1 

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF TEXAS 

HOUSTON DIVISION

UNITED STATES OF AMERICA, 

Plaintiff,

v.

TURBO SOLUTIONS INC., f/k/a Alex Miller 

Financial Services Inc., d/b/a Alex Miller 

Credit Repair, and 

ALEXANDER V. MILLER, in his individual 

and corporate capacity, 

Defendants. 

Civil Action No.

FILED UNDER SEAL

COMPLAINT FOR CIVIL PENALTIES, PERMANENT INJUNCTION, 

MONETARY RELIEF, AND OTHER RELIEF 

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“FTC”), pursuant to Section 16(a)(1) of the 

FTC Act, 15 U.S.C. § 56(a)(1), for its Complaint alleges:

1. This is an action arising under Sections 5(a), 5(m)(1)(A), 13(b), 16(a), and 19 of

the FTC Act, 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), 56(a), and 57b, Section 410(b) of the Credit 

Repair Organizations Act (“CROA”), 15 U.S.C. § 1679h(b), and Section 6(b) of the Telemarketing 

and Consumer Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. § 6105(b), to 

obtain civil penalties, permanent injunctive relief, monetary relief, and other relief for Defendants’ 

acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), CROA, 15 U.S.C. 

§§ 1679-1679l, and the FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. Part 310, in

connection with Defendants’ marketing and sale of credit repair services.

4:22-mc-369
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NATURE OF THE CASE

2. Since at least 2018, Defendants have operated an unlawful credit repair scam that 

has harmed vulnerable consumers nationwide. Through Internet websites, social media, and 

telemarketing, Defendants falsely claim that, for a fee ranging from several hundred dollars to 

more than $1,500, they can improve consumers’ credit scores. Defendants attempt to improve the 

credit scores of their customers by filing false identity theft reports on the FTC’s identitytheft.gov 

website and by other means, all of which are either ineffective or unlawful. In addition, Defendants 

have routinely solicited and accepted prohibited advanced fees for their credit repair services and 

fail to make required disclosures regarding those services.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 

1331 because it arises under the law of the United States. It also has subject matter jurisdiction 

over this action pursuant to 28 U.S.C. § 1337(a) because it arises under an Act of Congress 

regulating interstate commerce, under 28 U.S.C. § 1345 because the United States is the Plaintiff, 

and under 28 U.S.C. § 1355 because the United States seeks a civil money penalty. At all times 

relevant to this Complaint, Defendants have maintained a substantial course of trade in or affecting 

commerce, as “commerce” is defined in Section 4 of the FTC Act, 15 U.S.C. § 44.

4. The Court has personal jurisdiction over Defendants because Defendants reside in 

and have their principal place of business in this district and because the alleged acts giving rise to 

the claims occurred in this District and elsewhere in the United States.

5. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), (c)(1), and 

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

6. Plaintiff is the United States of America.

7. Defendant Turbo Solutions Inc. (“Turbo Solutions”) is a Wyoming company with 

its principal place of business at 440 Louisiana Street, Suite 575, Houston, Texas. Turbo Solutions 

was administratively dissolved for tax delinquency on June 9, 2021.

1 Turbo Solutions has also 

used mailing addresses of 77 Sugar Creek Center Boulevard, Suite 611, Sugar Land, Texas and 

7890 Kemper Circle, Beaumont, Texas. Turbo Solutions was formerly known as Alex Miller 

Financial Services Inc. and has done business as Alex Miller Credit Repair. At all times relevant

to this Complaint, acting alone or in concert with others, Turbo Solutions has marketed and sold 

credit repair services to consumers throughout the United States. Turbo Solutions has employees 

in the United States and has employees or contractors in the Philippines. Turbo Solutions transacts 

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

8. Defendant Alexander V. Miller is or was an owner, officer, director, or manager of 

Turbo Solutions. He is an authorized signatory on many of Defendants’ bank accounts. At all times 

relevant to this Complaint, acting alone or in concert with others, he has formulated, directed, 

controlled, had the authority to control, or participated in the acts and practices set forth in this 

Complaint. Defendant Alexander Miller resides in this District and, in connection with the matters 

alleged herein, transacts or has transacted business in this District and throughout the United 

States.

1 Under Wyoming law, a corporation continues to exist as a corporation after administrative 

dissolution and may be named in a civil proceeding. See Wyo. Stat. Ann. § 17-16-1405(a), 

(b)(v).
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THE FTC ACT

9. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.”

10. Misrepresentations or deceptive omissions of material fact constitute deceptive acts 

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

THE CREDIT REPAIR ORGANIZATIONS ACT

11. The Credit Repair Organizations Act (“CROA”) took effect on April 1, 1997. 

CROA’s purposes are (1) to ensure that prospective buyers of the services of credit repair 

organizations receive the information necessary to make an informed decision regarding the 

purchase of such services; and (2) to protect the public from unfair or deceptive advertising and 

business practices by credit repair organizations. 15 U.S.C. § 1679(b).

12. CROA defines a “credit repair organization” as “any person who uses any 

instrumentality of interstate commerce or the mails to sell, provide, or perform (or represent that 

they can or will sell, provide, or perform) any service, in return for the payment of money or other 

valuable consideration, for the express or implied purpose of . . . improving any consumers’ credit 

record, credit history, or credit rating. . . .” 15 U.S.C. § 1679a(3).

13. CROA prohibits all persons from making any statement, or counseling or advising 

any consumer to make any statement, which is untrue or misleading with respect to any consumer’s 

credit worthiness, credit standing, or credit capacity to any consumer reporting agency. 15 U.S.C. 

§ 1679b(a)(1)(A). CROA also bars all persons from making or using any untrue or misleading 

representation of the services of the credit repair organization. 15 U.S.C. § 1679b(a)(3).

Furthermore, CROA prohibits all persons from engaging, directly or indirectly, in any act, practice, 

or course of business that constitutes or results in the commission of, or an attempt to commit, a 
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fraud or deception on any person in connection with the offer or sale of the services of the credit 

repair organization. 15 U.S.C. § 1679b(a)(4).

14. CROA prohibits credit repair organizations from charging or receiving any money 

or other valuable consideration for the performance of any service which the credit repair 

organization has agreed to perform before such service is fully performed. 15 U.S.C. § 1679b(b).

15. Credit repair organizations must provide consumers with a written statement 

containing prescribed language concerning “Consumer Credit File Rights Under State and Federal 

Law” before any contract or agreement is executed. 15 U.S.C. § 1679c(a).

16. Credit repair organizations must also include certain terms and conditions in any 

contract or agreement for services, including a conspicuous statement in bold face type, in 

immediate proximity to the space reserved for the consumer’s signature on the contract, which 

reads as follows: “You may cancel this contract without penalty or obligation at any time before 

midnight of the 3rd business day after the date on which you signed the contract. See the attached 

notice of cancellation form for an explanation of this right.” 15 U.S.C. § 1679d(b)(4).

17. CROA directs credit repair organizations to provide consumers with a “Notice of 

Cancellation” form, in duplicate, containing prescribed language concerning consumers’ three-day 

right to cancel that consumers can use to cancel the contract. 15 U.S.C. § 1679e(b). Any consumer 

who enters into a contract with a credit repair organization shall be given a copy of the completed 

contract and all disclosures required under the Act and a copy of any other document the credit 

repair organization requires the consumer to sign. 15 U.S.C. § 1679e(c).

18. A violation of CROA constitutes an unfair or deceptive act or practice in commerce 

in violation of Section 5(a) of the FTC Act (15 U.S.C. § 45(a)), 15 U.S.C. § 1679h(b)(1), and shall 

be treated as a violation of an FTC trade regulation rule. 15 U.S.C. § 1679h(b)(2). A violation of 
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CROA made with the knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 

45(m)(1)(A), is subject to monetary civil penalties for each violation of CROA. See 15 U.S.C. § 

45(m)(1)(A), as modified by Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 

1990, 28 U.S.C. § 2461, the Federal Civil Penalties Inflation Adjustment Act Improvements Act 

of 2015, Public Law 114-74, sec. 701, 129 Stat. 599 (2015); see also 16 C.F.R. § 1.98(d).

19. Each instance in which Defendants have failed to comply with CROA constitutes 

a separate violation of CROA for the purpose of assessing monetary civil penalties.

THE TELEMARKETING SALES RULE

20. In 1994, Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 U.S.C. §§ 6101-

6108. The FTC adopted the original Telemarketing Sales Rule in 1995, extensively amended it in 

2003, and amended certain sections thereafter. 16 C.F.R. Part 310.

21. Under the TSR, a “telemarketer” means any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a consumer or donor. 16 C.F.R. § 

310.2(ff). A “seller” means any person who, in connection with a telemarketing transaction, 

provides, offers to provide, or arranges for others to provide goods or services to the customer in 

exchange for consideration. 16 C.F.R. § 310.2(dd).

22. The TSR prohibits sellers and telemarketers from misrepresenting, directly or by 

implication, any material aspect of the performance, efficacy, nature, or central characteristics of 

goods or services that are the subject of a sales offer. 16 C.F.R. § 310.3(a)(2)(iii).

23. The TSR bars sellers and telemarketers from requesting or receiving payment of 

any fee or consideration for goods or services represented to remove derogatory information from, 

or improve, a person’s credit history, credit record, or credit rating until: (a) the time frame in 
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which the seller has represented all of the goods or services will be provided to that person has 

expired; and (b) the seller has provided the person with documentation in the form of a consumer 

report from a consumer reporting agency demonstrating that the promised results have been 

achieved, such report having been issued more than six months after the results were achieved. 16 

C.F.R. § 310.4(a)(2). The TSR also prohibits sellers and telemarketers from requesting or receiving 

payment of any fee or consideration in advance of obtaining a loan or other extension of credit 

when the seller or telemarketer has guaranteed or represented a high likelihood of success in 

obtaining or arranging a loan or other extension of credit for a person. 16 C.F.R. § 310.4(a)(4). 

24. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), and Section 

18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR constitutes an unfair or 

deceptive act or practice in or affecting commerce, in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a). A violation of the TSR made with the knowledge required by Section 5(m)(1)(A) 

of the FTC Act, 15 U.S.C. § 45(m)(1)(A), is subject to monetary civil penalties for each violation. 

See 15 U.S.C. § 45(m)(1)(A), as modified by Section 4 of the Federal Civil Penalties Inflation 

Adjustment Act of 1990, 28 U.S.C. § 2461, the Federal Civil Penalties Inflation Adjustment Act 

Improvements Act of 2015, Public Law 114-74, sec. 701, 129 Stat. 599 (2015); see also 16 C.F.R. 

§ 1.98(d).

DEFENDANTS’ UNLAWFUL BUSINESS ACTIVITES

Defendants’ Deceptive Website and Social Media Accounts

25. To induce consumers to purchase their credit repair services, Defendants 

maintained an Internet website, alexmillercreditrepair.com, and continue to operate various social 

media accounts on which they market and make deceptive claims regarding their credit repair 

services. Defendants have claimed to be “a professional credit corrections company specializing 
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in restructuring and rebuilding your credit.” Individual Defendant Alexander Miller has claimed

to be a “Credit Repair Expert on Debt Validation.”

26. Defendants’ marketing routinely claims that they improve consumers’ credit scores 

through a two-step process: removing negative information from consumers’ credit histories or 

credit reports and adding positive credit history. For the first step, Defendants have claimed to 

remove negative information that involves “advanced disputing” of information on consumers’ 

credit reports. For the second step, Defendants have claimed that they can add “credit building 

products” to consumers’ credit histories that will result in a positive payment history being added 

to the consumer’s credit history or credit report.

27. Defendants have claimed that this two-step process will significantly increase 

consumers’ credit scores and their ability to gain access to mortgages, car loans, and eligibility for 

funding at lower interest rates.

28. For example, Defendants’ website alexmillercreditrepair.com featured an 

embedded video that claimed: “You’re your credit,” “700+ credit scores,” “Larger loan amounts,” 

and “Higher credit card limits.” Defendants’ website also displayed the following statements:

• Repair Your Credit Today!! Guaranteed Results in 40 days!

• Delete Negative Accounts

• We Delete Inaccurate and Negative Accounts

• We provide trade lines (Credit Boosters).

• “The 3 Round Burst”...is now known as the most effective way to get negative 

accounts deleted off credit reports.

• The 3 Round Burst consist [sic] of 3 master rounds of advanced disputing. Each 

round is 30-40 days. You will see massive deletion results at the end of each round.

• Will my score go up? Your score will increase according to how many positive 

accounts you have after we delete the negative accounts.
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• Your scores will increase according to how many Positive Accounts you have after 

the Negative/Inaccurate accounts are deleted. If you don’t have any Positive 

Accounts then we have Credit Building Products that will help to strengthen you 

credit scores.

• Alex Miller Credit Repair has helped over 10,000 clients repair their credit and 

purchase the cars, homes and businesses of their dreams! 

29. Defendants have made the following statements on their Instagram “feed:”

• 2 STEP PROCESS: Credit Repair is a 2 step process. Step 1 is to delete the negative 

accounts. Step 2: is for you to add credit building products/tradelines to BOOST 

your scores. If you don’t do BOTH steps or try to skip a step it won’t work. So you 

have to do both.

• Credit repair is a 2 STEP PROCESS. Step 1: The removal of at least 85% of your 

inaccurate negative accounts. Step [2]: is for you to replace the negative accounts 

that we helped to remove with some positive accounts which we call credit building 

products/tradelines which will help INCREASE your scores to help get you that 

approval that you need.

• My client [] did everything she was supposed to do and that’s why it worked out 

for her to buy this house. 1. She was patient during Covid. 2. She purchased both 

credit building products/tradelines. . .

• While we clean your inaccurate negative accounts you MUST DO 2 THINGS to 

see HUGE INCREASES in your scores. 1. Purchase both credit building 

products/tradelines. . . .

• Student Loans = Deleted/Collections = Deleted/Charge offs = Deleted/Evictions = 

Deleted/Bankruptcies = Deleted/Repos = Deleted/Late Payments = 

Deleted/Hospital Bills = Deleted/Foreclosures = Deleted

30. Defendants’ website and Instagram account also promote their services using

purported testimonials that display pictures of homes and automobiles with captions such as, “I 

fixed her credit! She bought this house.”
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Defendants’ Deceptive Telemarketing

31. Defendants’ website and social media accounts invite consumers to call a telephone 

number for more information on their credit repair services. The Defendants’ Instagram account 

also encourages consumers to text message Defendants their contact information.

32. When consumers contact Defendants using the telephone number listed on 

Defendants’ website or Instagram account, they speak with one of Defendants’ telephone

representatives. These representatives make many of the same representations included on 

Defendants’ website and social media accounts. For example, Defendants’ telephone 

representatives have claimed that Defendants can remove negative items from consumers’ credit 

reports. They tell consumers that Defendants achieve their results by sending the major credit 

reporting agencies several rounds of letters that dispute the consumers’ negative transactions.

33. Defendants’ telephone representatives also tell consumers that purchasing credit 

building products, such as store credit cards (that can only be used to purchase goods or services 

from a particular retailer), will improve consumers’ credit scores. 

34. Defendants’ telephone representatives have even claimed that as a result of 

Defendants’ services, consumers’ credit scores will improve by 200 points in 90 days.

Defendants’ Unlawful Enrollment Process

35. Before providing any of the promised credit repair services, Defendants’ telephone 

representatives require consumers to make an upfront payment of up to $1,500, the amount 

typically quoted by sales representatives and listed on Defendants’ Instagram feed. Occasionally, 

Defendants’ telephone representatives have offered consumers a lower fee if the consumers agree

to purchase credit repair services that day, or may allow the customer to make multiple payments.
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36. Defendants’ telephone representatives require consumers to provide a credit or 

debit card number on the phone. They tell consumers that they must make at least a down payment 

immediately. Defendants charge consumers’ credit or debit cards or debit payment from 

consumers’ bank accounts soon after they receive the billing information, and well before the 

promised credit repair services have been provided or completed.

37. Defendants’ Instagram account makes clear that Defendants require payment 

before the work is performed. For example, one post reads “The #1 Reason why we have to stop 

or pause Credit repair. Our most recent attempt to bill your credit card failed. Please update your 

credit card information to restore access. Will set status to inactive due to no response.” Another 

post reads “All you gotta do is 2 simple things. 1. Don’t miss your monthly payments. 2. Keep 

your IdentityQ active. And you will see the same results as this client.”

38. Although Defendants’ website indicated that consumers should complete and sign 

an online contract, Defendants have allowed consumers to enroll by sending Defendants a copy of 

their driver’s license, social security number, and credit or debit card or bank account information.

At least one consumer enrolled without signing a contract.

39. Consumers who do sign a contract are generally not informed of all of their rights 

before they execute the contract. In some cases Defendants have not provided consumers with a 

written statement containing prescribed language concerning “Consumer Credit File Rights Under 

State and Federal Law.” Defendants’ contracts have also failed to display a conspicuous statement 

in bold face type next to the space reserved for the consumer’s signature on the contract, which 

reads: “You may cancel this contract without penalty or obligation at any time before midnight of 

the 3rd business day after the date on which you signed the contract. See the attached notice of 

cancellation form for an explanation of this right.” Defendants have further failed to provide 
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consumers with the aforementioned “Notice of Cancellation” form, in duplicate, that explains 

consumers’ three-day right to cancel the contract. Defendants have also failed to provide many 

consumers with copies of the contracts they signed. 

Defendants Do Not Follow Through on Credit Repair Promises

40. As detailed above, Defendants claim they can improve consumers’ credit scores by 

removing negative items from their credit report and adding positive credit history. However, there 

is no legal way to remove accurate, non-obsolete negative items from a consumer’s credit history. 

Defendants’ strategy for removing negative items has included filing bogus identity theft reports 

and fabricating baseless credit disputes. Defendants purport to add “positive credit history” by 

instructing consumers to apply for store credit cards or to pay to be added to as an authorized user 

on a “trade line,” i.e., a line of credit. Defendants’ services do little or nothing to increase 

consumers’ credit scores.

41. Purportedly to remove consumers’ negative credit history, Defendants have

submitted dispute letters to one or more credit reporting agencies challenging, without support,

most or all of the negative information in consumers’ credit reports. These unsupported challenges 

rarely if ever cause credit reporting agencies to delete or change any consumer’s credit 

information.

42. Defendants also have attempted to remove negative credit history by, unbeknownst 

to consumers, filing or causing to be filed on the FTC’s identitytheft.gov website, fake identify 

theft reports asserting that the negative information on consumers’ reports was the result of identity 

theft. In fact, none of the consumers on whose behalf Defendants filed, or caused to be filed, these

identity theft reports were victims of identity theft, nor was the negative information on their credit 

reports caused by identity theft.
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43. Even if these identity theft reports had not been fake, simply filing an identity theft 

report will not automatically result in the removal of negative information from consumers’ credit 

reports. Credit reporting agencies typically review identity theft reports submitted to them, and if 

those reports are determined to have been wrongfully filed, the credit reporting agency may decline 

to remove the requested negative information.

44. Defendants’ credit building products similarly fail to improve their credit as 

promised. The store credit cards and trade lines that Defendants recommend for this purpose do 

not have the positive impact on the consumer’s credit score promised by Defendants.

45. In summary, consumers who purchase Defendants’ credit repair services do not 

obtain the promised improvements to their credit scores. In fact, at least one consumer reported 

that her credit score actually worsened after purchasing Defendants’ credit repair services.

46. Since at least 2018, Defendants have collected over $9 million from thousands of 

consumers through their unlawful credit repair scheme. The FTC has received dozens of consumer 

complaints about Defendants’ scams.

47. Based on the facts and violations of law alleged in this Complaint, the Government

has reason to believe that Defendants are violating or are about to violate laws enforced by the 

FTC.

COUNT I

Violations of the FTC Act

48. Paragraphs 1-47 are incorporated as if set forth herein.

49. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of credit repair services, Defendants have represented, directly or 

indirectly, expressly or by implication, that Defendants will significantly improve consumers’ 
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credit scores by, among other things, a) removing negative information from consumers’ credit 

reports or profiles; and/or b) selling credit building products, such as store credit cards.

50. In fact, when Defendants have made the representations set forth above, such 

representations were false or misleading. 

51. Therefore, Defendants’ false or misleading representations as set forth above 

constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

COUNT II

Fraudulent or Deceptive Credit Repair Practices

52. Paragraphs 1-51 are incorporated as if set forth herein.

53. Defendants are a “credit repair organization” under Section 403(3) of CROA, 15 

U.S.C. § 1679a(3).

54. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of services to consumers by a credit repair organization, Defendants have 

engaged in practices prohibited by CROA. For example, Defendants have made statements, or 

counseled or advised consumers to make statements, which are untrue or misleading with respect 

to their credit worthiness, credit standing, or credit capacity to consumer reporting agencies, 

including by filing or causing to be filed identity theft reports even when consumers have not, in 

fact, been victims of identity theft.

55. In addition, Defendants have made untrue or misleading representations to 

consumers, including that Defendants will significantly improve consumers’ credit scores by, 

among other things: a) removing negative information from consumers’ credit reports or profiles; 

and/or b) selling credit building products, such as store credit cards, that will appear on consumers’ 

credit reports or profiles.
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56. Defendants also have engaged, directly or indirectly, in acts, practices, or course of 

business that constitute or result in the commission of, or an attempt to commit, a fraud or 

deception on any person in connection with the offer or sale of the services of the credit repair 

organization, including by filing identity theft reports on behalf of consumers even when 

consumers have not, in fact, been victims of identity theft.

57. Defendants have actual knowledge or knowledge fairly implied of the federal credit 

repair organization laws or analogous state laws that apply to and regulate credit repair 

organizations.

58. Therefore, Defendants’ acts or practices as set forth above violate Section 404(a)

of CROA, 15 U.S.C. § 1679b(a).

COUNT III

Violation of Prohibition against Charging Advanced Fees for Credit Repair Services

59. Paragraphs 1-58 are incorporated as if set forth herein.

60. In numerous instances, in connection with the advertising, marketing, promotion, 

offering for sale, or sale of services to consumers by a credit repair organization, Defendants have 

charged or received money or other valuable consideration for the performance of credit repair 

services that Defendants have agreed to perform before such services were fully performed.

61. Therefore, Defendants’ acts or practices as set forth above violate Section 404(b) 

of CROA, 15 U.S.C. § 1679b(b).

COUNT IV

Failure to Make Required Disclosures

62. Paragraphs 1-61 are incorporated as if set forth herein.

63. In connection with the sale of services to consumers by a credit repair organization,

Defendants have failed to provide a written statement of “Consumer Credit File Rights Under State 
16

and Federal Law,” in the form and manner required by CROA, to consumers before any contract 

or agreement was executed.

64. Therefore, Defendants’ acts or practices as set forth above violate Section 405 of 

CROA, 15 U.S.C. § 1679c.

COUNT V

Failure to Include Required Terms and Conditions in Contracts

65. Paragraphs 1-64 are incorporated as if set forth herein.

66. In connection with the sale of services to consumers by a credit repair organization,

Defendants have failed to include in their consumer contracts the following required terms and 

conditions: the specific conspicuous statement in bold face type, in immediate proximity to the 

space reserved for the consumer’s signature on the contract, regarding the consumers’ right to 

cancel the contracts without penalty or obligation at any time before the third business day after 

the date on which consumers signed the contracts.

67. Therefore, Defendants’ acts or practices as set forth above violate Section 406 of 

CROA, 15 U.S.C. § 1679d.

COUNT VI

Failure to Provide Copy of Contract and Cancellation Form

68. Paragraphs 1-67 are incorporated as if set forth herein.

69. In connection with the sale of services to consumers by a credit repair organization, 

Defendants have failed to provide with their consumer contracts a form with the heading “Notice 

of Cancellation,” in the form and manner required by CROA to consumers. Similarly, Defendants 

have failed to provide consumers who entered into a contract with Defendants a copy of the 

completed contract and all disclosures required under CROA and a copy of any other document 

Defendants required the consumers to sign. 
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70. Therefore, Defendants’ acts or practices as set forth above violate Section 407 of 

CROA, 15 U.S.C. § 1679e.

COUNT VII

Violations of Prohibition on Deceptive Telemarketing Practices

71. Paragraphs 1-70 are incorporated as if set forth herein.

72. Defendants are “seller[s]” or “telemarketer[s]” engaged in “telemarketing,” as 

those terms are defined in the TSR, 16 C.F.R. § 310.2(dd), (ff), and (gg).

73. In numerous instances, in connection with the telemarketing of credit repair 

services, Defendants have misrepresented, directly or by implication, material aspects of the 

performance, efficacy, nature, or central characteristics of their credit repair services, including 

but not limited to, that Defendants will significantly improve consumers’ credit scores by, among 

other things: a) removing negative information from consumers’ credit reports or profiles; and/or

b) selling credit building products, such as store credit cards, that will appear on consumers’ credit 

reports or profiles.

74. Defendants have actual knowledge or knowledge fairly implied of the TSR or 

analogous federal or state laws that regulate telemarketing. 

75. Therefore, Defendants’ acts or practices as set forth above violate Section 310.3 of 

the TSR, 16 C.F.R. § 310.3.

COUNT VIII

Violation of Prohibition against Abusive Telemarketing Practices

76. Paragraphs 1-75 are incorporated as if set forth herein.

77. In connection with the telemarketing of credit repair services, Defendants have 

engaged in abusive telemarketing practices in violation of the TSR. Defendants have requested or 

received payment of a fee or consideration for credit repair services before: (a) the time frame in 
18

which Defendants have represented all of the credit repair services will be provided to consumers 

has expired; and (b) Defendants have provided consumers with documentation in the form of a 

consumer report from a consumer reporting agency demonstrating that the promised results have 

been achieved, such report having been issued more than six months after the results were 

achieved.

78. In addition, Defendants have requested or received payment of a fee or 

consideration in advance of obtaining a loan or other extension of credit when the seller or 

telemarketer has guaranteed or represented a high likelihood of success in obtaining or arranging 

a loan or other extension of credit for a person.

79. Defendants’ acts or practices as set forth above violate Section 310.4 of the TSR, 

16 C.F.R. § 310.4.

CONSUMER INJURY

80. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act, CROA, and the TSR. Absent injunctive 

relief by this Court, Defendants are likely to continue to injure consumers and harm the public 

interest.

PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court:

A. Grant preliminary injunctive and ancillary relief as may be necessary to avert the likelihood 

of consumer injury during the pendency of this action and to preserve the possibility of 

effective final relief, including but not limited to, temporary and preliminary injunctions, 

an order freezing assets, and appointment of a receiver;
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B. Enter a permanent injunction to prevent future violations of the FTC Act, CROA, and the 

TSR by Defendants;

C. Award monetary and other relief as provided by law; 

D. Award Plaintiff monetary civil penalties from Defendants for every violation of CROA 

and the TSR; and

E. Award any other and additional relief as the Court may determine to be just and proper.

Dated: March 1, 2022 Respectfully submitted,

FOR FEDERAL TRADE

COMMISSION:

JAMES REILLY DOLAN

Acting General Counsel

MALINI MITHAL

Associate Director

Division of Financial Practices

HEATHER ALLEN

Assistant Director

Division of Financial Practices

GREGORY A. ASHE

Federal Trade Commission

600 Pennsylvania Avenue NW

Washington, DC 20580

Telephone: 202-326-3719

Facsimile: 202-326-3768

Email: gashe@ftc.gov

FOR PLAINTIFF UNITED STATES OF 

AMERICA:

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General 

Civil Division

ARUN G. RAO

Deputy Assistant Attorney General

GUSTAV W. EYLER

Director

Consumer Protection Branch

LISA K. HSIAO

Assistant Director

CLAUDE F. SCOTT

Senior Litigation Counsel

STEPHEN C. TOSINI

Senior Trial Counsel

AMY P. KAPLAN

MARCUS P. SMITH

Trial Attorneys 

JENNIFER B. LOWERY

United States Attorney 

By: s/ Richard A. Kincheloe 

Richard Kincheloe
20

Assistant United States Attorney

United States Attorney's Office

Southern District of Texas

Texas Bar No. 24068107

S.D. Tex. ID No. 1132346

1000 Louisiana Street, Suite 2300

Houston, Texas 77002

Phone: (713) 567-9422

Fax: (713) 718-3303

Richard.Kincheloe@usdoj.gov