Case 8:22-cv-02670-GLS Document 2-1 Filed 10/18/22 Page 1 of 18 

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

PASSPORT AUTOMOTIVE GROUP, INC., a

corporation,

PASSPORT MOTORCARS, INC., a corporation,

also d/b/a as PASSPORT NISSAN OF MARLOW

HEIGHTS, also d/b/a as PASSPORT NISSAN OF

VIRGINIA, also d/b/a as PASSPORT INFINITI

OF ALEXANDRIA,

IMPORT MOTORCARS, INC., a corporation,

also d/b/a PASSPORT MAZDA,

AUTOS INTERNATIONAL, INC., a corporation,

also d/b/a PASSPORT INFINITI OF SUITLAND,

PASSPORT IMPORTS, INC., a corporation, also

d/b/a PASSPORT TOYOTA,

PASSPORT MOTORS HOLDING, INC., a

corporation, also d/b/a PASSPORT MINI OF

MONTGOMERY COUNTY,

PASSPORT OF ALEXANDRIA, INC., a

corporation, also d/b/a PASSPORT MINI OF

ALEXANDRIA,

INTERNATIONAL MOTORCARS, INC., a

corporation, also d/b/a PASSPORT BMW,

Case No. ____________

STIPULATED ORDER FOR

PERMANENT INJUNCTION,

MONETARY JUDGMENT, AND

OTHER RELIEF

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Case 8:22-cv-02670-GLS Document 2-1 Filed 10/18/22 Page 2 of 18 

EVERETT HELLMUTH, III, individually and as

an owner of PASSPORT AUTOMOTIVE

GROUP, INC., PASSPORT MOTORCARS,

INC., IMPORT MOTORCARS, INC., AUTOS

INTERNATIONAL, INC., PASSPORT

IMPORTS, INC., PASSPORT MOTORS

HOLDING, INC., PASSPORT OF

ALEXANDRIA, INC., and INTERNATIONAL

MOTORCARS, INC., and

JAY KLEIN, individually and as an officer of

PASSPORT MOTORCARS, INC., IMPORT

MOTORCARS, INC., AUTOS

INTERNATIONAL, INC., PASSPORT

IMPORTS, INC., PASSPORT MOTORS

HOLDING, INC., PASSPORT OF

ALEXANDRIA, INC., and INTERNATIONAL

MOTORCARS, INC.

Defendants.

Plaintiff the Federal Trade Commission (“Commission” or “FTC”), filed its Complaint for

Permanent Injunction, Monetary Relief, and Other Relief (“Complaint”), for a permanent

injunction and other relief in this matter, pursuant to Sections 5(a), 13(b), and 19 of the Federal

Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(a), 53(b), and 57b, and the Equal Credit

Opportunity Act (“ECOA”), 15 U.S.C. §§ 1691-1691f. The Commission and Defendants

stipulate to the entry of this Stipulated Order for Permanent Injunction, Monetary Judgment, and

Other Relief (“Order”) to resolve all matters in dispute in this action between them.

THEREFORE, IT IS ORDERED as follows:

FINDINGS

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1. This Court has jurisdiction over this matter.

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

practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and the Equal Credit

Opportunity Act (“ECOA”) and its implementing Regulation B, 12 C.F.R. § 202, in the

advertising, sales, and financing of motor vehicles.

3. Defendants neither admit nor deny any of the allegations in the Complaint, except as

specifically stated in this Order. Only for purposes of this action, Defendants admit the facts

necessary to establish jurisdiction.

4. Defendants waive any claim that they may have under the Equal Access to Justice Act, 28

U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, and agree

to bear their own costs and attorney fees.

5. Defendants and the Commission waive all rights to appeal or otherwise challenge or

contest the validity of this Order.

DEFINITIONS

For the purpose of this Order, the following definitions apply:

A. “Buy rate” means the lowest interest rate at which any assignee will purchase the

contract.

B. “Clearly and conspicuously” means that a required disclosure is difficult to miss (i.e.,

easily noticeable) and easily understandable by ordinary consumers, including in all of the

following ways:

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1. In any communication that is solely visual or solely audible, the disclosure must be

made through the same means through which the communication is presented. In any

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

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

audible portions of the communication even if the representation requiring the disclosure

is made in only one means.

2. A visual disclosure, by its size, contrast, location, the length of time it appears, and

other characteristics, must stand out from any accompanying text or other visual elements

so that it is easily noticed, read, and understood.

3. An audible disclosure, including by telephone or streaming video, must be

delivered in a volume, speed, and cadence sufficient for ordinary consumers to easily hear

and understand it.

4. In any communication using an interactive electronic medium, such as the Internet

or software, the disclosure must be unavoidable.

5. The disclosure must use diction and syntax understandable to ordinary consumers

and must appear in each language in which the representation that requires the disclosure

appears.

6. The disclosure must comply with these requirements in each medium through

which it is received, including all electronic devices and face-to-face communications.

7. The disclosure must not be contradicted or mitigated by, or inconsistent with,

anything else in the communication.

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8. When the representation or sales practice targets a specific audience, such as

children, the elderly, or the terminally ill, “ordinary consumers” includes reasonable

members of that group.

C. “Defendants” means all of the Individual Defendants and the Corporate Defendants,

individually, collectively, or in any combination.

1. “Corporate Defendants” means Passport Automotive Group, Inc.; Passport

Motorcars, Inc., also d/b/a Passport Nissan of Marlow Heights, also d/b/a Passport Nissan

of Virginia, also d/b/a Passport Infiniti of Alexandria; Import Motorcars, Inc., also d/b/a

Passport Mazda; Autos International, Inc., also d/b/a Passport Infiniti of Suitland; Passport

Imports, Inc., also d/b/a Passport Toyota; International Motor Cars, Inc., also d/b/a

Passport BMW; Passport Motors Holding, Inc., also d/b/a Passport MINI of Montgomery

County; Passport of Alexandria, Inc., also d/b/a Passport MINI of Alexandria; and their

successors and assigns.

2. “Individual Defendants” means Everett A. Hellmuth, III and Jay Klein.

D. “Express, Informed Consent” means an affirmative act communicating unambiguous

assent to be charged, made after receiving and in close proximity to a Clear and Conspicuous

disclosure, orally and in writing, of the following:

1. what the charge is for; and

2. the amount of the charge(s), including if the charge is for a product or service: all

fees and costs to be charged to the consumer over the period of repayment with and without the

product or service.

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ORDER

I. PROHIBITION AGAINST MISREPRESENTATIONS

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees,

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

receive actual notice of this Order, whether acting directly or indirectly, in connection with the

advertising, marketing, promotion, offering for sale or financing, or sale and financing of vehicles

are permanently restrained and enjoined from misrepresenting, expressly or by implication:

A. the costs or terms of purchasing, financing, or leasing a vehicle;

B. the availability of vehicles at an advertised price;

C. whether charges, products, or services are optional or required;

D. whether charges, products, or services are authorized by consumers; and

E. any material fact, including all material restrictions, limitations, or conditions

applicable to the purchase, receipt, or use of any product or service for which a charge is

incurred.

II. PROHIBITION AGAINST UNLAWFUL CREDIT DISCRIMINATION

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees,

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

receive actual notice of this Order, whether acting directly or indirectly, are permanently

restrained and enjoined from:

A. discriminating against any credit applicant:

1. on the basis of race, color, religion, national origin, sex or marital status, or

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age (provided the applicant has the capacity to contract);

2. because all or part of the applicant’s income derives from any public

assistance program; or

3. because the applicant has in good faith exercised any right under the

Consumer Credit Protection Act, §§ 1601-1693r, a copy of which is attached; or

B. failing to comply with the Equal Credit Opportunity Act, 15 U.S.C. §§ 1691-

1691f, and Regulation B, 12 C.F.R. § 202 (“ECOA”), a copy of which is attached.

III. FAIR LENDING PROGRAM

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees,

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

receive actual notice of this Order, whether acting directly or indirectly, shall not participate in the

extension, renewal, or continuation of credit unless they establish and implement, and thereafter

maintain, a fair lending program (“Fair Lending Program”) that safeguards against discrimination

against credit applicants on a basis prohibited by this Order or by law. To satisfy this

requirement, Defendants must, at a minimum:

A. Designate a finance director and/or senior finance manager qualified in fair lending

compliance as the fair lending compliance officer responsible for the Fair Lending

Program;

B. Ensure all employees, before engaging in the extension, renewal, or continuation

of credit, and at least once every twelve (12) months, receive training from an independent

qualified person or organization on the Fair Lending Program, the requirements of the

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ECOA, and Defendants’ obligations under the ECOA, and sign an acknowledgement that

states that the employee: (1) completed the training, (2) had the opportunity to have

questions about his or her legal responsibilities answered, and (3) understands his or her

legal responsibilities not to discriminate under the federal fair lending laws;

C. Implement and maintain written guidelines specifying the reasons for assessing or

not assessing any fee or other charge and each factor Defendants may consider in

calculating any such charge, each of which must be objective and none of which can be

discriminatory;

D. At each of Defendants’ dealership locations:

1. Offer a subvented retail installment sales contract to each consumer who is

eligible; and

2. On an annual basis, choose to and thereafter either:

a. Charge an interest rate not greater than the Buy Rate on all retail

installment sales contracts; or

b. Charge the same number of basis points (not to exceed 100) above

the Buy Rate on all non-subvented retail installment sales contracts;

E. Promptly terminate employees engaged in discriminatory conduct or conduct that

violates the Fair Lending Program or any term of Sections I through III and V of this

Order; and

F. For 20 years after entry of this Order, within 14 days of receiving, whether directly

or indirectly, such as through a third party, a complaint of discrimination relating to a

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motor vehicle transaction against Defendants or any of Defendants’ officers, agents, or

employees, submit a copy, along with any response, to the Commission pursuant to the

Section titled “Compliance Reporting.”

Provided, however, that nothing in this Order shall be construed as permitting any conduct

that overtly, in treatment, or in effect discriminates against consumers on the basis of race,

color, national origin, or any other protected characteristic or violates the ECOA or any

other law.

IV. OBTAINING EXPRESS INFORMED CONSENT FOR ALL CHARGES

IT IS FURTHER ORDERED THAT Defendants, Defendants’ officers, agents, employees,

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

receive actual notice of this Order, whether acting directly or indirectly, in connection with the

sale or lease of motor vehicles, are permanently restrained and enjoined from charging a

consumer without having obtained the consumer’s Express, Informed Consent.

V. MONETARY JUDGMENT

IT IS FURTHER ORDERED that:

A. Judgment in the amount of Three Million, Three Hundred Eighty Thousand

Dollars ($3,380,000) is entered in favor of the Commission against Defendants, jointly

and severally, as monetary relief.

B. Defendants are ordered to pay to the Commission Three Million, Three Hundred

Eighty Thousand Dollars ($3,380,000), which, as Defendants stipulate, their undersigned

counsel holds in escrow for no purpose other than payment to the Commission. Such

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payment must be made within 7 days of entry of this Order by electronic fund transfer in

accordance with instructions previously provided by a representative of the Commission.

D. Defendants relinquish dominion and all legal and equitable right, title, and interest

in all assets transferred pursuant to this Order and may not seek the return of any assets.

E. The facts alleged in the Complaint will be taken as true, without further proof, in

any subsequent civil litigation by or on behalf of the Commission, including in a

proceeding to enforce its rights to any payment or monetary judgment pursuant to this

Order, such as a nondischargeability complaint in any bankruptcy case.

F. The facts alleged in the Complaint establish all elements necessary to sustain an

action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11

U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for such

purposes.

H. Defendants acknowledge that their Taxpayer Identification Numbers (Social

Security Numbers or Employer Identification Numbers), which Defendants must submit to

the Commission, may be used for collecting and reporting on any delinquent amount

arising out of this Order, in accordance with 31 U.S.C. §7701.

I. All money received by the Commission pursuant to this Order may be deposited

into a fund administered by the Commission or its designee to be used for consumer relief,

such as redress and any attendant expenses for the administration of any redress fund. If

a representative of the Commission decides that direct redress to consumers is wholly or

partially impracticable or money remains after such redress is completed, the Commission

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may apply any remaining money for such related relief (including consumer information

remedies) as it determines to be reasonably related to Defendants’ practices alleged in the

Complaint. Any money not used for relief is to be deposited to the U.S. Treasury.

Defendants have no right to challenge any actions the Commission or its representatives

may take pursuant to this Subsection.

VI. CUSTOMER INFORMATION

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees

and all other persons in active concert or participation with any of them, who receive actual notice

of this Order, are permanently restrained and enjoined from directly or indirectly failing to

provide sufficient customer information to enable the Commission to efficiently administer

consumer redress. If a representative of the Commission requests in writing any information

related to redress, Defendants must provide it, in the form prescribed by the Commission, within

14 days.

VII. ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of this

Order:

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

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury.

B. For 5 years after entry of this Order, each Individual Defendant for any business

that such Defendant, individually or collectively with any other Defendants, is the

majority owner or controls directly or indirectly, and each Corporate Defendant, must

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deliver a copy of this Order to: (1) all principals, officers, directors, and LLC managers

and members; (2) all employees having managerial responsibilities for conduct related to

the subject matter of the Order and all agents and representatives who participate in the

advertising, marketing, promotion, offering for sale or financing, or sale and financing of

vehicles; and (3) any business entity resulting from any change in structure as set forth in

the Section titled Compliance Reporting. Delivery must occur within 7 days of entry of

this Order for current personnel. For all others, delivery must occur before they assume

their responsibilities.

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

Order, that Defendant must obtain, within 30 days, a signed and dated acknowledgment of

receipt of this Order.

VIII. COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendants make timely submissions to the

Commission:

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

report, sworn under penalty of perjury:

1. Each Defendant must: (a) identify the primary physical, postal, and email

address and telephone number, as designated points of contact, which

representatives of the Commission may use to communicate with Defendant; (b)

identify all of that Defendant’s businesses by all of their names, telephone

numbers, and physical, postal, email, and Internet addresses; (c) describe the

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activities of each business, including the goods and services offered, the means of

advertising, marketing, and sales, and the involvement of any other Defendant

(which Individual Defendants must describe if they know or should know due to

their own involvement); (d) describe in detail whether and how that Defendant is

in compliance with each Section of this Order; and (e) provide a copy of each

Order Acknowledgment obtained pursuant to this Order, unless previously

submitted to the Commission.

2. Additionally, each Individual Defendant must: (a) identify all telephone

numbers and all physical, postal, email and Internet addresses, including all

residences; (b) identify all business activities, including any business for which

such Defendant performs services whether as an employee or otherwise and any

entity in which such Defendant has any ownership interest; and (c) describe in

detail such Defendant’s involvement in each such business, including title, role,

responsibilities, participation, authority, control, and any ownership.

B. For 20 years after entry of this Order, each Defendant must submit a compliance

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

1. Each Defendant must report any change in: (a) any designated point of

contact; or (b) the structure of any Corporate Defendant or any entity that

Defendant has any ownership interest in or controls directly or indirectly that may

affect compliance obligations arising under this Order, including: creation,

merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate that

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engages in any acts or practices subject to this Order.

2. Additionally, each Individual Defendant must report any change in: (a)

name, including aliases or fictitious name, or residence address; or (b) title or role

in any business activity, including any business for which such Defendant

performs services whether as an employee or otherwise and any entity in which

such Defendant has any ownership interest, and identify the name, physical

address, and any Internet address of the business or entity.

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

bankruptcy petition, insolvency proceeding, or similar proceeding by or against such

Defendant within 14 days of its filing.

D. Any submission to the Commission required by this Order to be sworn under

penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as

by concluding: “I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct. Executed on: _____” and supplying the

date, signatory’s full name, title (if applicable), and signature.

E. Unless otherwise directed by a Commission representative in writing, all

submissions to the Commission pursuant to this Order must be emailed to

DEbrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: Associate

Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission,

600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin:

FTC v. Passport Motorcars, Inc.

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IX. RECORDKEEPING

IT IS FURTHER ORDERED that Defendants must create certain records for 20 years

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

Defendant and each Individual Defendant for any business that such Defendant, individually or

collectively with any other Defendants, is a majority owner or controls directly or indirectly, must

create and retain the following records:

A. accounting records showing the revenues from all goods or services sold;

B. personnel records showing, for each person providing services, whether as an

employee or otherwise, that person’s: name; addresses; telephone numbers; job title or

position; dates of service; and (if applicable) the reason for termination;

C. records of all consumer complaints and refund requests, whether received directly

or indirectly, such as through a third party, and any response. For purposes of this

provision, consumer complaint(s) shall mean any written, oral, or electronic allegation,

charge, claim, demand, dispute, or lawsuit concerning the subject matter of the Order;

D. a copy of each unique advertisement or other marketing material;

E. each employee’s Fair Lending Training Acknowledgement Form; and

F. all records necessary to demonstrate full compliance with each provision of this

Order, including all submissions to the Commission.

X. COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’ compliance

with this Order and any failure to transfer any assets as required by this Order:

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A. Within 14 days of receipt of a written request from a representative of the

Commission, each Defendant must: submit additional compliance reports or other

requested information, which must be sworn under penalty of perjury; appear for

depositions; and produce documents for inspection and copying. The Commission is also

authorized to obtain discovery, without further leave of court, using any of the procedures

prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic depositions),

31, 33, 34, 36, 45, and 69.

B. For matters concerning this Order, the Commission is authorized to communicate

directly with each Defendant. Defendant must permit representatives of the Commission

to interview any employee or other person affiliated with any Defendant who has agreed

to such an interview. The person interviewed may have counsel present.

C. The Commission may use all other lawful means, including posing, through its

representatives as consumers, suppliers, or other individuals or entities, to Defendants or

any individual or entity affiliated with Defendants, without the necessity of identification

or prior notice. Nothing in this Order limits the Commission’s lawful use of compulsory

process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1.

D. Upon written request from a representative of the Commission, any consumer

reporting agency must furnish consumer reports concerning Individual Defendants,

pursuant to Section 604(1) of the Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(1).

XI. RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for purposes

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r 

1 

_______________________________ 

____________________ 

UNITED STATES DISTRICT JUDGE

SO STIPULATED AND AGREED:

Federal Trade

Attorneys 

Larkin Turner

Samuel Jacobson

FEDERAL TRADE COMMISSION

FOR PLAINTIFF: 

Commission 

Email: sjacobson@ftc.gov 

Fax: 202-326-3768

Tel: 202-876-5590 (Jacobson) 

Washington, DC 20580 

600 Pennsylvania Ave. NW

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FOR DEFENDANTS: 

Allen H. Denson, Esq. 

Stephen J. Newman, Esq. 

Stroock & Stroock & Lavan LLP 

1875 K Street NW, Suite 800 

Washington, DC 20006 

Tel: 202-739-2805 

Email: adenson@stroock.com 

Date: 

DEFENDANTS: Passport Automotive Group, Inc., Passport Motorcars, Inc., Import 

Motorcars, Inc., Autos International, Inc., Passport Imports, Inc., Passport Motors 

Holding, Inc., Passport of Alexandria, Inc., International Motorcars, Inc., Everett 

He~b, ill and~ Date: fJ' /, ~~ 9-'J-.-

EVE&UTH, Ill TNDIVJDUALL Y ~ ,j 

AND AS AN OFFICER OF 

PASSPORT AUTOMOTIVE GROUP, INC., 

PASSPORT MOTORCARS, INC., 

IMPORT MOTORCARS, INC., 

AUTOS INTERNATIONAL, INC., 

PASSPORT IMPORTS, INC., 

PASSPORT MOTORS HOLDING, INC., 

PASSPORT OF ALEXANDRIA, INC., 

INTERNA AL MOTORCARS, INC. 

JAY KLEIN IN IVIDUALL Y 

AND AS AN O FICER OF 

PASSPORT A TOMOTIVE GROUP, INC., 

PASSPORT TORCARS, INC., 

IMPORT MO ORCARS, INC., 

AUTOS INTERNATIONAL, INC., 

PASSPORT IMPORTS, INC., 

PASSPORT MOTORS HOLDING, INC., 

PASSPORT OF ALEXANDRIA, INC., 

INTERNATIONAL MOTORCARS, INC. 

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