________________________________________________ 

________________________________________________ 

1923106 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

In the Matter of 

HOMEADVISOR, INC., a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED BY ANGI. 

Docket No. 9407 

Provisionally Redacted 

Public Version 

COMPLAINT 

The Federal Trade Commission, having reason to believe that HomeAdvisor, Inc., a 

corporation, has violated the provisions of the Federal Trade Commission Act, and it appearing 

to the Commission that this proceeding is in the public interest, alleges: 

1. Respondent HomeAdvisor, Inc. (“HomeAdvisor”), also doing business as Angi Leads, 

also doing business as HomeAdvisor Powered by Angi, is a Delaware corporation with its 

principal offices or places of business at 3601 Walnut Street, Denver, Colorado 80205 and 14023 

Denver West Parkway, Golden, Colorado 80401. 

2. HomeAdvisor has marketed, advertised, offered for sale, and sold products to home 

service providers, including leads, HomeAdvisor memberships, and mHelpDesk. 

3. The acts and practices of HomeAdvisor alleged in this complaint have been in or 

affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission 

Act. 

Summary of the Matter 

4. HomeAdvisor collects information about potential customers for home services like 

kitchen remodels or lawn care, and sells that information to service providers in its network, such 

as general contractors and gardeners, as leads. 
5. HomeAdvisor rec111its service providers, , through marketing 

materials and--sales agents who call service providers and attempt to persuade them 

to j oin HomeAdvisor's network. To j oin HomeAdvisor's network, a service provider pays an 

annual membership fee of $287.99 in addition to paying for each lead, which can range from6. Since at least July 2014, HomeAdvisor, through its sales agents and marketing materials, 

has made representations to service providers about the quality, characteristics, and source of 

HomeAdvisor's leads that are false, misleading, or unsubstantiated. HomeAdvisor represents 

that its leads concern people who intend to hire a service provider soon, even though many of 

them do not. HomeAdvisor represents that service providers will only receive leads that match 

the types of services they provide and their geographic preferences, even though many service 

providers receive leads that do not match the types of services they provide or their geographic 

preferences. HomeAdvisor represents that its leads concern people who knowingly sought its 

assistance in selecting a service provider, even though many of the leads HomeAdvisor sells are 

purchased from third paiiies who collect info1mation from potential customers without first 

revealing their affiliation with HomeAdvisor. In addition, HomeAdvisor represents to service 

providers that its leads conve1i into jobs at rates well above what HomeAdvisor can substantiate. 

7. Since at least 2015, HomeAdvisor's sales agents have also misrepresented the cost of an 

optional one-month subscription to a field service software, mHelpDesk, which assists service 

providers with tasks like scheduling appointments and processing payments. Whereas 

HomeAdvisor has represented to service providers that the first month of the mHelpDesk 

subscription is free with an annual membership, in fact, the first month of the subscription 

increases the cost of the annual membership by $59.99. 

8. Based on HomeAdvisor's false, misleading, or unsubstantiated representations about the 

quality, chai·acteristics, and source of HomeAdvisor's leads and the rates at which those leads 

conve1i into jobs, service providers agree to j oin HomeAdvisor's network, paying an upfront 

(and often inflated) membership fee, followed by additional fees for each lead they receive. 

Service providers, ah-eady busy with the demands of 111nning small businesses, expend precious 

time following up on leads that ai·e not of the quality HomeAdvisor promises, and still more time 

seeking, often unsuccessfully, credits and refunds from HomeAdvisor for such leads. 

9. HomeAdvisor's deceptive practices have caused service providers to suffer of 

dollai·s of injmy. 

HomeAdvisor's Business Practices 

HomeAdvisor's Lead Product 

10. Eve1y yeai·, HomeAdvisor sells--ofleads to service providers in its network. 

- the leads that HomeAdvisor sells consist of info1mation submitted by visitors to 

HomeAdvisor's website, homeadvisor.com. The website 's homepage states: "Find tiusted local 

pros for any home project," and prompts the visitor to answer a series of questions about a 

2 
project and provide contact infonnation. A visitor can also browse a directo1y of service 

providers on HomeAdvisor's website. 

11. Using the infonnation visitors submit to its website, HomeAdvisor sells a variety of lead 

types to service providers, including "Market Match Leads," "Exact Match Leads," and "Instant 

Booking Leads." 

12. - of the leads HomeAdvisor sells to service providers are Market Match Leads. 

HomeAdvisor generates Market Match Leads from its website when a visitor follows the 

prompts and answers several questions about a home project. With the exception of an optional 

field that allows the visitor to provide further details about the project, the questions are multiple 

choice with one answer option often pre-selected by default. Based on a subset of the visitor's 

answers, HomeAdvisor uses an automated matching system to identify service providers in 

HomeAdvisor's network to whom HomeAdvisor sends the infonnation provided by the visitor as 

a lead. 

13. HomeAdvisor generates Exact Match and Instant Booking Leads from visitors who 

browse the directo1y of service providers on HomeAdvisor's website. The directory consists of 

service provider listings that include a description of each service provider's work and reviews. 

Many service provider listings also include an appointment calendar. HomeAdvisor generates an 

Exact Match Lead when a visitor selects a specific service provider from the directo1y and 

submits project and contact info1mation directly to that service provider. HomeAdvisor 

generates an Instant Booking Lead when a visitor makes an appointment with a specific service 

provider via a web-based application on the directo1y. Approximately-- of the leads 

HomeAdvisor sells to service providers are Exact Match Leads and approximately--are 

Instant Booking Leads. 

14. In addition to selling leads to service providers that are generated from visitors' 

interactions with HomeAdvisor's website, HomeAdvisor has resold--of leads that it has 

purchased from third paiiies ("affiliates"). Affiliates generate these leads from webbased fo1ms 

. In many cases, the 

internet users do not know that their info1mation will be shared with HomeAdvisor until they 

complete the fonn, if at all. 

15. HomeAdvisor also sells leads to service providers that are generated when HomeAdvisor 

customer representatives input info1mation provided over the phone by potential customers of 

home services. HomeAdvisor's telephone-generated leads 

3 
18. In order to receive leads from HomeAdvisor, service providers must first pass a 

background check and join HomeAdvisor's network by purchasing a membership. 

HomeAdvisor regularly sold a membership package for $347.98 that included a one-month 

subscription to mHelpDesk, a field service software produced by a subsidia1y of HomeAdvisor. 

After the first month, the mHelpDesk subscription automatically renewed at $59.99 per month 

unless service providers cancelled it. 

19. Upon purchasing a HomeAdvisor membership, service providers receive leads, including 

Market Match, Exact Match, and Instant Booking Leads. The price of a Market Match Lead 

ranges from approximately- to- depending on the type of home project it concerns (e.g., 

a kitchen remodel will typically be priced higher than house cleaning), and the geographic 

location of the project. Exact Match and Instant Booking Leads cost fifty percent more than 

Market Match Leads of the same project type and location. The average price of a lead, across 

lead types, is approximately • . 

20. Service providers pay HomeAdvisor for each Market Match, Exact Match, or Instant 

Booking Lead they receive. Service providers limit the number of Market Match and Exact 

Match Leads they receive by setting an approximate monthly lead budget in their HomeAdvisor 

account. 

- HomeAdvisor also allows a service provider to "pause" receiving Market Match, Exact 

Match, and Instant Booking Leads for a limited time, after which the leads will automatically 

resume. 

21. HomeAdvisor does not allow service providers to preview leads prior to receiving them. 

If a service provider is dissatisfied with a lead she receives from HomeAdvisor, her primaiy 

4 
recourse is to request a credit to her HomeAdvisor account for the cost of the lead in question. If 

HomeAdvisor grants the credit request, HomeAdvisor then applies the credit against the cost of 

future leads. HomeAdvisor does not generally provide refunds for leads. 

22. Service providers can submit lead credit requests by speaking with a HomeAdvisor 

customer service representative who submits the credit request on the service provider's behalf. 

Service providers can also submit lead credit requests online via their HomeAdvisor account. To 

submit a lead credit request, a service provider must provide the reason the service provider 

thinks a credit is appropriate. HomeAdvisor grants lead credit requests at its discretion based on 

a variety of factors, including 

July 2014, HomeAdvisor has denied more than 

--1_percent of those submitted. 

HomeAdvisor's Misrepresentations About Its Leads 

23. HomeAdvisor employs sales agents who call service providers around the 

count:Iy and attempt to persuade them to join HomeAdvisor's network. A service provider can 

only join HomeAdvisor's network by speaking to a HomeAdvisor representative over the phone. 

24. In their sales calls with service providers,- ofHomeAdvisor's sales agents,_ 

, make false, misleading, or unsubstantiated representations about the 

quality, characteristics, and source of HomeAdvisor's leads and the rates at which those leads 

conve1t into jobs. 

Misrepresentations About Intent to Hire 

25. In--instances, HomeAdvisor's sales agents have represented to service providers 

that HomeAdvisor's leads concern people who intend to hire a service provider soon. For 

example, in sales calls HomeAdvisor's sales agents have described the leads as follows: 

5 
-

26. Indeed, HomeAdvisor has provided its sales a~ ts with a list of marketing claims 

approved for use in sales calls that include 

-and 

27. HomeAdvisor's external marketing materials make similar representations. On its 

website, HomeAdvisor prominently displays a "How It Works" video for service providers that 

states, "With HomeAdvisor's patented ProFinder technology, you're only matching to serious 

homeowners in your area." 

28. Another po1i ion of its website represents to service providers: "When you're a [member 

of HomeAdvisor's service provider network], HomeAdvisor matches you with homeowners 

actively seeking the services you provide in your area." 

> How will I benefit from HomeAdvisor Pro membership? 

When you're a HomeAdvisor Pro member, HomeAdvisor matches you with homeowners actively seeking the services you 

provide in your area - making it easier than ever to connect with new customers and win more Jobs. You·11 also get a listing in 

our online directory, a business profile page on our website, access to helpful business management and marketing tools, and 

qualified new business opportunities (Pro Leads) to keep your pipeline full. 

Illustration 1: available at https://pro.homeadvisor.com/r/membership/#membership (last visited August 9, 2021) 

29. Yet another page on HomeAdvisor's website states, "You won't have to waste your time 

with customers who just window-shop. Angi Leads allows you to spend your time with the right 

'ready-to-buy' customers." 

Benefits of Joining 

Can Angi Leads increase a service professionars profits? 

Absolutely. You won1 have to waste your time with customers who just window-shop. Angi Leads allows you to spend your time with Ille right "ready-to-buy" customers. We do 

our best to fully Educate customers about the scope, cost, and timing of their projects. Then we'll match them willl you, based on your preferen~ s for job type and location. 

fllustration 2: available at https://pro.homeadvisor.com/helplfaqs/ (last visited August 9, 2021) 

30. Other marketing materials describe HomeAdvisor's leads as "project requests" and 

adve1iise HomeAdvisor as a means for service providers to "connect with project-ready 

homeowners." 

6 
~ H Advisorm 

Q C.1 ..,.,..,...._ HPHf:IINf 

Connect WlU1 PU>l!Cl•(!Jldy hQflllOWINf5 lvday1 

We recetved 

proJKt requests 

111 O.nvw last .,onlh 

.,. 

1:ir,o;o..,..,. .... ,-..i ... ,...i~ 

111>..-.-....~ 

1:.0)11'_.,,,_ 

fllustration 3: email marketing sent to prospective service provider members 

31. Contraiy to HomeAdvisor's representations, _ of the leads that HomeAdvisor sells to 

service providers do not concern people who intend to hire a service provider soon. --

32. Indeed, HomeAdvisor sells infonnation to service providers as leads even when internet 

users affinnatively indicate that they do not intend to hire a service provider soon. For example, 

one of the questions that a user typically must answer about a home project is whether its status 

is "Ready to Hire" or only "Planning & Budgeting." Similai·ly, another question that a visitor 

typically must answer is how soon they would like the project completed (e.g., "Timing is 

flexible," "Within 1 week," "1-2 weeks," or "More than 2 weeks"). Yet another question asks 

whether the internet user is "the owner or authorized to make property changes." 

7 
--

Misrepresentations About Leads Matching Types of Work and Geographic Preferences 

35. In--instances, HomeAdvisor's sales agents have told service providers that the 

leads they will receive concern home services projects that match the type of work and 

geographic preferences that service providers express to HomeAdvisor. For example, in sales 

calls HomeAdvisor's sales agents have described the leads as follows: 

36. Indeed, scripts used by HomeAdvisor sales agents describe HomeAdvisor's leads as 

follows: 

( emphasis original) 

37. HomeAdvisor's marketing material . Its website states, 

"Tell us what you do and where, and we deliver prospects that meet your exact needs." 

8 
Helping You Grow Your Business 

One Homeowner at a Time 

• Connect with the Targeted Prospects You Need to Succeed 

Tell us what you do and where, and we deliver prospects 

that meet your exact needs 

• Stay in Control and in Charge of Your Business 

You control your budget and lead preferences. 

• Leap Ahead of the Competition to Win More Jobs 

O ur lead management tools keep you organized and in touch 

With the homeovmers you need to grow your business. 

Sign Up Today Learn More > 

" -

j 

tli ' - ' ·~-- ,, ~ 

j 

Illustration 4: available at https://pro.homeadvisor.com/ (last visited August 9, 2021) 

You're In Control 

Only Get the 

Leads You Want 

You pick your service types and location 

preferences and we bring you prospects that 

match what you want. 

Illustration 5: previously available at https://pro.homeadvisor.com/how-it-works/ 

38. Another page on its website has stated, "Only Get the Leads You Want. You pick yowservice types and location preferences and we bring you prospects that match what you want." 

39. In fact, contnuy to HomeAdvisor's representations,- ofthe leads that service 

providers receive do not concern the type of work that the service providers perfonn, or fall 

outside of the service providers' geographic JJreferences. For example, 

9 
Misrepresentations About Lead Source 

42. HomeAdvisor's sales agents also have--represented to service providers that 

HomeAdvisor's leads concern people who knowingly sought HomeAdvisor's assistance in 

selecting a service provider. For example, in sales calls HomeAdvisor's sales agents have 

described the somce of HomeAdvisor's leads as follows: 

Indeed, scripts used by HomeAdvisor's sales agents state, 

--

44. HomeAdvisor's marketing materials have also represented that HomeAdvisor's leads 

concern people who knowingly sought HomeAdvisor's assistance in selecting a service provider. 

HomeAdvisor's website has described Market Match Leads as follows: "Consumers come to 

HomeAdvisor.com and give us detailed info about their project." 
Market Match 

Get Started 

Consumers come to HomeAdvisor com and 

giVe us detailed mfo about lheir project. We 

match that info with your work and area 

preferences, and connect you wrth 

homeowners that match your needs. 

Illustration 6: previously available at https://www.homeadvisor.com/rfs/enroll/sppostenrollleadsdetails 

45. In fact, contraiy to HomeAdvisor's representations,- ofthe leads that HomeAdvisor 

sells to service providers ai·e purchased from affiliates and concern individuals who did not 

knowingly seek HomeAdvisor's assistance. Since July 2014, HomeAdvisor has sold service 

providers--of leads that HomeAdvisor purchased from affiliates and did not come from 

HomeAdvisor's website . 

.... HomeAdvisor recognizes that it has ve1y limited control over the quality of affiliategenerated leads. Indeed, a document HomeAdvisor's parent company filed publicly with the 

Securities and Exchange Commission acknowledged that "the quality and conve1tibility of 

[HomeAdvisor's] leads generated through third-pai·ty aiTangements are dependent on many 

factors, most of which are outside our control." 

11 
Misrepresentations About the Rates at Which Leads Convert into Jobs 

48. In numerous instances, HomeAdvisor's sales agents have represented to service providers 

that HomeAdvisor's leads conve1i into jobs at rates well above what HomeAdvisor can 

substantiate. 

49. According to HomeAdvisor's own calculations, 

, the average rate at which a lead purchased by a service provider 

turns into a job for that service provider the "win rate") has ranged between 

since July 2014. 

50. Similarly, according to HomeAdvisor's own calculations, the average win rate for Market 

Match Leads 

-

since July 2014. In that same period, the average win 

rate for Exact Match Leads has ranged between and the 

average win rate for Instant Booking Leads has ranged between 

51. Nonetheless, HomeAdvisor's sales agents have--represented falsely inflated 

win rates to service providers. For example, in sales calls HomeAdvisor's sales agents have 

described the leads as follows: 

53. HomeAdvisor' s deJ)aiiment has pe1J)etuated inflated win rate 

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HomeAdvisor's Deceptive mHelpDesk Sales Practices 

54. In numerous instances, HomeAdvisor's sales agents have represented to service providers 

that the cost of an annual membership is $347.98, and includes a free one-month subscription to 

mHelpDesk. 

55. For example, in sales calls HomeAdvisor's sales agents have described mHelpDesk as 

follows: 

56. Indeed, HomeAdvisor's training materials have pe1petuated sales agents' representations 

that the first month of mHelpDesk is free. ScriJ)tS used by HomeAdvisor's sales--

57. Similarly, until at least 2016, the fo1m email that HomeAdvisor sent service providers 

confmning their pm-chase of an annual membership represented that $347.98 was the cost of the 

annual membership and a "free" month of mHelpDesk. 

58. In fact, the cost of an annual membership is $287.99. The $347.98 price has represented 

the cost of an annual membership plus one month of mHelpDesk, an optional, add-on product 

that costs $59.99 per month and automatically renews after the first month. If a service provider 

does not want a one-month subscription to mHelpDesk, she can pm-chase an annual membership 

for $287.99. 

13 
59. After HomeAdvisor' s sales agents have added a month of mHelpDesk to service 

providers' annual memberships, service providers frequently have not learned that they were 

charged an additional $59.99 because the $347.98 charge has appeared as a single line item on 

the service provider's receipt and credit card bill. 

60. Of the more than service providers who have been charged $347.98 for an 

annual membership and a one-month subscription to mHelpDesk 

Count! 

Misrepresentations About the Quality, Characteristics, and Source of Leads 

61. In--instances in connection with the adve1iising, marketing, promotion, offering 

for sale, or sale of leads, HomeAdvisor represents to service providers, directly or indirectly, 

expressly or by implication, that the leads service providers will receive: 

a. concern individuals who intend to hire a service provider soon; 

b. concern projects that match the types of services that service providers have 

expressed they perfo1m; 

c. concern projects that match the geographic areas that service providers have 

expressed they serve; or 

d. concern individuals who knowingly sought HomeAdvisor for assistance in 

selecting a service provider. 

62. In tiuth and in fact, in instances in which HomeAdvisor has made the 

representations set fo1th in Paragraph 61, the leads service providers received, respectively: 

a. did not concern individuals who intend to hire a service provider soon; 

b. did not concern projects that match the types of services that service providers 

have expressed they perfo1m; 

c. did not concern projects that match the geographic areas that service providers 

have expressed they se1ve; or 

d. did not concern individuals who knowingly sought HomeAdvisor for assistance in 

selecting a se1vice provider. 

63. Therefore, HomeAdvisor's representations as set fo1th in Paragraph 61 are false or 

misleading. 

14 
Count II 

Misrepresentations About the Rates at which Leads Convert into Jobs 

64. In instances in connection with the advertising, marketing, promotion, offering 

for sale, or sale of leads, HomeAdvisor represents to service providers, directly or indirectly, 

expressly or by implication, that the leads convert into jobs at or above the rates that 

HomeAdvisor states. 

65. The representations set forth in Paragraph 64 are false or misleading or were not 

substantiated at the time the representations were made. 

Count III 

Misrepresentations Regarding mHelpDesk 

66. In instances in connection with the advertising, marketing, promotion, offering 

for sale, or sale of leads, HomeAdvisor has represented to service providers, directly or 

indirectly, expressly or by implication, that the first month of mHelpDesk is free. 

67. In truth and in fact, in instances in which HomeAdvisor has made the 

representations set forth in Paragraph 66, the first month of mHelpDesk is not free. 

68. Therefore, HomeAdvisor’s representations as set forth in Paragraph 66 are false or 

misleading. 

Violations of Section 5 

69. The acts and practices of HomeAdvisor as alleged in this complaint constitute unfair or 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act. 

NOTICE 

You are notified that on November 9, 2022, at 10:00 a.m., at the Federal Trade 

Commission offices, 600 Pennsylvania Avenue, NW, Room 532-H, Washington, DC 20580, an 

Administrative Law Judge of the Federal Trade Commission, will hold a hearing on the charges 

set forth in this Complaint. At that time and place, you will have the right under the Federal 

Trade Commission Act to appear and show cause why an order should not be entered requiring 

you to cease and desist from the violations of law charged in this Complaint. 

You are notified that you are afforded the opportunity to file with the Federal Trade 

Commission (“Commission”) an answer to this Complaint on or before the 14th day after service 

of the Complaint upon you. An answer in which the allegations of the Complaint are contested 

must contain a concise statement of the facts constituting each ground of defense; and specific 

admission, denial, or explanation of each fact alleged in the Complaint or, if you are without 

knowledge thereof, a statement to that effect. Allegations of the Complaint not thus answered 

will be deemed to have been admitted. 

15 
If you elect not to contest the allegations of fact set forth in the Complaint, the answer 

should consist of a statement that you admit all of the material facts to be true. Such an answer 

will constitute a waiver of hearings as to the facts alleged in the Complaint and, together with the 

Complaint, will provide a record basis on which the Commission may issue a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. In 

such answer, you may, however, reserve the right to submit proposed findings of fact and 

conclusions of law under FTC Rule § 3.46. 

Failure to answer timely will be deemed to constitute a waiver of your right to appear and 

contest the allegations of the Complaint. It will also authorize the Commission, without further 

notice to you, to find the facts to be as alleged in the Complaint and to enter a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. 

The Administrative Law Judge will hold an initial prehearing scheduling conference to be 

held not later than 10 days after the answer is filed by the Respondent. Unless otherwise directed 

by the Administrative Law Judge, the scheduling conference and further proceedings will take 

place at the Federal Trade Commission, 600 Pennsylvania Avenue, NW, Room 532-H, 

Washington, DC 20580. Rule 3.21(a) requires a meeting of the parties’ counsel as early as 

practicable before the prehearing scheduling conference, but in any event no later than 5 days 

after the answer is filed by the Respondent. Rule 3.31(b) obligates counsel for each party, within 

5 days of receiving a Respondent’s answer, to make certain initial disclosures without awaiting a 

formal discovery request. 

The following is the form of the order which the Commission has reason to believe 

should issue if the facts are found to be as alleged in the Complaint. If, however, the 

Commission concludes from record facts developed in any adjudicative proceedings in this 

matter that the proposed order provisions as to Respondent might be inadequate to fully protect 

the consuming public, the Commission may order such other relief as it finds necessary and 

appropriate, including corrective advertising or other affirmative disclosures. 

Moreover, the Commission has reason to believe that, if the facts are found as alleged in 

the Complaint, it may be necessary and appropriate for the Commission to seek relief to redress 

injury to consumers. Such relief could be in the form of restitution for past, present, and future 

consumers and such other types of relief as are set forth in Section 19(b) of the Federal Trade 

Commission Act. The Commission will determine whether to apply to a court for such relief on 

the basis of the adjudicative proceedings in this matter and such other factors as are relevant to 

consider the necessity and appropriateness of such action. 

NOTICE OF CONTEMPLATED RELIEF 

If the Commission concludes from the record developed in any adjudicative proceedings 

in this matter that Respondent has violated or is violating Section 5 of the FTC Act, the 

Commission may order such relief against Respondent as is supported by the record and is 

necessary and appropriate, including but not limited to: 

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a. A prohibition on misrepresentations, including false or unsubstantiated claims, in 

connection with the promoting, advertising, marketing, offering for sale, or selling of 

any product or service. 

b. A requirement that, for a period of time, Respondent must send acknowledgments of 

the order to the Commission. 

c. A requirement that, for a period of time, Respondent must create and retain certain 

business records. 

d. A requirement that, for a period of time, Respondent must provide prior notice to the 

Commission of all new business activity. 

e. A requirement that, for a period of time, Respondent must submit compliance reports 

to the Commission. 

f. Provisions to enable the Commission to monitor Respondent’s compliance with the 

order. 

g. Any other relief appropriate to correct or remedy the effects of Respondent’s unfair or

deceptive practices or of any or all of the conduct alleged in the complaint. 

THEREFORE, the Federal Trade Commission this 11th day of March, 2022, has issued this 

Complaint against Respondent. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

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