PROTECTING OLDER 

CONSUMERS 

--2018-2019 --

A Report of the Federal Trade Commission 

Federal Trade Commission I Report to Congress 

October 18, 2 019 
PROTECTING OLDER 

CONSUMERS

2018-2019

A Report of the Federal Trade Commission to Congress

October 18, 2019

FEDERAL TRADE COMMISSION

Joseph J. Simons, Chairman

Noah Joshua Phillips, Commissioner

Rohit Chopra, Commissioner

Rebecca Kelly Slaughter, Commissioner

Christine S. Wilson, Commissioner
Contents

I. Introduction ........................................................................................................................1

II. Developing Effective Strategies to Protect Older Consumers .......................................2

A. Research and Data Analysis .................................................................................................2

1. Consumer Sentinel Reports from Older Adults ....................................................................2

2. Alerting the Public About Shifting Trends and Tactics ........................................................9

3. Hearing Directly from Older Consumers About FTC Imposters .........................................10

B. Coordinated Efforts to Protect Older Consumers ................................................................11

III. FTC Enforcement Activities Affecting Older Consumers ............................................. 12

A. Fake Medical Insurance Plans .............................................................................................13

B. Tech Support .........................................................................................................................13

C. Robocall Credit Card Interest Reduction ............................................................................14

D. Business Opportunity Schemes ...........................................................................................15

E. Money Transfer System Fraud .............................................................................................15

F. Real Estate Scam ...................................................................................................................16

G. Negative Option Marketing .................................................................................................16

H. Anti-Aging/Health Claims ...................................................................................................17

I . Other Enforcement Highlights .............................................................................................18

1. Relevant Settlements .............................................................................................................18

2. Warning Letters .....................................................................................................................19

3. Consumer Monetary Relief ...................................................................................................20

4. Criminal Liaison Unit ...........................................................................................................21

IV. Outreach and Education Activities .................................................................................. 22

A. Pass it On Education Campaign ..........................................................................................22

B. Talking About Fraud Videos ................................................................................................23

C. Common Ground and Ethnic Media Events ........................................................................23

D. Other Outreach Events Relating to Older Adults ................................................................24

V. Conclusion ............................................................................................................................ 25

Appendix A: Federal Trade Commission FY 2019 ............................................................... 26
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 1

I. Introduction 

As the nation’s primary consumer protection agency, the Federal Trade Commission (“FTC” or 

“Commission”) has a broad mandate to protect consumers from unfair, deceptive, or fraudulent 

practices in the marketplace.1 It does this by, among other things, filing law enforcement actions to 

stop unlawful practices and, when possible, returning money to consumers. The FTC also protects 

the public through education and outreach on consumer protection issues. Through research and 

collaboration with federal, state, international, and private sector partners, the FTC strategically 

targets its efforts to achieve the maximum benefits for consumers, including older adults.2

Protecting older consumers in the marketplace is one of the FTC’s top priorities.3 Unfortunately, in 

numerous FTC cases, older adults have been targeted or disproportionately affected by fraud. For 

example, the FTC has brought numerous enforcement actions in federal court to stop deceptive 

technical support schemes that affected older consumers.4 As the population of older adults grows, 

the FTC’s aggressive efforts to bring law enforcement action against scams that affect them, as well 

as provide useful consumer advice, become increasingly important.5

The FTC submits this second annual report to the Committees on the Judiciary of the United States 

Senate and the United States House of Representatives to fulfill the reporting requirements of 

Section 101(c)(2) of the Elder Abuse Prevention and Prosecution Act of 2017.6 The law requires 

the FTC Chairman to file a report listing the FTC’s enforcement actions “over the preceding year 

in each case in which not less than one victim was an elder or that involved a financial scheme or 

scam that was either targeted directly toward or largely affected elders.” Given the large number of 

consumers affected in FTC actions, this list includes every administrative and federal district court 

action filed in the one-year period. Appendix A to this report lists all of the FTC’s enforcement 

1 The FTC has wide-ranging law enforcement responsibilities under the Federal Trade Commission Act, 15 U.S.C. 

§ 41 et seq., and enforces a variety of other laws ranging from the Telemarketing and Consumer Fraud and Abuse 

Prevention Act to the Fair Credit Reporting Act. In total, the Commission has enforcement or administrative

responsibilities under more than 70 laws. See http://www.ftc.gov/ogc/stats.shtm

2 This report will focus on the Bureau of Consumer Protection’s work to protect older adults. The FTC’s Bureau of 

Competition also serves older adults through its competition work in various sectors of the economy, such as health 

care, consumer products and services, technology, manufacturing, and energy.

3 This report refers to persons 60 and older when using the terms “older adults” or “older consumers” to be consistent with the requirements in Section 2(1) of the Elder Abuse Prevention and Prosecution Act, which references 

Section 2011 of the Social Security Act (42 U.S.C. 1397j(5)) (defining “elder” as an individual age 60 or older).

4 See, e.g., FTC v. Elite IT Partners, Inc., No. 2:19-cv-125 (D. Utah filed Feb. 25, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/182-3114/elite-it-partners-inc. In technical support scams, 

consumers often receive pop-up messages on their computers or telemarketing calls indicating that their computer 

is infected and in critical need of repair, followed by sham scans of their computers and requests for payments to 

“fix” the computer problem.

5 According to U.S. Census Bureau projections, by 2030 more than 20 percent of U.S. residents will be over age 65, 

compared to 13 percent in 2010 and 9.8 percent in 1970. See Sandra L. Colby and Jennifer M. Ortman, U.S. Dep’t 

of Commerce, U.S. Census Bureau, Projections of the Size and Composition of the U.S. Population: 2014 to 2060, 

March 2015, at 1, available at www.census.gov/content/dam/Census/library/publications/2015/demo/p25-1143.pdf.

6

 Public Law 115–70, 115th Congress (enacted Oct. 18, 2017).
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 2

actions over the preceding year. In addition to the list, the FTC files this report to provide detail on 

the agency’s efforts to protect older consumers, including its research and strategic initiatives, its 

law enforcement actions that noted an impact on older adults, and its targeted consumer education 

and outreach.

II. Developing Effective Strategies to Protect Older Consumers 

The FTC conducts research and analysis, publishes information about patterns and trends, and 

engages in coordinated efforts to protect older adults from financial loss and assist them with other 

consumer issues such as identity theft protection. The agency is able to spot patterns and trends 

through its data analysis and research and it works closely with stakeholders to learn about the top 

issues concerning older adults. The FTC can then use its limited resources strategically to respond 

to the needs of older consumers through enforcement, policy, education, and other initiatives.

A. Research and Data Analysis 

The FTC collects and analyzes consumer report information through its Consumer Sentinel 

Network (“Sentinel”) to inform its consumer protection mission. Sentinel is an online database that 

provides federal, state, and local law enforcement agencies with secure access to consumer reports 

on a wide variety of fraud-related topics. Law enforcement agencies and other organizations7

contribute consumer reports to the database, which is searchable by criteria such as the type of 

fraud and the name, address, and telephone number of the reported entity. Using Sentinel, the FTC 

and its law enforcement partners can analyze reports filed by older adults to look for patterns and 

trends, identify problematic business practices and enforcement targets, and develop cases against 

targets under investigation.

1. Consumer Sentinel Reports from Older Adults

During 2018, Sentinel took in nearly 3.1 million reports from consumers directly and through 

its data contributors (Fraud: 1.5 million; Identity theft: 444,383; Other: 1.2 million).8 Consumers 

reported losing nearly $1.6 billion to fraud. About 45 percent of fraud reports filed in 2018 included 

consumer age information. Consumers who said they were 60 and older (older adults) filed 256,404 

fraud reports with reported losses of nearly $400 million. 

Key findings from the 2018 data are:

• In 2018, older adults were still the least likely of any age group to report losing money to fraud, 

but their individual median dollar losses remained higher than for younger adults.

7 A list of Sentinel data contributors, including the U.S. Senate Special Committee on Aging and the AARP Fraud 

Watch Network, is located at https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors. 

8 See generally FTC, FTC Consumer Sentinel Network (July 29, 2019), available at

https://public.tableau.com/profile/federal.trade.commission. Consumer Sentinel data is self-reported and not a 

survey. As such, individuals decide whether or not to file a report. As noted below, not all consumers who file a 

report provide their age, payment method, amount of dollar loss, etc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 3

• Compared to 2017 numbers, reported median individual losses among consumers 60 and over 

increased, and the increase was particularly large for people 80 and over. 

• Older adults were much more likely than younger consumers to report losing money on tech 

support scams, prize, sweepstakes & lottery scams, and family & friend impersonation. 

• Phone scams were the most lucrative against older consumers in terms of aggregate losses, and 

online scams were a distant second.

• Gift cards became the payment of choice for scammers, but wire transfers persisted in the top spot 

for total dollars paid. 

These findings, explored more fully below, help inform the FTC’s consumer education and law 

enforcement mission.

a) Most Older Consumers Who Filed Fraud Reports Avoided Losing Any Money

Like last year, the overwhelming majority of Sentinel fraud reports filed in 2018 by consumers 60 

or older did not indicate any monetary loss. Figure 1, which controls for population size,9

 shows that 

older adults filed these no-loss reports about fraud they had spotted or encountered – but avoided 

losing money on – at nearly twice the rate of consumers ages 20-59.

Moreover, it remained true through 2018 that older adults were less likely than younger consumers 

(ages 20-59) to report losing any money to fraud. Figure 1 shows that, after controlling for population 

size, older adults were nearly 20% less likely to report losing money to fraud than consumers ages 20-59. 

This suggests that older adults may be more likely to avoid losing money when exposed to fraud, more 

inclined to report fraud when no loss has occurred, or a combination of these or other factors. Notably, 

the FTC fraud survey has also found that the rates of victimization for the various categories of frauds 

included in the survey were generally lower for those 65 and older than for younger consumers.10

9 The comparison of older adults and younger consumers is normalized against the population size of each age 

group. The analysis is based on U.S. Census Bureau data for population by age. See U.S. Census Bureau, Annual 

Estimates of the Resident Population for Selected Age Groups by Sex for the United States, States, Counties and 

Puerto Rico Commonwealth and Municipios (June 2019), available at https://factfinder.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=PEP_2018_PEPAGESEX&prodType=table. 

10 See FTC Bureau of Economics Staff Report, Consumer Fraud in the United States, 2011: The Third FTC Survey, 

at 56-59 (Apr. 2013), available at https://www.ftc.gov/reports/consumer-fraud-united-states-2011-third-ftc-survey. 
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 4

b) Older Consumers Reported Higher Median Dollar Losses in 2018 than in 2017

In 2018, the broad trend from prior years held strong: younger consumers were more likely to 

report losing money to fraud than older consumers, but older consumers who did report losing 

money, reported much higher individual losses. In addition, the median individual losses reported 

by older consumers rose significantly in 2018.

In 2018, median reported losses were fairly stable for younger adults as compared to 2017, but 

increased for older adults (Figure 2). Consumers ages 80 and older reported the largest median 

losses of $1,700 as well as the largest increase as compared to 2017. The median dollar loss for this 

80 and over age group was more than four times the median loss amount reported by consumers in 

their 20s and 30s and more than two to three times that of other age groups. This striking growth 

for people 80 and older was driven in large part by increases in reported median dollar losses 

on prize, sweepstakes and lottery scams, and family and friend imposter scams (often called the 

“grandparent scam”).11 For people ages 60-79, a surge in reports of losses to imposters posing as 

the Social Security Administration during the second half of 2018 contributed to the upward trend 

in median losses.12

11 Reported median losses by people 80+ increased 124% to $5,000 on prize, sweepstakes and lottery scams and 

39% to $5,000 on family and friend imposter scams in 2018.

12 The number of loss reports about government imposter scams by consumers ages 60-79 increased 27% in 2018, 

and reported median individual losses on government imposter scams increased 33% to $1,200 for this age group.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 5

The growth in median losses among consumers 60 and over can also be explained, in part, by 

differences in the types of fraud older adults reported more frequently than younger consumers. 

For example, median individual losses on real estate and timeshare resale frauds, both of which 

are far more likely to harm older adults, are among the highest reported in Sentinel.13 In contrast, 

median individual losses to online shopping frauds, which are more heavily reported by younger 

consumers, are among the lowest reported. However, even when median individual losses were 

compared across all frauds, older adults reported higher median losses for the vast majority of 

frauds tracked in Sentinel.

c) Older Adults Are More Likely Than Younger Consumers to Report Losing Money to Tech 

Support, Prize, Sweepstakes and Lottery, and Family and Friend Impersonation Scams 

As noted above, not all fraud reports indicate that the consumer lost money. To identify the top 

scams that had a financial effect on consumers, Figure 3 displays the top fraud categories reported 

by older consumers in which they indicated they lost any money. As shown in Figure 3, controlling 

for population size, older adults were more likely than younger consumers to report financial losses 

to certain types of frauds, but less likely to file loss reports on many other frauds. Notably, older 

13 In 2018, adjusting for population size, older adults were 381% more likely than younger consumers to report 

losing money to timeshare resale fraud, and 496% more likely to report a loss to real estate fraud (unrelated to 

timeshares). The median individual losses reported by older adults to these frauds were $6,000, $9,500, and 

$12,662 respectively.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 6

adults filed loss reports on tech support scams more frequently than on any other fraud, and were 

371% more likely to report losing money on these scams than younger consumers. The aggregate 

amount older consumers reported losing on tech support scams in 2018 was nearly $21 million. Older 

adults were also far more likely to report a loss on prize, sweepstakes and lottery scams, and family 

and friend imposter scams, but were notably less likely than younger consumers to report losing 

money to online shopping frauds, government imposter scams, and fake check scams.

An analysis of total dollars lost on these frauds presents a slightly different picture. For the frauds 

listed in Figure 3, the highest aggregate dollar losses reported were in the romance scam category, 

with older consumers reporting aggregate losses of $56 million in 2018.14 Prize, sweepstakes 

and lottery scams are next, claiming $52 million from older consumers in that time period. The 

government imposter category follows as a close third, with $50 million in aggregate dollar losses 

reported. The losses on government imposter scams are an exemplar of the broader theme observed 

at the opening of this section—older consumers are less likely to report losing money to government 

imposter scams than younger consumers are.15 When they do lose money, however, older consumers 

lose a lot more than younger consumers.

d) Phone Scams Were Most Lucrative Against Older Consumers

Phone scams continue to be a tremendous problem for consumers of all ages. Older adults reported 

that a phone call was the initial contact method in numbers four times higher than all other contact 

methods combined (see Figure 4). This high rate of phone fraud reporting was driven largely by 

14 See FTC Consumer Protection Data Spotlight, Romance scams rank number one on total reported losses (Feb. 12, 

2019), available at https://www.ftc.gov/news-events/blogs/data-spotlight/2019/02/romance-scams-rank-numberone-total-reported-losses.

15 In 2018, adjusting for population size, aggregate reported losses on government imposter scams were about 

twice as high for older adults as for younger consumers. Reported median individual dollar losses on government 

imposter scams were $1,374 for older adults and $800 for younger consumers.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 7

reported calls from government imposters, particularly Social Security Administration imposters.16

However, as the teal bars show in Figure 4, when reports with no monetary losses are excluded, 

the disparity in reporting levels between phone and other contact methods is far less pronounced.

Consumers 80 and over filed more loss reports about calls from family and friend imposters than 

other phone frauds, while consumers ages 60-79 most often reported losing money on phone calls 

from tech support scammers. Tech support scams, which can start with an alarming browser pop-up 

message rather than a phone call, were also the top online fraud reported by older adults.

e) Gift Cards Are Becoming Payment Method of Choice for Scammers, but Wire Transfers 

Persist in the Top Spot for Total Dollars Paid

Consumers reporting fraud frequently indicate what payment method they used, and this 

information helps the FTC identify opportunities for enforcement and consumer education. The 

first column in Figure 5 shows that older adults most often reported paying fraudsters with a 

credit card, gift or reload card, or wire transfer in 2018. The second column in Figure 5 shows the 

aggregate dollar losses that older adults reported for the payment methods shown. During the 

course of 2018, the number of older adults who said they paid with gift cards or reload cards 

16 See FTC Consumer Protection Data Spotlight, Growing Wave of Social Security Imposters Overtakes IRS Scam 

(Apr. 12, 2019), available at https://www.ftc.gov/news-events/blogs/data-spotlight/2019/04/growing-wave-social-security- imposters-overtakes-irs-scam.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 8

increased dramatically.17 In fact, during the second half of 2018 (and continuing into 2019), 

gift and reload cards were the most frequently reported payment method by older adults, even 

for tech support scams. This is a sharp reversal from 2017 trends, which indicated tech support 

scammers typically demanded payment with credit cards. This is a concerning trend as gift and 

reload cards offer virtually no fraud protections for consumers. Credit cards offer the strongest 

fraud protections for consumers.

As in 2017, older adults reported sending more money to fraudsters by wire transfer than by any 

other method, and wire transfers sent in connection with romance scams and prize, sweepstakes, 

and lottery scams were drivers of this trend. In fact, consumers in their 60s reported far higher 

aggregate losses on romance scams than on any other fraud in 2018, and the vast majority 

of those dollars were sent by wire transfer. Wire transfers were also the top payment method 

on prize, sweepstakes and lottery frauds, which had the highest aggregate reported losses for 

people 70 and older. While cash or cash advance remained a relatively uncommon payment 

method, extremely high median losses by older adults who mailed cash for grandparent scams 

(i.e., family/friend imposter scams) in 2018 contributed to total losses that exceeded some more 

frequently used payment methods.18 These findings are important as a wire transfer, gift card 

purchase, or large cash withdrawal will typically involve an in-person interaction with a business 

in the consumer’s community. Recent research has shown that these front line businesses can 

make a substantial difference in helping consumers to avoid losing money.19 More specifically, 

over fifty percent of consumers who reported an intervention by a third party during a scam in 

progress avoided a loss.20 This is notable given that these interventions are likely to occur at 

a stage when the consumer is heavily under the influence of the scammer and on the cusp of 

sending money.

17 The number of loss reports made directly to the FTC by older adults indicating gift or reload cards as the method 

of payment increased by 85% in 2018. The rise of gift cards as payment for scams was explored in a Consumer 

Protection Data Spotlight. See FTC Consumer Protection Data Spotlight, Scammers increasingly demand payment 

by gift card (Oct. 16, 2018), available at https://www.ftc.gov/news-events/blogs/data-spotlight/2018/10/scammers-increasingly-demand-payment-gift-card.

18 A Consumer Protection Data Spotlight described an increase in people 70+ mailing cash on grandparent scams. 

The median cash amount sent was $9,000. See FTC Consumer Protection Data Spotlight, New twist to grandparent scam: mail cash (Dec. 3, 2018), available at https://www.ftc.gov/news-events/blogs/data-spotlight/2018/12/

new-twist-grandparent-scam-mail-cash. 

19 The study involved a survey of respondents who had reported a scam. Among those survey respondents, 20% 

reported a third-party intervention or attempted intervention. Of those, 51% said that they did not lose money. By 

contrast, survey respondents who said they engaged with a scammer were also significantly more likely to report 

losing money if they had not talked to anyone while it was happening. See FINRA Investor Education Foundation, 

BBB Institute for Marketplace Trust, & Stanford Center on Longevity, Exposed to Scams: What Separates Victims 

from Non-Victims? at 9, 12 (Sept. 2019) available at

https://www.finrafoundation.org/sites/finrafoundation/files/exposed-to-scams-what-separates-victims-from-nonvictims_0_0.pdf.

20 Id.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 9

The FTC monitors Sentinel data for these and other important trends to inform its strategies for 

protecting older adults. Significant improvements to the Sentinel system have contributed to the 

agency’s efforts to identify enforcement targets strategically and enhance the agency’s education 

messages. Outreach efforts with stakeholders, described below, further improve the system by 

increasing the number of reports from consumers. The FTC has also worked to increase the 

number of data contributors providing reports to Sentinel, and was pleased to welcome the 

Microsoft Corporation Cyber Crime Center in 2018, adding thousands of reports about tech 

support scams to the Sentinel database.

2. Alerting the Public About Shifting Trends and 

Tactics

The FTC made aggregate consumer reporting data 

more accessible in 2018 by publishing Sentinel 

data on a quarterly basis in a new interactive online 

format.21 Previously, aggregate Sentinel data were 

released only in the FTC’s annual Consumer Sentinel 

Network Data Book. This engaging new tool, 

available at www.ftc.gov/exploredata, provides a 

more timely snapshot of what consumers are reporting 

and empowers users to explore data by fraud type, contact or payment method, and a variety 

of other dimensions. Users can track trends over time or click on interactive maps to see what 

consumers are reporting in their area. Dashboards showing data by consumer age enable users to 

explore age-related trends and differences 

in losses and reporting levels by age. By 

making Sentinel data more accessible, 

the FTC hopes to encourage reporting 

and to promote data-driven outreach by 

the media, government agencies, and 

consumer groups to help the public spot 

and avoid fraud. 

The FTC also launched the Consumer 

Protection Data Spotlight publication in 

the fall of 2018 to illuminate emerging 

trends in the data and important stories 

the agency is hearing from consumers. 

The Spotlight has regularly highlighted 

differences in how fraud affects older 

adults, particularly the much higher median losses reported on a variety of frauds. One Spotlight

told the story of older adults mailing thousands of dollars in cash to scammers posing as their 

21 Interactive Sentinel dashboards are hosted on the Tableau Public website and can be accessed from

www.ftc.gov/exploredata.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 10

grandchildren.22 The Spotlight noted that people 70 and older who sent cash to these kinds of 

scammers, reported median individual losses of $9,000. Another Spotlight highlighted the vastly 

disproportionate harm Sentinel data suggest tech support scams are causing older adults.23 As 

stated in the Spotlight, in 2018, people 60 and older were about five times more likely to report 

losing money to tech support scams than younger people. The data stories and consumer tips 

highlighted in the Spotlight have reached millions of consumers through coverage by both local 

and national news programs, network morning shows, syndicated news columns, and through the 

agency’s own outreach channels.

3. Hearing Directly from Older Consumers About FTC Imposters

Imposter scams were the top type of scam reported to the FTC in 2018. In particular, reports 

about scammers impersonating the government (often the Internal Revenue Service or the Social 

Security Administration) have risen to the top of the list. The FTC has also been impersonated 

through the years.24

To better understand imposter scams, this year, the FTC directly engaged with older consumers 

who reported losing money to scammers pretending to be FTC staff. Between July 1, 2018 and 

June 30, 2019, more than 100 consumers aged 60+ reported to the FTC that they lost more than 

$1,000 to FTC impersonators. Most of these people reported that the scammers told them they 

had won prizes, money, or grants, and the FTC would distribute the benefits once the consumers 

paid fees. FTC staff spoke to the majority of these complainants to clarify that the FTC does not 

distribute prizes, money or grants, and provided additional information to the consumers about 

government imposter scams as needed.

Several key takeaways came from talking with these consumers about their experiences. First, 

and not surprisingly, the fact that the scammers presented themselves as representing a federal 

agency made a difference in how the consumers reacted. The consumers said they believed they 

were less likely to be scammed by a person from a government source as opposed to a company. 

Some scammers went to great lengths, making up details about the FTC, to make themselves 

seem authentic. Second, even after conversation with real FTC staff, many of these consumers 

still wondered whether the person who had called them was, in fact, an FTC employee. Further 

conversation was required in many cases to help them understand that the calls – and the 

information the scammer had provided – were false. Third, consumers reported that these types 

of scams were often a long, drawn out process. In numerous instances, the scammers contacted 

the consumers daily, building relationships and creating trust. Frequently, large money losses 

occurred through multiple contacts over the course of weeks or months.

22 See FTC Consumer Protection Data Spotlight, New twist to grandparent scam: mail cash (Dec. 3, 2018), available 

at https://www.ftc.gov/news-events/blogs/data-spotlight/2018/12/new-twist-grandparent-scam-mail-cash. 

23 See FTC Consumer Protection Data Spotlight, Older adults hardest hit by tech support scams (Mar. 7, 2019), available 

at https://www.ftc.gov/news-events/blogs/data-spotlight/2019/03/older-adults-hardest-hit-tech-support-scams.

24 See, e.g., Consumer Alert, FTC, No prizes from the FTC (June 22, 2018) available at

https://www.consumer.ftc.gov/blog/2018/06/no-prizes-ftc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 11

While the economic impact of losing large amounts of money varied from difficult to 

devastating, the consumers reported feeling a sense of embarrassment and shame at having been 

scammed. Many reported feeling a loss to their self-image as competent people with a lifetime 

of experience that would help them avoid being fooled. Some reported seeing this as proof that 

they were now too old to be handling their own money. This type of self-doubt was alarming to 

numerous consumers, and independent of the monetary loss they also suffered.

The special outreach to this group of older consumers has not only helped the agency deliver 

consumer education more directly, it has also improved our understanding of how these scams 

unfold. The insights gained from these conversations will continue to inform how the FTC works to 

combat government imposter fraud.

B. Coordinated Efforts to Protect Older Consumers

The FTC’s Every Community Initiative leads the agency’s strategic planning for the protection of 

older consumers. Understanding that different types of frauds affect different groups of consumers, 

the Initiative examines the impact of different schemes on different groups of consumers, including 

older adults, military service members and veterans, African Americans, Latinos, Asian Americans, 

Native Americans, and other groups. The Initiative includes staff throughout the Bureau of 

Consumer Protection and the FTC’s regional offices who use research and input from stakeholders in 

communities to develop strategies to prevent fraud, inform the agency’s law enforcement program, 

and expand outreach to such communities. As discussed further in Section IV, these partnerships 

across the country have been extremely valuable as the FTC identifies potential cases and further 

develops strategies to protect older adults in a wide range of communities from financial loss.

The FTC continues to coordinate with federal, state, and international law enforcement agencies, 

including those with criminal authority, leveraging resources to track down fraudsters and build 

actions to stop them. With the Department of Justice (“DOJ”), the FTC organizes and participates 

in the International Mass Marketing Fraud Working Group, a multilateral network of agencies 

that enforces laws prohibiting mass marketing fraud. The Working Group has been pivotal in 

enforcement actions against entities that have allegedly defrauded millions of older consumers out 

of hundreds of millions of dollars. In March 2019, the FTC, the DOJ, the U.S. Postal Inspection 

Service, and a number of other domestic and foreign law enforcement partners announced civil and 

criminal actions against a host of defendants.25

Further, the FTC has continued to be an active member of the Elder Justice Coordinating Council, 

a multi-agency federal entity charged with identifying and proposing solutions to elder abuse, 

neglect, and financial exploitation. Part of the Council’s mission is to develop recommendations 

to the Secretary of the Department of Health and Human Services (“DHHS”) for the coordination 

25 Press Release, U.S. Dept. of Justice, Justice Department Coordinates Largest-Ever Nationwide Elder Fraud 

Sweep (March 7, 2019), available at https://www.justice.gov/opa/pr/justice-department-coordinates-largest-evernationwide-elder-fraud-sweep-0. As part of this effort, the FTC filed an action seeking to shut down a technical 

support scheme that affected elderly consumers. FTC v. Elite IT Partners, Inc., No. 19-cv-00125-RJS (D. Utah 

Feb. Feb. 25, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/03/ftc-halts-tech-supportscam-part-major-initiative-focused-older.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 12

of relevant activities.26 FTC staff serve on the Council’s working group and subcommittees. Staff 

also presented information about the FTC’s work to protect older consumers at the DOJ’s 

Rural and Tribal Elder Justice Summit in Des Moines, Iowa, in November 201827. This work 

connects the agency with other federal government offices that are working to combat elder 

abuse and facilitates information sharing and coordination. 

III. FTC Enforcement Activities Affecting Older Consumers 

Aggressive law enforcement is a key component in the FTC’s efforts to protect older 

consumers.28Congress has directed the FTC to list “each case in which not less than one 

victim was an elder or that involved a financial scheme or scam that was either targeted 

directly toward or largely affected elders.” 29 Most FTC enforcement actions involve numerous 

consumers of all ages. Further, the ages of consumers affected are not typically known. 

Therefore, Appendix A to this report lists all new enforcement actions brought by the FTC (or 

by the DOJ on the FTC’s behalf) between October 1, 2018, and September 30, 2019. Based 

upon our law enforcement experience, the Commission is of the view that people ages 60 

or older are in the groups of affected consumers in almost every consumer protection case 

filed. The 66 cases listed in Appendix A involve a wide range of matters, including alleged 

business opportunity and money-making schemes, deceptive health product advertising claims, 

deceptive negative option schemes, data security and privacy violations, charity frauds, scams 

directed at small business owners, and more.30

To provide a better description of the FTC’s work to protect older consumers, the next section 

summarizes ten enforcement actions filed within the last fiscal year where the Commission 

notes a significant impact on older consumers. Also listed are additional agency actions — 

including settlements, warning letters, issuance of consumer refunds, and subsequent criminal 

26 DHHS convened the Elder Justice Coordinating Council in accordance with the Elder Justice Act of 2009. The 

Council consists of heads of federal departments and other government entities, including the FTC, identified as 

having responsibilities, or administering programs, relating to elder abuse, neglect, and exploitation. See DHHS, 

What is the Elder Justice Coordinating Council? (last modified Mar. 29, 2019), available at https://www.acl.gov/

programs/elder-justice/elder-justice-coordinating-council-ejcc.

27 Press Release, U.S. Department of Justice, Justice Department, Department of Agriculture Host Inaugural Rural 

and Tribal Elder Justice Summit (Nov. 14, 2018) available at https://www.justice.gov/opa/pr/justice-department-department-agriculture-host-inaugural-rural-and-tribal-elder-justice. 

28 When staff identifies unfair or deceptive acts or practices that harm consumers, the FTC often sues the fraudsters 

in federal district court, seeking injunctive relief to stop illegal business practices as well as monetary relief in 

the form of redress for consumers or disgorgement of ill-gotten gains. The agency can also bring cases through 

administrative process. In some circumstances, the Department of Justice files cases on the FTC’s behalf for rule 

violations or to secure civil penalties for violations of FTC administrative orders.

29 The Elder Abuse Prevention and Prosecution Act, PUBLIC LAW 115–70, Oct. 18, 2017. Sec. 101(c)(2).

30 This list includes cases involving student loan debt relief schemes and violations of children’s privacy laws. The 

perpetrators of such schemes may not typically target older adults, but the cases are listed because they involve 

large and diverse groups of consumers. The affected consumers are likely to include an older adult paying off 

student debt for him or herself or for an adult child, or an older parent or grandparent caring for children who go 

online and wish to protect the child’s privacy.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 13

action by other agencies relating to FTC matters — that affected older consumers. These 

actions illustrate some of the key consumer issues that disproportionately affect older adults.

A. Fake Medical Insurance Plans

In Simple Health Plans, LLC,31 the FTC alleged that the defendants falsely claimed to be 

selling a variety of comprehensive healthcare plans. The defendants falsely held themselves 

out as experts on and providers of government-sponsored health insurance policies, including 

Medicare. The defendants’ lead generation websites advertised “Medicare Health Plans for 

Your Needs and Budget,” or “Medicare Senior Health Insurance Options.” The defendants also 

claimed affiliation with AARP. In reality, the defendants did not actually offer the comprehensive 

plans that they marketed and had no affiliation with AARP. Instead, at most, the defendants 

enrolled consumers in limited benefit plans and medical discount programs that offered none 

of the promised coverage. At the FTC’s request, a federal court froze the defendants’ assets and 

halted their marketing efforts. This litigation is ongoing. 

FIGURE A – SCREENSHOT OF A PORTION OF A WEBSITE IN SIMPLE HEALTH PLANS, LLC

B. Tech Support

In Elite IT Partners, Inc.,32 the FTC alleged that the defendants had been operating a technical 

support scheme using internet ads targeting consumers looking for email password recovery help. 

31 FTC v. Simple Health Plans, LLC, No. 18-cv-62593, (S.D. Fla. filed Oct. 28, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3148/simple-health-plans-llc.

32 FTC v. Elite IT Partners, Inc., No. 2:19-cv-125, (D. Utah filed Feb. 25, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/182-3114/elite-it-partners-inc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 14

The defendants’ representatives 

falsely told consumers that their 

computer problems most likely 

stemmed from a computer virus or 

infection. The telemarketers ran 

bogus “diagnostic” tests and used 

scare tactics and misrepresentations 

to sell additional service plans. The 

vast majority of consumers that the 

defendants contacted were older. 

At the FTC’s request, the federal 

court temporarily shut down the 

defendants’ scheme and froze their 

assets. This litigation is ongoing. 

The case was brought as part of a 

coordinated effort with DOJ and 

other federal and state agencies to 

take down technical support scams.33

FIGURE B – SCREENSHOT OF A PORTION OF A 

WEBSITE IN ELITE IT PARTNERS, INC.

C. Robocall Credit Card Interest Reduction 

In First Choice Horizon LLC,34 the FTC alleged that the defendants robocalled financially 

distressed and older consumers, including many whose phone numbers were on the Do Not Call 

Registry, about a bogus credit card interest rate reduction service. Under the guise of confirming 

consumers’ identities, the defendants tricked consumers into providing their personal financial 

information, including their Social Security and credit card numbers. Consumers were promised 

they could lower their credit card interest rates to zero percent for the life of the debt, thereby 

saving them thousands of dollars on their credit card debt. In reality, the defendants applied 

for new credit cards with only a promotional rate that lasted for a limited time, after which the 

interest rate increased significantly. The defendants did not disclose that their service could 

lead to consumers paying substantial additional bank or transaction fees. In many instances, the 

FTC alleged when consumers did not agree to use the defendants’ service, the defendants used 

consumers’ personal financial information to apply for credit cards on their behalf without their 

knowledge or consent. Upon the FTC’s request, the court froze the defendants’ assets and issued 

an order that prohibited the defendants from engaging in telemarketing to offer any sort of debt 

relief product or service. This litigation is ongoing.

33 Press Release, FTC, FTC Halts Tech Support Scam as Part of Major Initiative Focused on Older Adults Hit 

Hardest by These Scams (Mar. 7, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/03/ftchalts-tech-support-scam-part-major-initiative-focused-older.

34FTC v. First Choice Horizon LLC, No. 19-cv-1028-40LRH, (M.D. Fla. filed June 3, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3161-x190029/first-choice-horizon-llc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 15

D. Business Opportunity Schemes

In 8 Figure Dream Lifestyle 

LLC,

35 the FTC alleged that the 

defendants consistently made false 

or unsubstantiated claims about how 

much consumers could earn through 

their programs. They often said, for 

example, that a typical person with 

no prior skills could make $5,000 to 

$10,000 in 10 to 14 days. While the 

defendants marketed their scheme 

broadly, they also directly targeted 

older consumers. Their marketing 

to retirees said, “Make sure those 

golden years are actually ‘Golden’!!” 

The reality was less shiny, as people 

who bought the program spent up to $22,000, and rarely earned substantial income. In fact, they 

typically lost their entire investment, and often incurred significant loans and credit card debt. 

This litigation is ongoing.

E. Money Transfer System Fraud

In November 2018, the FTC settled charges in MoneyGram International over allegations 

that the company failed to take steps required under a 2009 FTC order that requires the 

company to protect consumers from fraud through its money transfer system.36 In its new filing 

addressing violations of the 2009 order, the FTC alleged that MoneyGram failed to implement 

the comprehensive fraud prevention program mandated by the 2009 order, which requires the 

company, among other things, to promptly train, investigate, restrict, suspend, and terminate 

high-fraud agents. The 2009 order requires MoneyGram to conduct timely fraud investigations 

of any agent location that has received two or more fraud complaints within 30 days; has fraud 

complaints totaling 5 percent or more of the location’s total monthly received transactions; or has 

displayed any unusual or suspicious money transfer activity. MoneyGram also must terminate 

locations that may be complicit in fraud-induced money transfers. The original FTC case 

described several scams perpetuated through the MoneyGram payment system including lottery 

or prize scams that often involve older adults.37 MoneyGram agreed to a $125 million payment as 

part of a global settlement, which resolved allegations that MoneyGram also violated a separate 

2012 deferred prosecution agreement with the Department of Justice.

FIGURE C - SCREENSHOT OF A PORTION OF A 

WEBSITE IN 8 FIGURE DREAM LIFESTYLE LLC

35 FTC v. 8 Figure Dream Lifestyle LLC, No. 8:19-cv-01165-AG-KES (C.D. Cal. filed June 12, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/182-3117/8-figure-dream-lifestyle-llc.

36 Press Release, FTC, MoneyGram Agrees to Pay $125 Million to Settle Allegations that the Company Violated the 

FTC’s 2009 Order and Breached a 2012 DOJ Deferred Prosecution Agreement (Nov. 8, 2018) available at https://

www.ftc.gov/news-events/press-releases/2018/11/moneygram-agrees-pay-125-million-settle-allegations-company.

37 FTC v. MoneyGram Int’l, 1:09-cv-06576 (N.D. Ill. Complaint filed Oct. 19, 2009) (complaint para. 30), available 

at https://www.ftc.gov/sites/default/files/documents/cases/2009/10/091020moneygramcmpt.pdf.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 16

F. Real Estate Scam

In In re Sanctuary Belize Litigation,

38 the FTC alleged that the defendants bilked more than 

$100 million from consumers, largely retirees, in a massive land sale scam. According to 

the complaint, recidivist Andris Pukke perpetrated an international scheme selling lots in a 

development in remote southern Belize with promises that he never intended to keep. The 

alleged scheme took in more than $100 million, marketing lots in what supposedly would 

become a luxury development in Central America known by several names, including Sanctuary 

Belize, Sanctuary Bay, and The Reserve. Among other things, the defendants falsely promised 

that the development would include luxury amenities and be completed soon, and that the value 

of the lots would rapidly appreciate. Litigation in this action, including a contempt action against 

former FTC defendant Pukke, is ongoing.

G. Negative Option Marketing

In F9 Advertising, LLC,

39 the FTC alleged that the defendants engaged in a deceptive negative 

option marketing scheme when they marketed trial-offer skin care products through their 

website. Products included the defendants’ Revived Youth Cream, Revived Youth Serum, Aura 

Youth Cream, and Aura Youth Serum. The defendants advertised free trial products for a nominal 

shipping and handling charge. Among other things, the FTC alleged that the defendants failed 

to disclose that consumers would be automatically charged full-price for the products, as well as 

for monthly auto-shipments, unless they cancelled their order within 14-15 days. The defendants 

charged consumers who ordered the “Free Trial” more than $90 and enrolled them in auto-ship 

programs. The complaint further alleged the defendants frequently charged consumers without 

their consent for additional products, enrolled them in additional auto-ship programs, and used a 

confusing checkout process that led consumers to unintentionally sign up for products they did 

not want. This litigation is ongoing, but presently stayed due to the criminal prosecution of one 

of the defendants.

In AH Media Group, Inc.,40 the FTC alleged that the defendants operated an online subscription 

scam that primarily sold cosmetics and dietary supplements, including Amabella Allure, Adelina, 

Parisian Glow, and Tone Fire Garcinia, with claims that they promote younger-looking skin or 

weight loss. The FTC alleged that the defendants sold their products through deceptive websites, 

which failed to disclose that defendants would charge consumers for both the “trial” product and 

ongoing monthly subscription plans. The defendants claimed consumers would have to pay only 

a small shipping and handling fee for the trial, usually $4.99 or less, while burying the true cost 

of these trials behind small-font “terms” links and faded background text. In reality, after 14 days 

38 FTC v. Ecological Fox, LLC, No. 1:18-cv-3309 (D. Md. Complaint filed Oct. 31, 2018) and FTC v. AmeriDebt, 

Inc., No. 1:18-c-3309 (D. Md. Contempt Action filed Oct. 31, 2018), available at

https://www.ftc.gov/enforcement/cases-proceedings/0223171/ameridebt-inc

39 FTC v. F9 Advertising, LLC, No. 3:19-cv-01174 (D.P.R. filed Feb. 21, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/1723164/f9-advertising-llc.

40 FTC v. AH Media Group, LLC, No. 3:19-cv-04022-JD (N.D. Cal. filed July 12, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/182-3047/ah-media-group-llc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 17

the defendants charged consumers around $90 for the trial product and enrolled them in unwanted 

subscription plans with additional monthly charges. The defendants have agreed to a preliminary 

injunction that stops the defendants from misleading consumers about supposedly “free trial” 

offers, enrolling them in unwanted continuity plans, billing them without their authorization, and 

making it nearly impossible for them to cancel or get their money back. The litigation is ongoing.

H. Anti-Aging/Health Claims

In Regenerative Medical Group, Inc.,41 the defendants advertised their stem cell therapy treatments 

through social media and various websites. The initial treatments cost from $9,500 to $15,000 and 

the defendants encouraged patients to undergo multiple treatments, including a $5,000-$8,000 

“booster.” The defendants did not conduct any studies on their treatments or otherwise prove that 

they would treat, alleviate, or cure various ailments, such as Parkinson’s disease and macular 

degeneration, or were comparable or superior to conventional medical treatments. The defendants 

settled with the FTC, including agreeing to a partially-suspended $3.31 million judgment and 

injunctive relief.42 The settlement order prohibits the defendants from making the challenged claims 

unless supported by competent and reliable human clinical testing and other health-related claims 

unless supported by competent and reliable scientific evidence, as defined in the order. In April 

2019, the FTC sent 270 refund checks totaling over $515,000 to consumers who had paid for what 

the FTC alleged was deceptively advertised therapy.43

FIGURE D - ADVERTISEMENT IN REGENERATIVE MEDICAL GROUP, INC.

In Global Community Innovations LLC,

44 the FTC alleged the defendants deceptively 

marketed “cognitive improvement” supplements. As alleged in the complaint, the defendants 

used fake news websites, references to non-existent clinical studies, and fraudulent 

41 FTC v. Regenerative Med. Grp., Inc., No. 8:18-cv-01838 (M.D. Fla. filed Oct. 12, 2018), available at

https://www.ftc.gov/system/files/documents/cases/172_3062_regenerative_med_grp_complaint.pdf.

42 Regenerative Med. Grp., No. 8:18-cv-01838 (M.D. Fla. filed Oct. 25, 2018), available at

https://www.ftc.gov/system/files/documents/cases/regenerative_medical_group_signed_order_10-25-18.pdf.

43 Press Release, FTC, FTC Returns Almost $515,000 to Consumers Who Bought Deceptively Marketed “Amniotic 

Stem Cell Therapy” Between 2014 and 2017 (Apr. 30, 2019) available at https://www.ftc.gov/news-events/pressreleases/2019/04/ftc-returns-almost-515000-consumers-who-bought-deceptively.

44 FTC v. Glob. Cmty. Innovations LLC, No. 5:19-CV-00788, (N.D. Ohio filed Apr. 10, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/162-3135/global-community-innovations-llc-et-al-geniux. 
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 18

FIGURE E – ADVERTISEMENT IN GLOBAL

COMMUNITY INNOVATIONS LLC

endorsements to deceptively claim the products 

were clinically proven to improve memory, 

increase focus, increase IQ, and prevent memory 

loss. To settle the FTC’s charges, the two sets 

of defendants agreed to injunctive and other 

equitable relief. The orders impose partiallysuspended judgments of $14,564,891 and 

$11,587,117 respectively.45 The orders also 

prohibit the defendants from making, among 

other misrepresentations, the challenged health 

claims without competent and reliable human 

clinical testing, other health-related claims unless 

supported by competent and reliable scientific 

evidence, and false claims of scientific proof.46

I . Other Enforcement Highlights

During Fiscal Year 2019, the FTC announced additional developments in prior enforcement actions 

affecting older consumers.

1. Relevant Settlements

In March 2019, the FTC settled charges against the defendants in Hite Media Group, LLC, a sham 

grant scheme that targeted older adults and consumers with disabilities who sought help with 

personal expenses.47 The FTC had alleged the defendants called consumers offering grant money, 

then charged upfront fees ranging from hundreds to thousands of dollars. The settlement orders 

impose a $3 million judgment and ban the defendants from grant services and telemarketing.

In March 2019, the FTC and the State of Missouri settled their case against the operators of a 

sweepstakes scam, Next-Gen, that targeted or affected older adults48. The defendants agreed 

to forfeit $30 million in cash and assets and be permanently banned from the prize promotion 

business. The settlement requires the defendants to turn over more than $21 million in cash, as well 

as two luxury vacation homes, a yacht, a Bentley automobile, and other personal property. The case 

represents the largest forfeiture the FTC has ever obtained in a case against a sweepstakes scam, 

and the proceeds will be used to refund money to victims. 

45 Press Release, FTC, Geniux Dietary Supplement Sellers Barred from Unsupported Cognitive Improvement Claims

(Apr. 10, 2019) available at https://www.ftc.gov/news-events/press-releases/2019/04/geniux-dietary-supplement-sellers-barred-unsupported-cognitive.

46 Glob. Cmty. Innovations, No. 5:19-CV-00788, (N.D. Ohio filed Apr. 30, 2019), available at https://www.ftc.gov/

system/files/documents/cases/geniux_entered_stipulated_final_j_and_perm_injphs_ds2019-04-30.pdf and

https://www.ftc.gov/system/files/documents/cases/geniux_entered_stipulated_final_j_and_perm_inj2019-04-30.pdf.

47FTC v. Hite Media Grp., LLC, No. 2:18-cv-02221, (D. Ariz. filed July 16, 2018), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3157/premium-grants.

48 FTC & State of Missouri v. Next-Gen, Inc., No. 4:18-CV-0128, (W.D. Mo. filed Feb. 20, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3133/federal-trade-commission-state-missouri-v-nextgen-inc.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 19

In June 2019, the FTC and the Florida Attorney General’s Office settled their case against 

Lifewatch, Inc.49 According to the complaint, the defendants bombarded primarily older 

consumers with at least a billion unsolicited robocalls to pitch supposedly “free” medical alert 

systems. One order permanently bans one set of defendants from telemarketing, prohibits them 

from misrepresenting the terms associated with the sale of any product or service, and imposes 

a judgment of $25.3 million. Another order permanently bans another set of defendants from 

robocalling, calling consumers whose phone numbers are on the Do Not Call Registry, calling 

anyone who is on an entity-specific do not call list and “spoofing” caller ID information. It also 

imposes financial judgments of $8.9 million against the second set of defendants. The financial 

judgments will be partially suspended after the defendants pay $2 million.

In June 2019, the FTC and the Florida Attorney General’s office also settled a case against Life 

Management Services, Inc.50 According to the complaint, the defendants bombarded consumers 

with illegal robocalls, attempting to sell them bogus credit card interest rate reduction services. 

The defendants allegedly tailored their debt-elimination pitch to consumers who were over the 

age of 60. The settlement permanently bans 17 Life Management defendants from engaging in 

telemarketing and debt relief services. It also imposes a judgment of $23.1 million against them, 

jointly and severally, which will be suspended after they turn over virtually all their assets. The 

order also resolves the claims against two relief defendants who were not directly involved in 

the scheme, but benefitted from it financially. The FTC won summary judgment and obtained a 

permanent injunction and monetary relief against scheme leader Kevin Guice in December 2018.

In May, the FTC settled charges with operators of a worldwide negative option scam in Triangle 

Media Corp.51The FTC alleged the defendants sold anti-aging products, including a cognitive 

enhancement supplement and an anti-aging cream, using deceptively advertised free trial offers. 

The court orders resolving the FTC’s complaint bar the defendants from such illegal conduct and 

require them to turn over more than $9 million in assets.

2. Warning Letters

In February, the FTC and the U.S. Food and Drug Administration sent three warning letters to 

companies selling dietary supplements claiming to treat Alzheimer’s disease and remediate or cure 

other serious illnesses such as Parkinson’s disease, heart disease, and cancer. The joint letters stated 

that the companies’ advertisements may violate the FTC Act by making false or unsubstantiated 

health claims and instructed the companies to contact the FTC regarding actions taken to address 

the agency’s concerns.52 The letters also indicated that the FTC can bring civil enforcement actions 

49 FTC & State of Florida v. Lifewatch, Inc., No. 1:15-cv-05781, (N.D. Ill. filed June 30, 2015) available at

https://www.ftc.gov/enforcement/cases-proceedings/142-3123/lifewatch-inc.

50 FTC & State of Florida v. Life Management Servs, Inc., No. 6:16-cv-982-Orl-41TBS, (M.D. Fla. filed July 7, 

2016) available at https://www.ftc.gov/enforcement/cases-proceedings/152-3216/life-management.

51 Press Release, FTC, Online Marketers Barred from Deceptive “Free Trial” Offers, Unauthorized Billing (May 

31, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/05/online-marketers-barred-deceptive-free-trial-offers-unauthorized. 

52 Press Release, FTC, FTC and FDA Send Warning Letters to Companies Selling Dietary Supplements Claiming 

to Treat Alzheimer’s Disease and Remediate or Cure Other Serious Illnesses Such as Parkinson’s, Heart Disease, 

and Cancer (Feb. 11, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/02/ftc-fda-sendwarning-letters-companies-selling-dietary.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 20

against companies for deceptively promoting, marketing, or selling health-related products, and 

seek monetary redress for consumers.

In September, the FTC sent warning letters to three companies that sell oils, tinctures, capsules, 

“gummies,” and creams containing cannabidiol (CBD), a chemical compound derived from the 

cannabis plant.53 The letters warned the companies that it is illegal to advertise that a product can 

prevent, treat, or cure human disease without competent and reliable scientific evidence to support 

such claims. Each company advertised that its CBD products treat or cure serious diseases and 

health conditions, including Alzheimer’s disease, Parkinson’s disease, and arthritis.

3. Consumer Monetary Relief

In addition to the Regenerative Medical Group case mentioned above, the FTC also sent checks to 

consumers in five cases this year that noted an impact on older consumers:

In Health Research Laboratories, LLC, the FTC sent refund checks totaling more than $750,000 

to consumers who bought two deceptively marketed dietary supplements.54 The sellers of these 

supplements, which each cost about $40 per bottle, falsely claimed that they would treat conditions 

that affect older consumers, such as Alzheimer’s disease, dementia, and arthritis.

In Tarr, Inc., the FTC mailed refund checks totaling more than $6 million to consumers who 

purchased health products from the defendants.55 The FTC’s complaint alleged the defendants sold 

more than 40 different products mostly advertised as promoting weight loss, muscle building, or 

wrinkle reduction.

In Troth Solutions, Inc., the FTC sent more than $26,000 to people deceived by the operators of an 

alleged tech support scheme.56 The complaint alleged that the defendants tricked consumers, many 

of whom were older adults, into believing their computers were infected with viruses and malware, 

and then charged them hundreds of dollars for unnecessary repairs.

In Advertising Strategies, LLC, the FTC sent refund checks totaling more than $7 million to people 

deceived by the operators of an alleged business opportunity fraud that targeted older consumers 

and others living on a fixed income.57

53 Press Release, FTC, FTC Sends Warning Letters to Companies Advertising Their CBD-Infused Products as 

Treatments for Serious Diseases, Including Cancer, Alzheimer’s, and Multiple Sclerosis (Sept. 10, 2019) available 

at https://www.ftc.gov/news-events/press-releases/2019/09/ftc-sends-warning-letters-companies-advertising-theircbd-infused.

54 Press Release, FTC, FTC Returns more than $750,000 to Consumers Who Bought Two Deceptively Marketed 

Supplements from Health Research Laboratories, LLC (Nov. 29, 2018), available at https://www.ftc.gov/newsevents/press-releases/2018/11/ftc-returns-more-750000-consumers-who-bought-two-deceptively.

55 Press Release, FTC, FTC Returns More Than $6 Million to Consumers Who Bought Deceptively Marketed Health 

Products from Tarr, Inc. (Feb. 1, 2019) available at https://www.ftc.gov/news-events/press-releases/2019/02/ftcreturns-more-6-million-consumers-who-bought-deceptively.

56 Press Release, FTC, FTC to Send Refund Check to Consumers who Lost Money to Tech Support Scam (Feb. 11, 

2019) available at https://www.ftc.gov/news-events/press-releases/2019/02/ftc-send-refund-checks-consumerswho-lost-money-tech-support-scam.

57 Press Release, FTC, FTC to Send Refund Checks to Consumers who Lost Money in Business Opportunity 

Telemarketing Scam (Mar. 5, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/03/ftcsend-refund-checks-consumers-who-lost-money-business.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 21

In All Us Marketing LLC, the FTC sent more than $314,000 to consumers who paid up-front for 

worthless credit card interest rate reduction programs pitched by the defendant’s illegal robocalls.58

The complaint alleged that the defendant illegally called thousands of consumers, including many

older adults, to convince them to provide their credit card information in this scheme.

In XXL Impressions LLC, the FTC sent refund checks totaling more than $113,000 to fully refund 

consumers who bought FlexiPrin, a deceptively marketed joint pain supplement.59 The Commission 

brought the Health Research Labs and XXL Impressions cases jointly with the Maine Attorney General.

4. Criminal Liaison Unit

The FTC’s Criminal Liaison Unit works with federal and state criminal prosecutors to better 

address consumer fraud. Many of these prosecutors have brought criminal cases that built on facts 

exposed as the FTC developed evidence in support of its civil law enforcement actions.60

For example, in March 2019, FTC defendant Fawaz Sebai,61 and his co-conspirators Vassilos 

Klouvatos and Lefkothea Klouvatos, were sentenced to a total of ten years for operating a call 

center that defrauded older adults by selling them bogus medical discount cards62. Sebai and his

co-conspirators were extradited from Canada and prosecuted in the United States.

In August 2019, three-time FTC defendant Crystal Ewing63 was charged with, and pled guilty for, 

operating a fraudulent mass-mailing scheme that tricked thousands of older adults into paying

up-front fees for the false promise of a large cash prize.64 DOJ prosecuted Ewing and her FTC

co-defendants, Steve McLenahan,65 Tully Lovisa,66 and Glen Burke67 for their roles in a 

58 Press Release, FTC, FTC Returns Nearly $315,000 to Consumers Who Bought Worthless Credit Card Interest Rate 

Reduction Programs (May 23, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/05/ftc-returnsnearly-315000-consumers-who-bought-worthless-credit.

59 Press Release, FTC, FTC Refunds Consumers Who Bought FlexiPrin Joint Pain Supplement (Aug. 22, 2019), available 

at https://www.ftc.gov/news-events/press-releases/2019/08/ftc-refunds-consumers-who-bought-flexiprin-joint-pain-supplement.

60 A description of the FTC’s Criminal Liaison Unit is available at https://www.ftc.gov/enforcement/criminal-liaison-unit.

61 Press Release, FTC, FTC Stops Marketers of Phony Health Care ‘Discount’ Schemes Directed at Older Americans and 

Spanish-Speaking Consumers (Sept. 12, 2014), available at https://www.ftc.gov/news-events/press-releases/2014/09/

ftc-stops-marketers-phony-health-care-discount-schemes-directed.

62 Press Release, U.S. Department of Justice, Canadian Telemarketers Who Defrauded Elderly Americans in Prescription 

Drug Discount Scam Headed to Prison (Mar. 27, 2019), available at https://www.justice.gov/usao-sdil/pr/canadian-telemarketers-who-defrauded-elderly-americans-prescription-drug-discount-scam.

63 See Press Release, FTC, Sweepstakes Promoters Will Pay $1.4 Million To Settle FTC Charges (Apr. 23, 2007), 

available at https://www.ftc.gov/news-events/press-releases/2007/04/sweepstakes-promoters-will-pay-14-million-settleftc-charges; Press Release, FTC, FTC Obtains $9.5 Million Judgment Against Sweepstakes Promoter for Contempt

(Feb. 11, 2015), available at https://www.ftc.gov/news-events/press-releases/2015/02/ftc-obtains-95-million-judgmentagainst-sweepstakes-promoter; Press Release, FTC, FTC Brings Action to Stop Marketer from Making Deceptive 

Opiate Addiction and Withdrawal Treatment Claims (Nov. 17. 2015), available at https://www.ftc.gov/news-events/

press-releases/2015/11/ftc-brings-action-stop-marketer-making-deceptive-opiate-addiction. 

64 See United States v. Ewing, No. 2:19cr170 (Criminal Information) (D. Nev. Jul. 31, 2019); id. (Plea Agreement).

65 See United States v. McClenahan, No. 2:19cr339 (Information) (E.D.N.Y. Jul. 26, 2019); id. (Minute Entry: Criminal 

Cause for Guilty Plea)

66 U.S. Department of Justice, Press Release, Five Charged for Elder Fraud Schemes (July 11, 2018) available at

|https://www.justice.gov/opa/pr/five-charged-elder-fraud-schemes.

67 U.S. Department of Justice, Press Release, Two Defendants Plead Guilty in Multimillion Dollar Prize Promotion Scams 

Targeting Elderly Victims (Dec. 20, 2017), available at https://www.justice.gov/opa/pr/two-defendants-plead-guiltymultimillion-dollar-prize-promotion-scams-targeting-elderly.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 22

sweepstakes scam ring, and each has either pled guilty, been sentenced, or is currently 

awaiting sentencing. 

In April 2019, the DOJ announced charges against Ghopalkrishna Pai,68 whom the FTC had 

sued for operating an internet mass marketing scheme that tricked many older adults into 

ordering supposedly “free” trial offers of youth cream or other personal care products, only 

to subject these consumers to monthly charges for unwanted shipments.69 The FTC’s matter 

against Mr. Pai is ongoing.

IV. Outreach and Education Activities

A. Pass it On Education Campaign

Pass It On is the FTC’s ongoing fraud prevention education campaign for older adults. Campaign 

materials show respect for the readers’ life experience and accumulated knowledge, and provide 

resources they can read and “pass on” to family and friends to start conversations about fraud.70

The Pass It On campaign began with a variety of print and online material that addressed common 

frauds like Identity Theft, Imposter Scams, Charity Fraud, Health Care Scams, Paying Too Much, 

and “You’ve Won” Scams. In response to users’ requests, the FTC added articles about Tech 

Support Scams, Grandkid Scams, Online Dating Scams and IRS Imposter Scams. Materials build 

on and refresh readers’ knowledge by briefly summarizing how certain scams work and what the 

reader can do in response. 

68 U.S. Department of Justice, Press Release, Texas Man Indicted In Puerto Rico For Wire And Bank Fraud Scheme 

(May 17, 2019), available at https://www.justice.gov/usao-pr/pr/texas-man-indicted-puerto-rico-wire-and-bankfraud-scheme.

69 Press Release, FTC, FTC Continues Actions to Stop Deceptive Free-Trial and Negative Option Pitches (Feb. 28, 

2019), available at https://www.ftc.gov/news-events/press-releases/2019/02/ftc-continues-actions-stop-deceptive-free-trial-negative-option.

70 Conversations about fraud are critical to avoiding fraud losses. Survey research shows that awareness of scams 

is extremely important in helping people avoid fraud losses, and that word of mouth is a primary source of 

information about scams, second only to news stories. See FINRA Investor Education Foundation, BBB Institute 

for Marketplace Trust, & Stanford Center on Longevity, Exposed to Scams: What Separates Victims from

Non-Victims? at 11-13 (Sept. 2019) available at https://www.finrafoundation.org/sites/finrafoundation/files/

exposed-to-scams-what-separates-victims-from-non-victims_0_0.pdf
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 23

The FTC has distributed more than 11.3 million Pass It On items since the campaign began, 

including almost 2 million items in fiscal year 2019, to banks, libraries, police departments, 

adult protective service offices, state attorneys general, military support groups and a variety of 

educational and community groups. Campaign materials are available at FTC.gov/PassItOn, FTC.

gov/pasalo (Spanish), FTC.gov/PassItOnImposters, and FTC.gov/Bulkorder.

In 2019, the FTC expanded the Pass It On materials again to add articles about Home Repair 

Scams and Unwanted Calls.71 These materials are designed to provide important information to 

older adults about these scams that may interest them.

The FTC also issues online Consumer Alerts on many of the topics covered by Pass It On and 

other topics of interest to older adults, such as Social Security imposter scams, responding to 

unwanted calls, and secret shopper scams. The FTC sends the alerts to its more than 291,000 

subscribers, which include news media outlets, and posts the material on our website to share the 

prevention messages.

B. Talking About Fraud Videos

As part of the Every Community Initiative, the FTC has underscored the importance of talking 

about fraud by conveying this message in a series of videos told from the perspective of real people 

who faced the threat of losing money.72 This year, the FTC added another video in this series, 

highlighting the experience of an older adult who experienced a tech support scam.73 The man 

appearing in this video tells a powerful story of an older adult fighting back against a scammer; a 

story that the agency hopes will inspire others to warn their friends and families about the scams 

they see in their communities and report them to law enforcement. The FTC continues to deploy 

these videos through various partners, including ethnic and mainstream media, legal aid offices, 

consumer advocacy groups, and fellow law enforcement agencies.

C. Common Ground and Ethnic Media Events

As part of the Every Community Initiative, the FTC hosted three Common Ground conferences 

in the past year that brought together stakeholders – including local law enforcement officials, 

legal services providers, and community-based organizations – to talk about consumer protection 

issues and spur cooperation on these issues. One of the conferences took place in Los Angeles 

and focused exclusively on issues affecting older adults. It included speakers from AARP, the 

National Center on Elder Abuse, the University of Southern California Keck School of Medicine, 

as well as law enforcement, community partners, a Federal Bureau of Investigation victim 

specialist, and other elder abuse prevention advocates. The sessions included presentations 

by scientists, law enforcement, consumer education and outreach specialists, and others. The 

Department of Justice’s Elder Justice Coordinator for the Southern District of California also 

provided remarks. The conference participants discussed the unique issues presented when 

71 See https://www.consumer.ftc.gov/features/feature-0030-pass-it-on#home-repair-scams and https://www.consumer.ftc.gov/features/feature-0030-pass-it-on#unwanted-calls.

72 See Fraud Affects Every Community Video Series available at https://www.consumer.ftc.gov/features/every-community. 

73 Video available at https://www.consumer.ftc.gov/media/video-0181-how-avoid-tech-support-scam.
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 24

older adults are victimized by fraud and discussed strategies for combating fraud affecting older 

adults. Common Ground conferences in Minneapolis and San Francisco also included segments 

regarding older consumer issues.

The FTC also conducted four more Community and Ethnic Media briefings this year, in 

Birmingham, Oklahoma City (hosted by AARP), Milwaukee, and Charleston, West Virginia. 

These events engaged community stakeholders, local media, and law enforcement in the ongoing 

conversation about how we can work together to do more to protect a wide range of consumers 

in local communities.74 These convenings have been critical as the agency refines its strategy for 

protecting the growing number of older adults from diverse communities.

D. Other Outreach Events Relating to Older Adults

The FTC partners with many organizations across the country to share its consumer education 

messages and inform the public about its work. In the past year, the FTC staff including its 

regional offices have presented, exhibited, or participated in more than 200 outreach events with 

the public, other law enforcement agencies, and/or other stakeholders aimed at protecting various 

communities. This included a variety of events with AARP, including several nationwide webinars 

and tele-town halls, a series of fraud prevention videos aimed at Asian American Pacific Islander 

older adults,75 and nine events with AARP in Washington, Oregon, California, and West Virginia. 

In addition, FTC staff spoke about scams and older adults at several nationwide conferences, 

including the American Society on Aging, Home and Community Based Services, the American 

Bar Association (ABA) National Aging and Law Conference, and the ABA Equal Justice 

Conference. In sum, over 70 of the outreach events either directly served older adults and those 

who work with them, or involved partner organizations to discuss issues affecting older adults, 

including events with the Better Business Bureau, the National Association of Area Agencies on 

Aging, and others.

In response to the increase in Social Security imposter scams, the FTC partnered with other 

agencies and non-profits to alert consumers about government imposter calls. The FTC updated 

IdentityTheft.gov to include IdentityTheft.gov/SSA, a page that tells consumers what to do if they 

get an SSA imposter call and how to report identity theft if someone misuses their Social Security 

number. As noted, the FTC also worked with AARP to offer nationwide webinars and tele-town 

halls about government imposter scams. Further, the FTC and Social Security Administration 

offered a Facebook Live event about government imposters during National Consumer Protection 

Week. Finally, to spread the word about the growing number of Social Security imposter scams, 

the FTC and SSA collaborated with the Consumer Financial Protection Bureau to create a fraud 

prevention placemat (often used by congregate meal sites). More than 56,000 copies were ordered 

in the first week alone – for use at senior living facilities, banks and more.

In addition, the Every Community Initiative is conducting a series of webinars for each state, 

bringing together federal, state, and local law enforcement in each jurisdiction with stakeholders 

74 See FTC’s Common Ground and Ethnic Media Event list available at www.consumer.gov/commonground

75 See videos on Medicare scams (https://www.youtube.com/watch?v=51I-szr0JEY), IRS scams (https://www.youtube.com/watch?v=o7U1k7bumDA), and robocalls (https://www.youtube.com/watch?v=8rDKxLUhbUE). 
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 25

from a range of local consumer groups including aging service providers and senior organizations, 

rural extension offices, libraries, military and veterans organizations, and others. The webinars 

share data about the frauds affecting consumers in each state, describe resources to help consumers 

spot the most common scams, identify where residents can go for help, and explain how to report to 

law enforcement. Attorneys General offices, the Better Business Bureaus, legal service providers, 

and others have spoken on these webinars, sharing information about the services available in their 

respective states. Regional representatives for the Centers for Medicare and Medicaid as well as the 

state Senior Medicare Patrols have shared information on these webinars about the new Medicare 

cards designed to prevent identity theft and deter Medicare scams. Staff completed seven more of 

these webinars this year.76

The FTC’s outreach with groups and communities throughout the country provides a way to 

share the agency’s important prevention messages, but also opens up the communication lines 

so the Commission hears about the scams and other consumer protection problems affecting the 

public. This, in turn, can generate opportunities for policy and education initiatives as well as 

new case leads.

V. Conclusion

The FTC remains firmly committed to protecting older consumers through aggressive law 

enforcement and effective consumer education and outreach. Research, law enforcement 

experience, and input from stakeholders will continue to be critical as the Commission strategizes 

about how to use its resources to protect the growing population of older adults in the years ahead.

76 See www.consumer.gov/statewebinars for the state webinar presentation materials
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 26

Appendix A - Federal Trade Commission FY 2019

STYLE OF CASE

Federal Trade Commission v. 

Match Group, Inc.

Appendix

Case Number

3:19-02281

 A - Federa

Court Name

Northern District 

of Texas

g

l Tra

Date

9/25/19

P

de Commission Ca

Case Type

Dating website

a

ses FY 2019

Description

Alleged the defendant used fake love interest 

advertisements to trick consumers into 

purchasing paid subscriptions.

Outcome

Litigation Ongoing

Federal Trade Commission v. 

Truly Organic Inc.and Maxx 

Harley Appelman. 1:19-23832

Southern District 

of Florida 9/13/19

e

Environmental 

marketing

 1 of

Alleged the defendants deceptively marketed 

personal care products as “100% organic” or 

“certified organic. Settlement

Federal Trade Commission, 

Plaintiff v. Student Advocates 

Team, LLC 8:19-cv-01728

Central District 

of California 9/11/19

Student loan debt 

relief scheme

 12

Alleged the defendants charged illegal 

upfront fees and falsely promised to lower or 

event eliminate consumers’ loan payments or 

balances. Settlement

Federal Trade Commission and 

State of Minnesota v. Manhattan 

Beach Venture, LLC, et al. 2:19-cv-07849

Central District 

of California 9/11/19

Student loan debt 

relief scheme

Alleged the defendants charged illegal 

upfront fees and falsely promised to lower or 

even eliminate consumers’ loan payments or 

balances. Settlement

United States of America and 

People of the State of New York 

v. Google LLC and YouTube, 

LLC 1:19-cv-02642

District of 

Columbia 9/4/19 Children’s privacy

Alleged the defendants illegally collected 

personal information from children without 

their parents’ consent. Settlement

In the Matter of 214 

Technologies, Inc., also 

business as Trueface.ai

doing FTC Matter No. 

1823193

FTC 

Administrative 

Matter 9/3/19

EU-U.S. Privacy 

Shield Program

Alleged the respondent falsely claimed that it 

participated in the EU-U.S. Privacy Shield 

and Swiss-U.S. Privacy Shield frameworks. Consent Agreement

In the Matter of EmpiriStat, Inc.

FTC Matter No. 

1823195

FTC 

Administrative 

Matter 9/3/19

EU-U.S. Privacy 

Shield Program

Alleged the respondent falsely claimed that it 

participated in the EU-U.S. Privacy Shield 

and Swiss-U.S. Privacy Shield frameworks. Consent Agreement
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 27

Appendix A - Federal Trade Commission Cases FY 2019

Page 2 of 12

Appendix A - Federal Trade Commission FY 2019

FTC Alleged the respondent falsely claimed that it 

FTC Matter No. Administrative EU-U.S. Privacy participated in the EU-U.S. Privacy Shield 

In the Matter of LotaData, Inc. 1823194 Matter 9/3/19 Shield Program and Swiss-U.S. Privacy Shield frameworks. Consent Agreement

FTC Alleged the respondent falsely claimed that it 

In the Matter of DCR FTC Matter No. Administrative EU-U.S. Privacy participated in the EU-U.S. Privacy Shield 

Workforce, Inc. 1823188 Matter 9/3/19 Shield Program and Swiss-U.S. Privacy Shield frameworks. Consent Agreement

FTC Alleged the respondent falsely claimed that it 

FTC Matter No. Administrative EU-U.S. Privacy participated in the EU-U.S. Privacy Shield 

In the Matter of Thru, Inc. 1823196 Matter 9/3/19 Shield Program and Swiss-U.S. Privacy Shield frameworks. Consent Agreement

Alleged the defendants used sales leads from 

lead generators that falsely told consumers 

Federal Trade Commission v. they were affiliated with the U.S. military, 

Career Education Corporation Northern District Use of illegal lead and used other unlawful tactics to generate 

et al. 1:19-cv-05739 of Illinois 8/27/19 generation leads. Settlement

FTC Deceptive Alleged the respondent deceived consumers 

FTC Matter No. Administrative collection of about how it accesses and uses their personal 

In the Matter of Unroll.Me Inc. 1723139 Matter 8/5/19 consumer data emails. Consent Agreement

Alleged the defendant violated a 2012 FTC 

order by deceiving users about their ability to 

United States of America v. District of Order violation - control the privacy of their personal 

Facebook, Inc. 1:19-cv-2184 Columbia 7/24/19 privacy information. Settlement
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 28

Appendix A - Federal Trade Commission Cases FY 2019

Page 3 of 12

Alleged the respondent employed deceptive 

FTC Matter Nos. FTC Deceptive tactics to harvest personal information from 

In the Matter of Cambridge 1823107 & Administrative collection of Facebook users for voter profiling and 

Analytica, LLC, et al. 1823106 Matter 7/24/19 consumer data targeting. Litigation Ongoing

Alleged the defendant failed to take 

reasonable steps to secure its network that led 

Federal Trade Commission v. Northern District to a data breach in 2017 affecting 

Equifax Inc. 1:19-cv-3297 of Georgia 7/22/19 Data breach approximately 147 million people. Settlement

Federal Trade Commission and Interest rate Alleged the defendants sold sham credit card 

State of Ohio v. Educare Centre Western District reduction services interest rate reduction services to consumers 

Services, Inc. et al. 3:19-cv-196 of Texas 7/18/19 scheme through telemarketers. Litigation Ongoing

Alleged the defendants generated and 

processed remotely created payment orders or 

checks that allowed many unscrupulous 

Federal Trade Commission and merchants, including deceptive telemarketing 

State of Ohio v. Madera Western District schemes, to withdraw money from their 

Merchant Services, LLC et al. 3:19-cv-195 of Texas 7/18/19 Payment processing victims’ bank accounts. Litigation Ongoing

Alleged the defendants deceptively marketed 

Negative option online trials of skin creams and dietary 

scheme for skin supplements, made unauthorized charges to 

Federal Trade Commission v. Northern District creams and diet consumers’ credit cards and enrolled them in 

AH Media Group, LLC et al. 3:19-cv-4022 of California 7/12/19 supplements costly, unwanted continuity plans. Litigation Ongoing

Alleged the defendants lured consumers into 

paying illegal upfront fees with false 

Federal Trade Commission v. Central District Student loan debt promises to lower consumers’ monthly 

Elegant Solutions, Inc. et al. 8:19-cv-1333 of California 7/8/19 relief student loan payments. Litigation Ongoing

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 29

Appendix A - Federal Trade Commission Cases FY 2019

Page 4 of 12

Alleged the defendant sent millions of calls to 

United States of America v. Middle District Robocalls - Do Not numbers on the DNC registry and used fake 

Bartoli 6:19-cv-1160 of Florida 6/21/19 Call violations caller ID information. Settlement 

Alleged the defendants called phone numbers 

on the DNC Registry and repeatedly or 

United States of America v. Central District Robocalls - Do Not continuously called consumers with the intent 

Media Mix 365, LLC, et al. 8:19-cv-1243 of California 6/21/19 Call violations of annoying, abusing, or harassing them. Settlement 

Federal Trade Commission v. Alleged the defendants charged illegal 

Grand Teton Professionals, LLC District of upfront fees and falsely claimed to repair 

et al. 3:19-cv-933 Connecticut 6/17/19 Credit Repair consumers’ credit. Litigation Ongoing

FTC Alleged the respondent falsely claimed that it 

FTC Matter No. Administrative EU-U.S. Privacy participated in the EU-U.S. Privacy Shield 

In the Matter of SecurTest, Inc. 1823152 Matter 6/14/19 Shield Program and Swiss-U.S. Privacy Shield frameworks. Consent Agreement

Federal Trade Commission v. 8 

Figure Dream Lifestyle LLC et Central District Money-making Alleged the defendants marketed and sold 

al. 8:19-cv-1165 of California 6/12/19 scheme fraudulent money-making opportunities. Litigation Ongoing

Alleged the respondent failed to implement 

In the Matter of Lightyear FTC readily available and low-cost measures to 

Dealer Technologies, LLC d/b/a FTC Matter No. Administrative protect personal information it obtained from 

DealerBuilt 1723051 Matter 6/12/19 Data security its auto dealer clients. Consent Agreement

Credit card interest Alleged the defendants used illegal robocalls 

Federal Trade Commission v. Middle District rate reduction to offer bogus credit card interest rate 

First Choice Horizon LLC et al. 6:19-cv-1028 of Florida 6/3/19 scheme reduction services. Litigation Ongoing

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 30

Appendix A - Federal Trade Commission Cases FY 2019

Page 5 of 12

In the Matter of Shore to Please 

Vacations LLC

FTC Matter No. 

1823088

FTC 

Administrative 

Matter 5/22/19 Consumer reviews

Alleged the respondent illegally used nondisparagement provisions in consumer form 

contracts in the course of renting vacation 

homes. Consent Agreement

In the Matter of Staffordshire 

Property Management, LLC

FTC Matter No. 

1823084

FTC 

Administrative 

Matter 5/22/19 Consumer reviews

Alleged the respondent illegally used nondisparagement provisions in consumer form 

contracts in the course of processing rental 

applications. Consent Agreement

Federal Trade Commission v. 

Alliedwallet, Inc. et al. 2:19-cv-4355

Central District 

of California 5/20/19 Payment processing

Alleged the defendants knowingly processed 

payments for merchants that were engaged in 

fraud. Settlement

In the Matter of A. Waldron 

HVAC, LLC d/b/a Waldron 

Electric Heating and Cooling, 

LLC

FTC Matter No. 

1823077

FTC 

Administrative 

Matter 5/8/19 Consumer reviews

Alleged the respondent included nondisparagement text in form contracts offered 

to prospective customers. Consent Agreement

In the Matter of National Floors 

Direct, Inc. 

FTC Matter 

No.1823085

FTC 

Administrative 

Matter 5/8/19 Consumer reviews

Alleged the respondent included nondisparagement text in form contracts it 

offered to consumers. Consent Agreement

In the Matter of LVTR LLC 

d/b/a/ Las Vegas Trail Riding 

and Tomi A. Truax

FTC Matter No. 

1823098

FTC 

Administrative 

Matter 5/8/19 Consumer reviews

Alleged the respondents included nondisparagement text in form contracts they 

offered consumers. Consent Agreement

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 31

Appendix A - Federal Trade Commission Cases FY 2019

Page 6 of 12

Federal Trade Commission v. 

ibackpack of Texas LLC et al. 3:19-cv-160

Southern District 

of Texas 5/6/19

Deceptive 

crowdfunding 

scheme

Alleged the defendants told consumers they 

were raising money to develop a high-tech 

backpack and other products, but failed to 

deliver any of the products and instead used 

much of the funds for the individual 

defendant. Litigation Ongoing

United States of America v. 

Unixiz, Inc. et al. 5:19-cv-2222

Northern District 

of California 4/24/19 Children’s privacy

Alleged the defendants failed to obtain 

parental consent before collecting personal 

information from children and failed to 

provide reasonable security for the data 

collected. Settlement

In the Matter of James V. 

Grago, Jr., d/b/a ClixSense.com

FTC Matter No. 

1723003

FTC 

Administrative 

Matter 4/24/19 Data security 

Alleged the respondent’s website’s 

inadequate security allowed hackers to gain 

access to consumers’ sensitive information 

through the company’s network. Consent Agreement

Federal Trade Commission v. 

Avant, LLC 1:19-cv-2517

Northern District 

of Illinois 4/15/19

Deceptive and 

unfair loan 

servicing practices

Alleged the defendant engaged in deceptive 

and unfair loan servicing practices. Settlement

Federal Trade Commission v. 

Global Community Innovations 

LLC et al. 5:19-cv-788

Northern District 

of Ohio 4/10/19

Deceptive 

endorsements for 

diet supplements

Alleged the defendants deceptively marketed 

“cognitive improvement” supplements. Settlement

United States of America v. 

iSpring Water Systems, LLC 

al.

et 

1:19-cv-1620

Northern District 

of Georgia 4/10/19

Order violation - 

Made in America 

claims

Alleged the defendants violated a 2017 FTC 

administrative order by making false claims 

that wholly imported Chinese water filtration 

systems were made in the United States. Settlement

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 32

Appendix A - Federal Trade Commission Cases FY 2019

Page 7 of 12

Federal Trade Commission v. 

Interbill, Ltd. et al. 2:06-cv-1644

District of 

Nevada 4/10/19 Order violation

Alleged the defendants repeatedly violated a 

2009 court order issued against them by 

facilitating processing of consumer payments 

for merchants while knowing or consciously 

avoiding knowing that the merchants’ 

business practices were, or were likely to be, 

deceptive or unfair. Settlement

In the Matter of Urthbox, Inc. 

and Behnam Behrouzi

FTC Matter No. 

1723028

FTC 

Administrative 

Matter 4/3/19

Negative option 

scheme and 

deceptive 

endorsements

Alleged the respondents misrepresented that 

customer reviews were independent and 

failed to adequately disclose terms of its “free 

trial” renewal programs. Consent Agreement

Federal Trade Commission v. 

Office Depot, Inc. et al. 9:19-cv-80431

Southern District 

of Florida 3/27/19

Deceptive 

computer repair 

scheme

Alleged the defendants tricked customers into 

buying millions of dollars worth of computer 

repair and technical services by deceptively 

claiming their software had found malware 

symptoms on the customers’ computers. Settlement

Federal Trade Commission and 

State of Florida v. American 

Veterans Foundation, Inc. et al. 8:18-cv-00744

Middle District 

of Florida 3/27/19 Charity fraud

Alleged the defendants deceptively claimed 

that consumers’ donations would be used for 

specific charitable purposes, including care 

packages for deployed service members, 

immediate assistance to veterans facing 

homelessness, and counseling. Settlement

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 33

Appendix A - Federal Trade Commission Cases FY 2019

Page 8 of 12

Federal Trade Commission and 

State of Missouri v. Disabled 

Police And Sheriffs Foundation 

et al. 4:19-cv-667

Eastern District 

of Missouri 3/27/19 Charity fraud

Alleged the defendants falsely claimed that 

consumers’ donations would be used to help 

police officers and families of slain officers, 

provide life-saving equipment to law 

enforcement agencies, and provide advanced, 

specialized training for law enforcement 

officers and departments. Settlement

Federal Trade Commission v. 

Day Pacer LLC et al. 1:19-cv-1984

Northern District 

of Illinois 3/22/19

Do Not Call 

registry violations

Alleged the defendants made illegal calls 

about educational programs to consumers 

who submitted their contact information to 

websites promising help with job searches, 

public benefits, and other programs. Litigation Ongoing

United States of America v. 

Musical.Ly et al. 2:19-cv-1439

Central District 

of California 2/27/19 Children’s privacy

Alleged the defendants illegally collected 

personal information from children. Settlement

Federal Trade Commission v. 

Elite IT Partners et al. 2:19-cv-125 District of Utah 2/25/19

Technical 

scheme

support 

Alleged the defendants used deceptive tactics 

to gain access to consumers’ computers and 

then sold costly and unnecessary computer 

repair and other services. Litigation Ongoing

Federal Trade Commission v. F9 

Advertising LLC et al. 3:19-cv-1174

District of 

Puerto Rico 2/21/19

Negative option 

scheme

Alleged the defendants deceptively charged 

consumers who ordered a “Free Trial” for 

skin care products and enrolled them in autoship programs Litigation Ongoing

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 34

Appendix A - Federal Trade Commission Cases FY 2019

Page 9 of 12

Alleged the defendant made false and 

Unsubstantiated unsubstantiated claims for their weight-loss 

Federal Trade Commission v. Eastern District claims and fake supplement and that they paid a third-party 

Cure Encapsulations, Inc. et al. 1:19-cv-982 of New York 2/19/19 reviews website to write and post fake reviews. Settlement

Federal Trade Commission v. Alleged the defendants operated a sham job 

Worldwide Executive Job Southern District Job placement placement and resume repair services 

Search Solutions, LLC et al. 4:19-cv-495 of Texas 2/13/19 scheme scheme. Litigation Ongoing

Alleged the defendants bilked consumers out 

Federal Trade Commission v. Western District of millions of dollars using deceptive and 

Global Asset Financial Services of North Phantom debt threatening tactics to collect phantom debts 

Group, LLC et al. 3:19-cv-55 Carolina 2/4/2019 collection that they did not owe. Litigation Ongoing

Alleged the defendants charged consumers an 

up-front fee to join a program that 

Federal Trade Commission v. purportedly would allow them to make 

Fat Giraffe Marketing Group, Business significant income from home by posting 

LLC et al. 2:19-cv-63 District of Utah 1/29/19 opportunity advertising links onto websites. Settlement

Alleged the defendant provided contact 

lenses to consumers without obtaining the 

required prescription, failed to verify the 

United States v. Lawrence L. Northern District prescription information, and failed to keep 

Duskin 1:18-cv-7359 of California 12/6/18 Contact lens sales required records. Settlement

Appendix A - Federal Trade Commission FY 2019
PROTECTING OLDER CONSUMERS 2018-2019 | FTC 35

Appendix A - Federal Trade Commission Cases FY 2019

Page 10 of 12

Federal Trade Commission v. 

Nobetes Corporation et al. 2:18-cv-10068

Central District 

of California 12/3/18

Deceptive diabetes 

treatment claims

Alleged the defendants made unsubstantiated 

health claims, misled consumers about the 

terms of “free trial” offers, billed consumers 

without their consent, and employed other 

practices related to the use of endorsements 

and consumer testimonials. Settlement

Federal Trade Commission v. 

Apex Capital Group, LLC et al. 2:18-cv-9573

Central District 

of California 11/14/18

Deceptive negative 

option scheme

Alleged the defendants marketed supposedly 

“free trial” offers for personal care products 

and dietary supplements online, but then 

charged consumers the full price of the 

products and enrolled them in negative option 

continuity plans without their consent. Partial settlement

Federal Trade Commission v. 

Moneygram International, Inc. 1:09-cv-6576

Northern District 

of Illinois 11/8/18 Order violation

Alleged the defendant failed to take steps 

required under a 2009 FTC order to crack 

down on fraudulent money transfers that cost 

U.S. consumers millions of dollars. Settlement

Federal Trade Commission v. 

Impetus Enterprise, Inc. et al. 8:18-cv-1987

Central District 

of California 11/6/18

Student loan debt 

relief

Alleged the defendants tricked consumers 

into paying illegal upfront fees in hopes of 

reducing or eliminating their student loan 

debt. Litigation Ongoing

In the Matter of Creaxion 

Corporation, et al.

FTC Matter Nos. 

1723066 and 

1723067

FTC 

Administrative 

Matter 11/5/18

Deceptive 

endorsements

Alleged the respondents misrepresented that 

paid endorsements were independent 

consumer opinions and that commercial 

advertising was independent journalistic 

content. Consent Agreement

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PROTECTING OLDER CONSUMERS 2018-2019 | FTC 36

Appendix A - Federal Trade Commission Cases FY 2019

Page 11 of 12

Federal Trade Commission v. 

Ecological Fox, LLC et al. 1:18-cv-3309

District of 

Maryland 10/31/18 Real estate scheme

Alleged the defendants duped consumers into 

buying Sanctuary Belize lots by falsely 

promising that the development would 

include luxury amenities and be completed 

soon, and that the value of the lots would 

rapidly appreciate. Litigation Ongoing

Federal Trade Commission v. 

Simple Health Plans, LLC et al. 0:18-cv-62593

Southern District 

of Florida 10/29/18

Deceptive health 

insurance claims

Alleged the defendants deceptively sold 

medical plans. Litigation Ongoing

In the Matter of Social Finance, 

Inc. et al.

FTC Matter No. 

1623197

FTC 

Administrative 

Matter 10/25/18

Deceptive student 

loan refinancing

Alleged the respondents made false 

statements about loan refinancing savings 

their advertisements.

in 

Consent Agreement

Federal Trade Commission and 

State of New York v. Campbell 

Capital LLC et al. 1:18-cv-1163

Western District 

of New York 10/23/18

Debt collection 

scheme

Alleged the defendants tricked people into 

agreeing to pay more money than what they 

allegedly owed, according to defendants’ own 

business records. Litigation Ongoing

Federal Trade Commission v. 

Realpage, Inc 3:18-cv-2737

Northern District 

of Texas 10/16/18

Fair Credit 

Reporting

Alleged the defendant failed to take 

reasonable steps to ensure the accuracy of 

tenant screening information that it provided 

to landlords and property managers. Settlement

Federal Trade Commission v. 

Forms Direct, Inc. et al. 3:18-cv-6294

Northern District 

of California 10/15/18

Impersonation of 

USCIS

Alleged the defendants implied that their 

websites were affiliated with the U.S. 

Citizenship and Immigration Services, and 

utilized this to sell immigration form 

preparation services to consumers. Settlement

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PROTECTING OLDER CONSUMERS 2018-2019 | FTC 37

Appendix A - Federal Trade Commission Cases FY 2019

Page 12 of 12

Alleged the defendants deceptively advertised 

that “amniotic stem cell therapy” can treat 

serious diseases, including Parkinson’s 

Federal Trade Commission v. disease, autism, macular degeneration, 

Regenerative Medical Group, Central District Deceptive health cerebral palsy, multiple sclerosis, and heart 

Inc. et al. 8:18-cv-1838 of California 10/12/18 claims attacks. Settlement

Deceptive health Alleged the defendants deceptively marketed 

claims and oral film strips and enrolled consumers in a 

Federal Trade Commission v. Central District unauthorized negative option continuity plan without their 

Jason Cardiff et al. 5:18-cv-2104 of California 10/10/18 billing knowledge or consent. Partial settlement

Alleged the defendants mailed fake “urgent 

Federal Trade Commission v. District of Deceptive recall recall” notices to consumers to lure them to 

Passport Imports, Inc. et al. 8:18-cv-3118 Maryland 10/10/18 notices visit dealerships. Settlement

Appendix A - Federal Trade Commission FY 2019