make 

more money than your purchase price. Neither 8 Figure Dream Lifestyle's representatives, nor 

its marketing materials have made any such representations at any time. You understand that 

we cannot guarantee any level of income. Your success depends entirely upon your own efforts, 

diligence, competency and on uncontrollable market factors. You have investigated the services 

and applicable law and you certify that the same do not constitute an "assisted marketing plan," 

"seller assisted marketing plan," "franchise," "investment" or "business opportunity." You agree 

that none of our training is a tax, insurance, lending, investment, or legal advice. You have 

consulted with your own legal counsel about these matters, or have at least had the opportunit) 

to do so yet chose not to. You agree that 8 Figure Dream Lifestyle is not intending to help you 

start a "new business." You understand that 8 Figure Dream Lifestyle is not willing to provide 

services to individuals who have been lead to believe they will earn significant sums of money 01 

who otherwise cannot provide the warranties above with full confidence. If any of my above 

warranties above turn out to be untrue, or if you otherwise breach this agreement in any way, 

you agree to completely indemnify, defend and hold harmless 8 Figure Dream lifestyle, and all 

of its owners, managers, employees, agents, vendors, licensees, and contractors, from and 

against any claim, demand, suit, investigation, fine, citation, judgment, cost, harm or expense, 

including also by paying the indemnified party's fines, court costs and reasonable attorney fees. 

47. As illustrated by the allegations throughout this Complaint, the Terms 

of Service have been in conflict with the marketing materials. The types of 

earnings representations outlined and purportedly disclaimed in this document 

(including that members would "make a significant amount of money" and "make 

more money than [their] purchase price") are precisely the types of representations 

that have been central to the 8 Figure Dream Lifestyle Defendants' marketing. 

Structure of the Scheme and Onboarding Process for New Members 

48. Consumers interested in purchasing memberships have learned that 

Defendants Bain, Dee, Kaplan, and Maurer created a five-tiered membership 

structure for the 8 Figure Dream Lifestyle scheme. The lowest level membership 

cost has been $2,000 plus an administrative fee of $395, while the highest level 

membership cost has been $21,000 plus an administrative fee of $1,495. The costs 

associated with the five membership levels are depicted in the table below taken 

from 8 Figure Dream Lifestyle marketing materials: 

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$3500 S6000 $12,000 $21,000 

$395 $495 $895 $945 $1495 

49. The principal difference among the membership levels has been that 

they affect the "commission" amounts that members are eligible to receive if they 

sell memberships. Members have not been eligible to receive "commissions" 

greater than their purchase price. For example, members that purchased $12,000 

memberships could not receive in excess of$12,000 on a membership sale (even 

for the sale of a $21 ,000 membership). 

50. The 8 Figure Dream Lifestyle Defendants have pressured consumers 

to purchase memberships at the highest possible levels. They have communicated 

that consumers will miss out if they join at lower levels because they will forfeit 

commission amounts above their membership purchase price, and they have 

represented that 80% of new members buy in at the $6,000 or $12,000 levels. The 

8 Figure Dream Lifestyle Defendants have encouraged prospective members to use 

8 Figure Dream Lifestyle's "Other People's Money System" and apply for loans or 

credit to fund higher-level membership purchases. Indeed, the 8 Figure Dream 

Lifestyle Defendants have claimed that "80% of [their] members get started" by 

borrowing money. 

51. New members have typically paid their membership fees to the 8 

Figure Dream Lifestyle member who closes the sale. Membership fees have been 

frequently paid by cashier's check, though payments have also been made via 

credit card, wire transfer, and other payment methods. 

52. On top of their membership fees, new members have also paid an 

administrative fee ranging from $395 to $1 ,495, as noted above. Typically, these 

administrative fees have been paid directly to Defendant 8 Figure Dream Lifestyle 

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or Defendant Bain. Bain shared administrative fees with Defendants Dee (through 

Defendant Spirit Consulting), Kaplan (through Defendant Millionaire Mind), and 

Maurer (through Defendant JL Net Bargains) prior to those Defendants 

announcing on or about November 2018 that they had left the 8 Figure Dream 

Lifestyle program. 

53. New members who have joined the 8 Figure Dream Lifestyle program 

have been instructed to undergo an "onboarding" process designed by Defendants 

Bain, Dee, Kaplan, and Maurer. 

54. The onboarding process has included having the new members 

register with a number of service providers, including: ( 1) a dialing service that 

specializes in making hundreds or thousands of robocalls simultaneously (voice 

broadcasting), (2) a text messaging service, (3) a provider of 1-800 toll-free phone 

numbers, (4) an email messaging service, (5) a website registration service, and (6) 

a marketing platform. Members have had to pay each of these providers for their 

services and tools, which they have been able to access through a members-only 8 

Figure Dream Lifestyle website called the "back office" or "dashboard." 

55. The back office area of the 8 Figure Dream Lifestyle website has also 

contained the marketing scripts and templates developed by and with the approval 

of the 8 Figure Dream Lifestyle Defendants. Use of these marketing scripts and 

templates by members has been part of the "proven business model" or "blueprint" 

of the 8 Figure Dream Lifestyle scheme. 

56. The 8 Figure Dream Lifestyle Defendants have provided these scripts 

and templates so that members stay on message and know what to say when they 

make contact with consumers. 

57. The focus of the 8 Figure Dream Lifestyle Defendants' scheme has 

been for new members to receive large commission payments by selling 8 Figure 

Dream Lifestyle memberships to other consumers. In addition, new members have 

received access and "licenses" to "digital products" of various types. As 

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Defendants Dee and Maurer have themselves acknowledged (see infra, Paragraphs

98-101), the inclusion of these digital products has been incidental to the scheme, 

and recently the products have been unavailable to members. The actual "product"

the 8 Figure Dream Lifestyle Defendants have sold to consumers is the opportunity

to market 8 Figure Dream Lifestyle memberships to other consumers and, in 

theory, receive substantial commissions. 

The 8 Figure Dream Lifestyle Defendants' Use of Robocalls 

in Violation of the TSR 

58. The 8 Figure Dream Lifestyle Defendants have relied on blasting 

illegal robocalls as their preferred marketing tool to reach consumers and have 

bolstered their sales by having their members blast such calls to millions of 

consumers. 

59. Under the TSR, robocalls are telephone calls that deliver a 

prerecorded message to induce the purchase of any good or service, and they are 

unlawful with limited exceptions. 16 C.F.R. § 310.4(b)(l)(v). 

60. The 8 Figure Dream Lifestyle Defendants have instructed their 

members to: (1) contact 8 Figure Dream Lifestyle's preferred dialer service, (2) set

up a voice broadcast account used to deliver robocalls to hundreds or thousands of

telephones simultaneously, (3) purchase a voice broadcast package, ( 4) watch 

"how to" videos on the dialer service's website, (5) complete a training session 

with one of the dialer service's certified trainers, and (6) certify that the member 

"know[s] how to run a ... Voice Broadcast Campaign." The 8 Figure Dream 

Lifestyle Defendants have instructed members to click "complete" buttons on the 

company's back office website to confirm that they have completed these steps. 

61. The 8 Figure Dream Lifestyle Defendants have strongly encouraged 

members to purchase thousands of sales leads from preferred sources for voice 

broadcast robocalling and text message marketing. They have represented these 

leads to be the best and most reliable sources for membership sales and therefore 

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lucrative commissions. And they have provided instruction and encouragement to 

members regarding loading the leads into the 8 Figure Dream Lifestyle program's 

preferred dialer service and text messaging platform. In a number of instances, the 

8 Figure Dream Lifestyle Defendants or their agents have uploaded leadspurchased by themselves or by members-into the preferred dialer service on 

behalf of members. 

62. In an audio recording of Defendant Dee's voice that has played for 

consumers who tried to reach him by phone, Dee stated: "[Y]ou'll have a system 

that will call those leads to find people interested in our opportunity. This system 

can call thousands of people each week, and it will consistently find two to three 

buyers for you per week that will put anywhere from $2,000 to $22,000 in your 

pocket each time." (Emphases added.) 

63. To further facilitate robocalling, the 8 Figure Dream Lifestyle 

Defendants have provided members with substantial assistance and support in the 

form of, among other things, prerecorded audio messages (including messages 

featuring the voice of an 8 Figure Dream Lifestyle principal), scripts, and 

templates that can be used for robocalls. 

64. At least four suits have alleged various claims under the Telephone 

Consumer Protection Act, 47 U.S.C. § 227, against one or more of the 8 Figure 

Dream Lifestyle Defendants. See Moore v. 8 Figure Dream Lifestyle LLC, et al., 

No. 1 :18-CV-2474 (N.D. Ill.); Ewing v. 8 Figure Dream Lifestyle LLC, et al., No. 

3:18-CV-1063-AJB-AGS (S.D. Cal.); Alves v. 8 Figure Dream Lifestyle LLC, No. 

2:17-CV-7970-MWF-GJS (C.D. Cal.); Perrong v. Smith, et al., 2:17-CV-3366-TJS 

(E.D. Pa.). 

65. The Moore plaintiff specifically alleged that Defendants 8 Figure 

Dream Lifestyle, JL Net Bargains, Spirit Consulting, Dee, Kaplan, and Maurer 

were liable under the TCPA for illegal robocalls. See No. 1 :18-CV-2474, ECF No. 

1, at ,r 56 (alleging that "placing prerecorded telemarketing calls" was a marketing 

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strategy for these Defendants). On notice of these serious allegations and 

seemingly unphased, the 8 Figure Dream Lifestyle Defendants continued to blast 

and/or have members blast robocalls after the initiation and settlement of Moore. 

66. Additionally, the Terms of Service document the 8 Figure Dream 

Lifestyle Defendants have posted on their website included a provision titled 

"TELEMARKETING" that states that members who used "prerecorded message 

marketing" were responsible for "fully comply[ing] with all laws and regulations, 

including ... [the] FTC's Telemarketing Sales Rule." 

The Creation of Online Entrepreneur Academy and the Relaunch of 

8 Figure Dream Lifestyle 

67. Beginning in August 2018, Defendant Dee, through Defendant 

Millionaire Mind, registered domain names now used for the Online Entrepreneur 

Academy scheme. That same month Defendant Dee, through Defendant Spirit 

Consulting, purchased domain privacy services for domain names now used for 

Online Entrepreneur Academy. 

68. On or about November 2018, Defendants Dee, Kaplan, and Maurer 

publicly abandoned the 8 Figure Dream Lifestyle scheme to launch a new 

fraudulent money-making opportunity called Online Entrepreneur Academy. 

69. On or about December 6, 2018, Defendant Bain and others still then 

associated with the 8 Figure Dream Lifestyle scheme held a conference call. The 

purpose of the call was to reassure existing 8 Figure Dream Lifestyle members that 

Defendant Bain and Defendant 8 Figure Dream Lifestyle would continue without 

Defendants Dee, Kaplan, and Maurer. In fact, Bain and the other presenters said 

they were working to relaunch an enhanced version of the 8 Figure Dream 

Lifestyle program. 

70. Defendants Dee, Kaplan, and Maurer stated in a December 2018 

webinar that existing 8 Figure Dream Lifestyle members would retain access to 

their 8 Figure Dream Lifestyle customer-relations management tools and digital 

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1 products. They said that 8 Figure Dream Lifestyle members who had questions 

about the 8 Figure Dream Lifestyle program should contact Defendant Bain. 

71. In April 2019, Defendant Bain sent 8 Figure Dream Lifestyle 

members an email with the subject line "8FDL Update . . .It's Almost Time." Bain 

stated that enhancements to 8 Figure Dream Lifestyle were ''very close to 

launching." 

72. The Online Entrepreneur Academy Defendants have tried to convince

as many 8 Figure Dream Lifestyle members as possible to join the Online 

Entrepreneur Academy scheme. They have offered them incentives, including 

reduced price and free Online Entrepreneur Academy products. 

The Online Entrepreneur Academy Scheme and Its False Earning~ Claims 

73. The first product related to the Online Entrepreneur Academy scheme 

is the 14 Day Champion Challenge or 14 Day Challenge, which is a multi-part 

onli!)e course that these Defendants claim has monetary and educational value. 

74. The Online Entrepreneur Academy Defendants intend for the 14 Day 

Champion Challenge, which costs nearly $100, to get new consumers through the 

door cheaply and onto a path to purchase upsell products that quickly become 

expensive. 

75. Below is a screen capture from an Online Entrepreneur Academy 

webinar hosted by Defendant Dee. It shows that the 14 Day Champion Challenge 

is just the first of the planned Online Entrepreneur Academy offerings. Some of 

the upsell products cost as much as $15,000. 

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--- .. ..... ·- EJll'IB'UNHIM:MINY 

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Figure 11: Screen capture from Online Entrepreneur Academy webinar. Attached 

as Ex.11. 

76. The Online Entrepreneur Academy Defendants also use the 14 Day 

Challenge as a tool to recruit new members to join the Champion Advocate 

membership tier, which is the first upsell. Those who join the Champion Advocate 

tier pay a monthly fee of nearly $100, and the Online Entrepreneur Academy 

Defendants permit and encourage them to sell Online Entrepreneur Academy 

offerings. The emphasis is on these members selling the 14 Day Challenge to new 

consumers because it is the introductory product. 

77. The Online Entrepreneur Academy Defendants claim to have their 

own marketers ( called "enrollment counselors") who sell the upsell products. 

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78. The Online Entrepreneur Academy Defendants claim that the 

Champion Advocate members will receive "commissions" and "residuals" on all 

Online Entrepreneur Academy products sold to their recruits over time (for the 

"lifetime" of each recruited client), and these amounts will grow quickly. 

79. Drawing on their experience from 8 Figure Dream Lifestyle, 

Defendants Dee, Kaplan, and Maurer, on behalf of the Online Entrepreneur 

Academy Defendants, create and disseminate marketing materials designed to 

drive consumers to webinars and sales videos during which Defendants Dee, 

Kaplan, and Maurer promote the Online Entrepreneur Academy scheme and its 14 

Day Champion Challenge. 

80. The Online Entrepreneur Academy Defendants make express earnings 

claims in their marketing. In some instances, these Defendants have repurposed 

for Online Entrepreneur Academy testimonials that they used to pitch the 8 Figure 

Dream Lifestyle program, which are laced with earnings claims. 

81. In January 2019 Defendant Dee sent an email targeting 8 Figure 

Dream Lifestyle members with the subject line: "20K in 60 Days Strategy ... are 

you coming?" The email invited recipients to attend a live webinar that would 

announce the ''NEW 20K in 60 days OEA Game Plan!!!" 

82. During a webinar designed to convince 8 Figure Dream Lifestyle 

members to join the Online Entrepreneur Academy scheme, Defendant Dee stated: 

So bottom line guys, the reason that I'm sharing this with you, is that when 

you build this out, you actually make more money and more profits where 

you guys are getting up to making 6 figures online and even higher and now 

you 're building out a monthly residual. Okay? So you can build this up to 

$6[,000), $10,000, $20,000 a month but that's residual. 

83. The Online Entrepreneur Academy Defendants also make earnings 

claims in marketing materials targeted to the public. The website 

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14daychampionchallenge.com, which promotes the 14 Day Champion Challenge, 

prominently displays the following graphic: 

.Attention onyone wonting to finolty 5tort living life on the11 term5 ... from their laptop or phone ... 

,. 

Discover the ONE THING this 

~gular guy used to create over 

·,~e 

$27,8 ~ ,ll;'. 

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Figure 12: Screen capture from 14daychampionchallenge.com. Attached as Ex. 

12. 

84. The embedded video, which is one of the principal sales videos to 

which the Online Entrepreneur Academy Defendants drive consumers, begins with

Defendant Dee standing by a pool at a luxury home that he says belongs to him. 

He asks the viewer: "How would you like to learn how to create this, on demand, 

online?" while he fans a stack of $100 bills: 

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WATCH THIS INCREDIBLE VIDEO NOW! + 

: f ,~ ~· 

Figure 13: Screen capture of embedded video from 14daychampionchallenge.com 

with Defendant Dee pictured. Attached as Ex. 13. 

85. Next, Defendant Dee cites earnings testimonials claiming that "Sean" 

made $2,174.97 in the last 7 days, "Ray'' made $40,000 in the last month, and 

"Cliff' has been making $5,000 per month. 

86. Defendant Dee says that he will show the viewer "exactly how they 

did it." He says he has taught ''the same one thing to hundreds of our students 

now, who have been making anywhere from $50,000 to $100,000 and more, and 

are able to do this from home or while they travel." 

87. Standing at a computer, Defendant Dee says: "Let me show you some 

of those students now," and he scrolls through a spreadsheet showing very large 

dollar amounts that he claims "our students" have earned, ranging from $1,212,000 

to $23,000: 

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2 WATCH THIS INCREDIBLE VIDEO NOW!+ 

$1,117,500 

I $1,071,50:01 . I $986,500 

$885,000 

$880,000 

Stan Your 1

$820.750 

4 Day Challenge In: 26:43 

Figure 14: Screen capture of embedded video from 14daychampionchallenge.com.

Attached as Ex. 14. 

88. As he scrolls through the spreadsheet, Defendant Dee says: "And 

here's the cool part, if they can do it, so can you." 

89. As with the 8 Figure Dream Lifestyle program, the Online 

Entrepreneur Academy Defendants encourage their members to purchase 

consumer leads from one or more preferred sources. They also design and make 

available marketing scripts and templates for use by members. 

90. One script provided by the Online Entrepreneur Academy Defendants

for live telephone calls promoting the 14 Day Champion Challenge instructs 

members to claim that new purchasers will make "a couple of grand online to 

start": 

Q2. How much does it cost? 

Now <firstname>, it's less than the price of a bad night out! But let me ask 

you! Are you more concerned about cost or value? Because if I showed 

you something that could make you a couple of grand online to start, you 

wouldn't mind putting $67 in, right? 

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91 . The same script instructs members to claim that "we have hundreds of 

students as you'll see when I send you the page that ha[ve] had success and if they 

can do it, so can you!" 

92. The Online Entrepreneur Academy Defendants have provided another 

script for use when pitching the 14 Day Champion Challenge to "professionals." 

The script instructs members to claim that consumers can "start making $50k-

$100,000": 

Script for a Professional: 

YOU: Hi there. What do you do? 

Professional: They tell you what they do for a living. 

YOU: I help professionals switch from working a job to 

mastering a sKill set that transitions them to part time 

online and then full time once they replace their salary! 

We have an academy that has all of these experts 

involved from lnstagram, to Facebook, to YouTube that 

can teach you at least one skill set how to start making 

$50k-$100 ,000. 

93. The Online Entrepreneur Academy Defendants' earnings claims are 

false or unsubstantiated. 

94. In fact, the Online Entrepreneur Academy Defendants have 

acknowledged that they lack substantiation for their earnings claims. A purported 

income disclaimer posted on their website states: "[ s ]ince OEA, LLC has recently 

launched, it lacks enough statistical data to prepare reliable income disclosures." 

95. The purported disclaimer also states that "[t)he average annual gross 

income for Members is projected to be between $500 and $5,000 based upon 

industry standards and company projections," although these numbers are merely 

"estimates prepared by the company pending a more detailed survey to be 

conducted after its first year," and "it's important to understand that the vast 

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majority of Members will not derive an income from the OEA, LLC." (Emphasis 

added.) 

96. Much like the 8 Figure Dream Lifestyle income disclaimer, the Online 

Entrepreneur Academy disclaimer is linked in small type at the bottom of the 

company's websites and not referenced within the Online Entrepreneur Academy 

marketing materials. 

Statements About the 8 Figure Dream Lifestyle Scheme in Marketing 

Mate.rials for the Online Entrepreneur Academy Scheme 

97. Defendants Dee, Kaplan, and Maurer have acknowledged that they 

left 8 Figure Dream Lifestyle and launched the Online Entrepreneur Academy 

scheme because they had serious concerns that the government might shut down 8 

Figure Dream Lifestyle following recent FTC actions against companies called 

MOBE and Digital Altitude. See FTC v. Mobe Ltd., et al., No. 6: 18-CV-862-ORL37DCI (M.D. Fla. 2018); FTCv. Digital Altitude LLC, et al., No. 2:18-CV-00729 

JAK (MRWx) (C.D. Cal. 2018). Those schemes pushed similar money-making 

models through false or unsubstantiated earnings claims. 

98. Indeed, Defendant Dee sent an email to 8 Figure Dream Lifestyle 

members in November 2018--days before the public announcement of Online 

Entrepreneur Academy- that directly referenced the MOBE and Digital Altitude 

shutdowns: "We had seen companies like MOBE and Digital Altitude who sell 

digital products not of high value that were empires that are no longer here!" 

Dee's email subject line was: "The gauntlet has been thrown down! And 

compliance has spoken! It's time to get ahead of the market?" 

99. During a December 2018 webinar, Defendant Dee displayed a written 

statement including the sentence: "While we don't endorse [Defendant Bain's] 

business model [for 8 Figure Dream Lifestyle], we're headed in a very different 

direction and won't be a part of it because the market has changed." 

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100. During that same webinar, Defendant Dee stated that Online 

Entrepreneur Academy's business model would differ from 8 Figure Dream 

Lifestyle's by being "Compliant friendly to establish [a] long term build" and 

having "true customers who utilize the academy vs. just recruiting members! . .. 

[T]here's a true value in the product itself." 

101. During a November or December 2018 webinar that contrasts Online 

Entrepreneur Academy with 8 Figure Dream Lifestyle, Defendant Maurer briefly 

posted a statement asking 8 Figure Dream Lifestyle members to "imagine NOT 

having to recruit to make money." 

102. In these instances the Online Entrepreneur Academy Defendants 

profess to be concerned with compliance and moving Online Entrepreneur 

Academy in a ''very different direction" than 8 Figure Dream Lifestyle. The 

reality is that little has changed besides the name. As with the 8 Figure Dream 

Lifestyle scheme, the Online Entrepreneur Academy scheme is a fraudulent 

money-making opportunity that relies on false or unsubstantiated earnings claims 

to sell memberships and pushes a recruiting-focused business model. 

Harm to Consumers 

103. Defendants have made statements that demonstrate the magnitude of 

the injury they have been inflicting on consumers. 

104. In an early 2018 webinar, Defendant Dee bragged that he and 

Defendants Kaplan and Maurer received more than $6.5 million from 547 

consumers in less than two years. He further claimed that the 8 Figure Dream 

ifestyle Defendants had paid out "over $25 million in commissions" and had over 

1,800 customers. The following is a screen capture from the webinar: 

L

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Here's What We've Done Collectively in last 2 

years - Over $25 Million in commissions paid out! 

> ' ~ 

AAodates i , 

T 0 1.i\f A 11)01.nll . S 1 '128.:XJO 

Associates 

Figure 15: Screen capture of 8 Figure Dream Lifestyle webinar with Defendant 

Dee on we beam. Attached as Ex. 15. 

105. In a November 2018 webinar promoting the Online Entrepreneur 

Academy program, Defendant Dee revised that number upward to "close to $30 

Million in commissions." The following is a screen capture from the webinar: 

How We Got to Where We're At 

• Brian, Jerry, and I - had met at another company! 

• We were responsible for close to 90% because of our systems! (common bond: helping 

members!) . 

• Each made over 7 figures! 

• Launch SFDL close to 2 years ago! 

• Started looking at companies in the space to emulate but build on top of what they were 

doing! 

• Launched our funnel system wit~ my8fdl -Jan - sales skyrocketed! 

• Started doing monthly product launches with valuable products - increase our credibility and 

value in the marketplace (What made us different than any other company out there!) 

• Had events to provide personal training and get to know our community! 

• Members having major success! 

• Created the mentors - members wanting to give back- time freedom - $30k Online! 

• Most importantly, Do date, we have paid out close to $30 Million in commissions In less than 3 

years! 

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Figure 16: Screen capture of Online Entrepreneur Academy webinar with 

Defendant Dee on webcam. Attached as Ex. 16. 

106. The "asserted" "commission" amounts likely came directly from 

consumers' payments for 8 Figure Dream Lifestyle memberships, and thus 

represent money consumers have lost after falling prey to Defendants' false or 

unsubstantiated earnings claims. Notably, the commission amounts do not account 

for harm that is resulting and has resulted from the newer Online Entrepreneur 

Academy scheme. 

107. 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 because, among other things, the 8 Figure Dream 

Lifestyle Defendants have a history of repeated fraudulent conduct and some of 

them continue to operate the 8 Figure Dream Lifestyle scheme while some of them 

left to create and operate the Online Entrepreneur Academy scheme. 

VIOLATIONS OF THE FTC ACT 

108. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits ''unfair or 

deceptive acts or practices in or affecting commerce." 

109. Misrepresentations or deceptive omissions of material fact constitute 

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

Count! 

Misrepresentations Regarding Earnings 

(All Defendants) 

110. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of their memberships or products, Defendants 

represent or have represented, directly or indirectly, expressly or by implication, 

that purchasers of their memberships or products will earn or are likely to earn 

substantial income. 

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111. Defendants' representations as set forth in Paragraph 110 are false, 

misleading, or were not substantiated at the time the representations were made. 

112. Therefore, Defendants' representations as set forth in Paragraph 110 

constitute 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 

113. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101-6108, in 1994. The FTC adopted the original Telemarketing Sales 

Rule ("TSR") in 1995, extensively amended it in 2003, and amended certain 

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

114. Under the TSR, a ''telemarketer" is any person who, in connection 

with telemarketing, initiates or receives telephone calls to or from a customer or 

donor. Id. § 310.2(ff). A "seller" means any person who, in connection with a 

telemarketing transaction, provides, offers to provide, or arranges for others to 

provide goods or services to the customer in exchange for consideration." Id. 

§ 310.2(dd). 

115. The TSR prohibits sellers and telemarketers from "[ m ]aking a false or 

misleading statement to induce any person to pay for goods or services or to induce

a charitable contribution." Id. § 310.3(a)(4). 

116. Under the TSR, an "investment opportunity" means 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." Id. § 310.2(s). 

117. 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." Id. § 310.3(a)(2)(vi). 

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118. Under the TSR, an "outbound telephone call" means a telephone call 

initiated by a telemarketer to induce the purchase of goods or services or to solicit 

a charitable contribution. Id. § 310.2(x). 

119. As amended, effective September 1, 2009, it is an abusive 

telemarketing act or practice and a violation of the TSR for a telemarketer to, or for 

a seller to cause a telemarketer to, initiate an outbound telephone call that delivers 

a prerecorded message to induce the purchase of any good or service. Id. 

§ 310.4(b )(1 )(v). Calls delivering prerecorded messages are commonly called 

"ro bocalls." 

120. It is a violation ofthe TSR for any person to provide substantial 

assistance or support to any seller or telemarketer when that person knows or 

consciously avoids knowing that the seller or telemarketer is engaged in any 

practice that violates Sections 310.3(a), (c) or (d), or 310.4 of the TSR. Id. 

§ 310.3(b). 

121. 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 

False or Misleading Statements to Induce Persons to Pay for 

Goods or Services 

(8 Figure Dream Lifestyle Defendants) 

122. In numerous instances, in connection with telemarketing and/or 

telemarketing transactions, the 8 Figure Dream Lifestyle Defendants make or have 

made false or misleading statements to induce persons to pay for 8 Figure Dream 

Lifestyle memberships or products. 

123. In numerous instances since approximately November 2018, in 

connection with telemarketing and/or telemarketing transactions, Defendant 8 

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Figure Dream Lifestyle and Defendant Bain make or have made false or 

misleading statements to induce persons to pay for 8 Figure Dream Lifestyle 

memberships or products. 

124. Defendants' acts or practices as set forth in Paragraphs 122-123 

violate 16 C.F.R. § 310.3(a)(4). 

Count III 

Misrepresentations Regarding Material Aspects of an 

Investment Opportunity 

(8 Figure Dream Lifestyle Defendants) 

125. In numerous instances, in connection with telemarketing and/or 

telemarketing transactions, the 8 Figure Dream Lifestyle Defendants misrepresent 

or have misrepresented, directly or by implication, material aspects of an 

investment opportunity, including the risk, liquidity, earnings potential, or 

profitability of 8 Figure Dream Lifestyle memberships or products. 

126. In numerous instances since approximately November 2018, in 

connection with telemarketing and/or telemarketing transactions, Defendant 8 

Figure Dream Lifestyle and Defendant Bain misrepresent or have misrepresented, 

directly or by implication, material aspects of an investment opportunity, including 

the risk, liquidity, earnings potential, or profitability of 8 Figure Dream Lifestyle 

memberships or products. 

127. Defendants' acts or practices as set forth in Paragraphs 125-126 

violate 16 C.F.R. § 310.3(a)(2)(vi). 

Count IV 

Unlawful Prerecorded Messages 

(8 Figure Dream Lifestyle Defendants) 

128. In numerous instances, in connection with telemarketing and/or 

telemarketing transactions, the 8 Figure Dream Lifestyle Defendants engage or 

have engaged in initiating or causing the initiation of outbound telephone calls that 

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delivered prerecorded messages to induce the sale of 8 Figure Dream Lifestyle 

memberships or products. 

129. In numerous instances since approximately November 2018, in 

connection with telemarketing and/or telemarketing transactions, Defendant 8 

Figure Dream Lifestyle and Defendant Bain engage or have engaged in initiating 

or causing the initiation of outbound telephone calls that delivered prerecorded 

messages to induce the sale of 8 Figure Dream Lifestyle memberships or products. 

130. Defendants' acts or practices as set forth in Paragraphs 128-129 

violate 16 C.F.R. § 310.4(b)(l)(v). 

CountV 

Assisting and Facilitating Abusive or Deceptive Telemarketing Acts 

or Practices 

(8 Figure Dream Lifestyle Defendants) 

131. In numerous instances, the 8 Figure Dream Lifestyle Defendants 

provide or have provided substantial assistance or support to sellers and/or 

telemarketers engaged in telemarketing, as defined by the TSR, 16 C.F .R. § 310.2, 

whom the 8 Figure Dream Lifestyle Defendants knew or consciously avoided 

knowing were engaged in conduct that violated TSR §§ 310.3(a)(2)(vi) 

( misrepresenting material aspects of an investment opportunity), 310 .3( a)( 4) 

(making false or misleading statements to induce persons to pay for goods or 

services), or 310.4(b)(l)(v) (initiating or causing the initiation of outbound 

telephone calls that delivered prerecorded messages). 

132. In numerous instances since approximately November 2018, 

Defendant 8 Figure Dream Lifestyle and Defendant Bain provide or have provided 

substantial assistance or support to sellers and/or telemarketers engaged in 

telemarketing, as defined by the TSR, 16 C.F.R. § 310.2, whom Defendant 8 

Figure Dream Lifestyle and Defendant Bain knew or consciously avoided knowing 

were engaged in conduct that violated TSR §§ 310.3(a)(2)(vi) (misrepresenting 

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material aspects of an investment opportunity), 310.3(a)(4) (making false or 

misleading statements to induce persons to pay for goods or services), or 

310.4(b)(l){v) (initiating or causing the initiation of outbound telephone calls that 

delivered prerecorded messages). 

133. Defendants' substantial assistance or support as set forth in 

Paragraphs 131-132 violates the TSR 16 C.F.R. § 310.3(b). 

CONSUMER INJURY 

134. 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.

In addition, Defendants have been unjustly enriched as a result of their unlawful 

acts or practices. Absent injunctive relief by this Court, Defendants are likely to 

continue to injure consumers and harm the public interest. 

THIS COURT'S POWER TO GRANT RELIEF 

135. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 

to grant injunctive and such other relief as the Court may deem appropriate to halt 

and redress violations of any provision of law enforced by the FTC. The Court, in 

the exercise of its equitable jurisdiction, may award ancillary relief, including 

rescission or reformation of contracts, restitution, the refund of monies paid, and 

the disgorgement of ill-gotten monies, to prevent and remedy any violation of any 

provision of law enforced by the FTC. 

136. Section 19 of the FTC Act, 15 U.S.C. § 57b, and Section 6(b) of the 

Telemarketing Act, 15 U.S.C. § 6105(b), authorize this Court to grant such relief 

as the Court finds necessary to redress injury to consumers resulting from 

Defendants' violations of the TSR including the rescission or reformation of 

contracts, and the refund of money. 

-45-

Case 8:19-cv-01165-AG-KES Document 2 Filed 06/12/19 Page 45 of 63 Page ID #:51 
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PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Sections 13(b) and 19 of the FTC Act,

15 U.S.C. §§ 53(b), 57b, and Section 6(b) of the Telemarketing Act, 15 U.S.C. 

§ 6105(b), and the Court's own equitable powers, requests that the Court: 

A. Award Plaintiff such preliminary injunctive and ancillary relief as 

may be necessary to avert the likelihood of consumer injury during the pendency 

of this action and to preserve the possibility of effective final relief, including 

temporary and preliminary injunctions, an order freezing assets, and appointment 

of a receiver; 

B. Enter a permanent injunction to prevent future violations of the FTC 

Act and the TSR by Defendants; 

C. Award such relief as the Court finds necessary to redress injury to 

consumers resulting from Defendants' violations of the FTC Act and the TSR, 

including rescission or reformation of contracts, restitution, the refund of monies 

paid, and the disgorgement of ill-gotten monies; and 

D. A ward Plaintiff the costs of bringing this action, as well as such other 

and additional relief as the Court may determine to be just and proper. 

Respectfully submitted, 

Dated: June 12, 2019 

P. Connell McNulty (PA Bar No. 87966) 

(202) 326-2061 I pmcnulty@ftc.gov 

Thomas L. Harris (CA Bar No. 266271) 

(202) 326-3620 I tharrisl@ftc.gov 

(202) 326-3395 (fax) 

600 Pennsylvania Ave., NW, CC-8528 

Washington, D.C. 20580 

-46-

Case 8:19-cv-01165-AG-KES Document 2 Filed 06/12/19 Page 46 of 63 Page ID #:52 
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I D. Emily Wu (CA Bar No. 293670) 

(310) 824-4324 I ewu@ftc.gov 

(310) 824-4380 (fax) 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Local Counsel 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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