Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 1 of 36 PageID 1760 

UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

JACKSONVILLE DIVISION 

FEDERAL TRADE COMMISSION, 

No. 3:22-cv-487-TJC-MCR 

Plaintiff, 

v. 

MICHAEL RANDO, et al., 

Defendants. 

STIPULATED ORDER FOR PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO DEFENDANTS MICHAEL RANDO, 

VALERIE RANDO, PROSPERITY TRAINING TECHNOLOGY LLC, FIRST 

COAST MATCHMAKERS INC., FIRST COAST MATCHMAKERS LLC, 

DIGITAL BUSINESS SCALING LLC, AND FINANCIAL CONSULTING 

MANAGEMENT GROUP LLC 

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

Complaint for Permanent Injunction and Other Equitable Relief (Doc. 1) 

(“Complaint”), for a permanent injunction, monetary relief, and other relief in this 

matter, pursuant to Sections 13(b) and 19 of the Federal Trade Commission Act 

(“FTC Act”), 15 U.S.C. §§ 53(b), 57b. The Commission and Defendants Michael 

Rando, Valerie Rando, Prosperity Training Technology LLC, First Coast 

Matchmakers Inc., First Coast Matchmakers LLC, Digital Business Scaling LLC, 

and Financial Consulting Management Group LLC (“Defendants”), stipulate to 

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entry of this Stipulated Order for Permanent Injunction and Monetary Judgment 

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

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The Complaint charges that Defendants participated in deceptive acts 

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

provisions of the Credit Repair Organizations Act (“CROA”), 15 U.S.C. §§ 1679-

1679j; multiple provisions of the FTC’s Telemarketing Sales Rule (“TSR”), 16 

C.F.R. Part 310; Section 1401(b)(2) of the COVID-19 Consumer Protection Act, 15 

U.S.C. § 45 note (CCPA § 1401(b)(2)); and multiple provisions of the FTC’s Trade 

Regulation Rule entitled “Disclosure Requirements and Prohibitions Concerning 

Business Opportunities” (“Business Opportunity Rule” or “BOR”), 16 C.F.R. Part 

437. 

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. 

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DEFINITIONS 

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

A. “Asset” means any legal or equitable interest in, right to, or claim to, 

any property, wherever located and by whomever held, whether tangible, intangible, 

digital, intellectual property, or otherwise. 

B. “Business Opportunity” means a commercial arrangement in which: 

1. A Seller solicits a prospective Purchaser to enter into a new 

business; and 

2. The prospective Purchaser makes a required payment; and 

3. The Seller, expressly or by implication, orally or in writing, 

represents that the Seller or one or more Designated Persons will: 

i. Provide locations for the use or operation of equipment, 

displays, vending machines, or similar devices, owned, leased, 

controlled, or paid for by the Purchaser; or 

ii. Provide outlets, accounts, or customers, including Internet 

outlets, accounts, or customers, for the Purchaser’s goods or services; or 

iii. Buy back any or all of the goods or services that the 

Purchaser makes, produces, fabricates, grows, breeds, modifies, or 

provides, including providing payment for such services as, for 

example, stuffing envelopes from the Purchaser’s home. 

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C. “Corporate Defendant” means Prosperity Training Technology LLC 

(d/b/a The Credit Game and The Credit Game University), First Coast 

Matchmakers Inc. (d/b/a Wholesale Tradelines), First Coast Matchmakers LLC 

(d/b/a Wholesale Tradelines), Digital Business Scaling LLC, Financial Consulting 

Management Group LLC, and each of their subsidiaries, affiliates, successors, and 

assigns, individually, collectively, or in any combination. 

D. “Credit Repair Service” means any service, in return for payment of 

money or other valuable consideration, for the express or implied purpose of: 1) 

improving any consumer’s credit report, credit record, credit history, credit profile, 

credit score, or credit rating; or 2) providing any advice or assistance to any 

consumer with regard to any activity or service the purpose of which is to improve a 

consumer’s credit report, credit record, credit history, credit profile, credit score, or 

credit rating. 

E. “Defendants” means Individual Defendant and Corporate Defendant, 

individually, collectively, or in any combination. 

F. “Designated Person” means any Person, other than the Seller, whose 

goods or services the Seller suggests, recommends, or requires that the Purchaser use 

in establishing or operating a new business. 

G. “Document” is synonymous in meaning and equal in scope to the 

usage of “document” and “electronically stored information” in Federal Rule of 

Civil Procedure 34(a), Fed. R. Civ. P. 34(a), and includes writings, drawings, graphs, 

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charts, photographs, sound and video recordings, images, Internet sites, web pages, 

websites, electronic correspondence, including e-mail and instant messages, 

contracts, accounting data, advertisements, FTP Logs, Server Access Logs, books, 

written or printed records, handwritten notes, telephone logs, telephone scripts, 

receipt books, ledgers, personal and business canceled checks and check registers, 

bank statements, appointment books, computer records, customer or sales databases, 

and any other electronically stored information, including Documents located on 

remote servers or cloud computing systems, and other data or data compilations 

from which information can be obtained directly or, if necessary, after translation 

into a reasonably usable form. A draft or non-identical copy is a separate Document 

within the meaning of the term. 

H. “Individual Defendant” means Michael Rando (a/k/a Mike Singles) 

and Valerie Rando (a/k/a Valerie Payton, Val Rando, and Val Singles), individually 

or collectively. 

I. “Investment Opportunity” means anything, tangible or intangible, that 

is offered, offered for sale, sold, or traded based wholly or in part on representations, 

either express or implied, about past, present, or future income, profit, or 

appreciation. 

J. “Person” means a natural person, an organization or other legal entity, 

including a corporation, partnership, sole proprietorship, limited liability company, 

association, cooperative, or any other group or combination acting as an entity. 

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K. “Providing locations, outlets, accounts, or customers” means 

furnishing the prospective Purchaser with existing or potential locations, outlets, 

accounts, or customers; requiring, recommending, or suggesting one or more 

locators or lead generating companies; providing a list of locator or lead generating 

companies; collecting a fee on behalf of one or more locators or lead generating 

companies; offering to furnish a list of locations; or otherwise assisting the 

prospective Purchaser in obtaining his or her own locations, outlets, accounts, or 

customers. 

L. “Purchaser” means a Person who buys a Business Opportunity. 

M. “Receiver” means Maria M. Yip, the receiver appointed in Section XIII 

of the Temporary Restraining Order issued on May 3, 2022 (Doc. 12), and any 

deputy receivers named by the Receiver. 

N. “Receivership Estate” means the Assets identified in Section IV.B of 

this Order and all Assets of the Defendants, including: (a) any Assets of the 

Defendants currently in the possession of the Receiver; (b) all the funds, property, 

premises, accounts, documents, mail, and all other Assets of, or in the possession or 

under the control of, the Defendants, wherever situated, the income and profits 

therefrom, all sums of money now or hereafter due or owing to the Defendants, and 

any other Assets or property belonging or owed to the Defendants; (c) any Assets of 

the Defendants held in Asset protection trusts; (d) any reserve funds or other 

accounts associated with any payments processed on behalf of any Defendant, 

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including such reserve funds held by a payment processor, credit card processor, or 

bank; and (e) any proceeds from the sale of such Assets, except those Assets the sale 

of which the Receiver determines will not add appreciably to the value of the estate. 

O. “Seller” means a Person who offers for sale or sells a Business 

Opportunity. 

ORDER 

CONDUCT RELIEF 

I. 

IT IS ORDERED that Defendants are permanently restrained and enjoined 

from advertising, marketing, promoting, selling, providing, or offering for sale, or 

assisting others in advertising, marketing, promoting, selling, providing, or offering 

for sale, any Credit Repair Service. 

II. 

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, promoting, or offering for 

sale of any product or service (including any Business Opportunity or Investment 

Opportunity), are permanently restrained and enjoined from misrepresenting, 

expressly or by implication: 

A. The profitability, effectiveness, or income potential, including but not 

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limited to claims of lifestyle changes tied to the representation, of any Business 

Opportunity or Investment Opportunity; 

B. That a product or service is legal or otherwise protected by any statute 

or rule; 

C. The terms of any refund, money-back guarantee, cancellation, 

exchange, or repurchase policy, or the circumstances under which a full or 

partial refund will be granted or denied; 

D. That a product or service is associated with a government benefit 

related to COVID-19; 

E. That a product or service is associated with the treatment, cure, 

prevention, mitigation, or diagnosis of COVID-19; or 

F. Any other fact material to consumers concerning any good or service, 

such as: the total costs; any material restrictions, limitations, or conditions; or 

any material aspect of its performance, efficacy, nature, or central 

characteristics. 

III. 

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, promoting, or offering for 

sale of any product or service, are permanently restrained and enjoined from making 

any representation or assisting others in making any representation, expressly or by 

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implication, about the benefits, performance, or efficacy of any product or service, 

unless the representation is non-misleading, and, at the time such representation is 

made, Defendants possess and rely upon competent and reliable evidence that is 

sufficient in quality and quantity based on standards generally accepted in the 

relevant field, when considered in light of the entire body of relevant and reliable 

evidence, to substantiate that the representation is true. 

IV. MONETARY JUDGMENT AND PARTIAL SUSPENSION 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of $18,875,613.94 is entered in favor of the 

Commission against Defendants, jointly and severally, as monetary relief 

pursuant to Section 19 of the FTC Act. The liability of Defendants for the 

judgment shall also be joint and several with any other defendants in this 

litigation to the extent subsequently ordered. 

B. In partial satisfaction of the judgment entered against Defendants, and 

to the extent not already done so: 

1. Defendants, immediately upon entry of this Order, to the extent 

not already done so, shall take all steps necessary to surrender to the 

Receiver all control, title, dominion, and interest in the Assets listed 

below: 

i) The Kensington Lakes 202 Land Trust, including the real 

property located at 12311 Kensington Lakes Drive, Unit 202, 

Jacksonville, FL 32246; 

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ii) The Sondra Cove Land Trust, including the real property 

located at 285 Sondra Cove Trl E, Jacksonville, FL 32225; 

iii) The 2016 Lamborghini Aventador listed in Defendants’ 

Financial Disclosure signed by Individual Defendants on 

September 20, 2022; 

iv) The 2022 Golf Cart listed in Defendants’ Financial 

Disclosure signed by Individual Defendants on September 20, 

2022; 

v) The two Rolex Watches listed in Defendants’ Financial 

Disclosure signed by Individual Defendants on September 20, 

2022; 

vi) The Chanel Purse listed in Defendants’ Financial 

Disclosure signed by Individual Defendants on September 20, 

2022; and 

vii) The Louis Vuitton Purse listed in Defendants’ Financial 

Disclosure signed by Individual Defendants on September 20, 

2022. 

2. Defendants, immediately upon entry of this Order, to the extent 

not already done so, shall surrender to their respective dealerships all 

control, title, dominion, and interest in the 2017 Maserati GT and the 

2022 Range Rover Land Rover listed in Defendants’ Financial 

Disclosure signed by Individual Defendants on September 20, 2022. 

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3. Acorns Advisers, LLC and Acorns Securities, LLC shall, within 

ten (10) business days of receipt of a copy of this Order, transfer to the 

FTC, the Receiver, or the FTC’s designated agent all Assets, if any, 

held by Defendant Valerie Rando. 

4. Ameris Bancorp shall, within ten (10) business days of receipt of 

a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account ending in -6567 

in the name of First Coast Matchmakers Inc. 

5. Bank of America shall, within ten (10) business days of receipt of 

a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account: 

i) ending in -8779 in the name of Financial Consulting 

Management Group LLC; and 

ii) ending in -0465 in the name of Financial Consulting 

Management Group LLC. 

6. Cardone Capital shall, within ten (10) business days of receipt of 

a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets held by Michael S Rando | MR Protection 

Trust 03-19-2018. 

7. CB Card LLC (d/b/a Credit Card Builder) shall, within ten (10) 

business days of receipt of a copy of this Order, transfer to the FTC, the 

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Receiver, or the FTC’s designated agent all Assets, including but not 

limited to any affiliate fees, owed to Defendants. 

8. Charles Schwab Corp. shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held in the account: 

i) ending in -2960 in the name of Michael S Rando; and 

ii) ending in -4631 in the name of Michael S Rando. 

9. Chime Financial, Inc. shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held in the account: 

i) ending in -1279 in the name of Valerie Rando; and 

ii) ending in -9731 in the name of Valerie Rando. 

10. Community First Credit Union shall, within ten (10) business 

days of receipt of a copy of this Order, transfer to the FTC, the 

Receiver, or the FTC’s designated agent all Assets, if any, held in the 

name of Defendants, including but not limited to, Financial Consulting 

Management LLC, Michael Shawn Rando, and Valerie Payton. 

11. Denefits shall, within ten (10) business days of receipt of a copy 

of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, including but not limited to any referral 

fees, owed to Defendants. 

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12. Electronic Commerce shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held by Prosperity Training 

Technology LLC. 

13. Fifth Third Bancorp shall, within ten (10) business days of receipt 

of a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account: 

i) ending in -3195 in the name of Digital Business Scaling 

LLC; 

ii) ending in -7966 in the name of Digital Growth Enterprises 

LLC; 

iii) ending in -0895 in the name of Dr. Steve’s Caffeine Melts 

(Michael S. Rando); 

iv) ending in -4862 in the name of Dr. Steve’s Caffeine Melts, 

LLC; 

v) ending in -7024 in the name of Education Training and 

Consulting LLC; 

vi) ending in -0190 in the name of First Coast Matchmakers 

Inc.; 

vii) ending in -2049 in the name of Legacy Matchmaking 

LLC; 

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viii) ending in -7636 in the name of Legacy Matchmaking 

LLC; 

ix) ending in -8483 in the name of Michael S Rando; 

x) ending in -3947 in the name of Michael S Rando; 

xi) ending in -8674 in the name of Michael S Rando; 

xii) ending in -1169 in the name of Michael S Rando | MR 

Protection Trust 03-19-2018; 

xiii) ending in -9105 in the name of Moneygame LLC; 

xiv) ending in -0699 in the name of Prosperity Training 

Technology LLC; 

xv) ending in -0720 in the name of Prosperity Training 

Technologies LLC; 

xvi) ending in -0842 in the name of Prosperity Training 

Technology LLC; 

xvii) ending in -7842 in the name of Valerie R Rando | VR 

Protection Trust Dated March 19, 2018; and 

xviii) ending in -4547 in the name of Valerie R Rando | VR 

Protection Trust Dated March 19, 2018. 

14. Google Wallet shall, within ten (10) business days of receipt of a 

copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account ending in -4553 

in the name of Mike Rando. 

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15. Identity Intelligence Group LLC (d/b/a Identity IQ) shall, 

within ten (10) business days of receipt of a copy of this Order, transfer 

to the FTC, the Receiver, or the FTC’s designated agent all Assets, 

including but not limited to any affiliate fees, owed to Defendants. 

16. JPMorgan Chase & Co. shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held in the account: 

i) ending in -9119 in the name of Financial Consulting 

Management Group LLC; 

ii) ending in -9101 in the name of Financial Consulting 

Management Group LLC; and 

iii) ending in -2828 in the name of Michael Shawn Rando 

Financial Consulting MANA. 

17. Maverick BankCard, Inc. (d/b/a Maverick) shall, within ten (10) 

business days of receipt of a copy of this Order, transfer to the FTC, the 

Receiver, or the FTC’s designated agent all Assets, if any, held by 

Prosperity Training Technology LLC. 

18. Merchant Services shall, within ten (10) business days of receipt 

of a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account ending in -1323 

in the name of Prosperity Training Technology LLC. 

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19. Navy Federal Credit Union shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held in the account: 

i) ending in -2312 in the name of First Coast Matchmakers 

LLC; 

ii) ending in -8277 in the name of First Coast Matchmakers 

LLC; 

iii) ending in -0423 in the name of First Coast Matchmakers 

LLC; 

iv) ending in -9374 in the name of Green Parrot 104 LLC; 

v) ending in -1794 in the name of Green Parrot 104 LLC; 

vi) ending in -3022 in the name of HITIDEFLORIDA LLC; 

vii) ending in -7210 in the name of HITIDEFLORIDA LLC; 

viii) ending in -4587 in the name of Hitideflorida LLC 

(Michael S. Rando); 

ix) ending in -5351 in the name of Key Lime 107 LLC; 

x) ending in -3134 in the name of Key Lime 107 LLC; 

xi) ending in -6318 in the name of Key Lime 204 LLC; 

xii) ending in -3951 in the name of Key Lime 204 LLC; 

xiii) ending in -4470 in the name of Key Lime 302 LLC; 

xiv) ending in -6698 in the name of Key Lime 302 LLC; 

xv) ending in -4884 in the name of Key Lime 305 LLC; 

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xvi) ending in -7019 in the name of Key Lime 305 LLC; 

xvii) ending in -1362 in the name of MJP Investors LLC; 

xviii) ending in -7789 in the name of MJP Investors LLC; 

xix) ending in -6793 in the name of MJP Investors LLC; 

xx) ending in -5785 in the name of Michael S. Rando; 

xxi) ending in -1388 in the name of Michael S. Rando; 

xxii) ending in -8483 in the name of Michael S Rando; 

xxiii) ending in -9042 in the name of Valerie Rando over the 

amount of $10,000; 

xxiv) ending in -3607 in the name of Valerie Rando; and 

xxv) ending in -7210 in the name of Valerie Rando. 

20. Northwestern Mutual Life Insurance Company shall, within ten 

(10) business days of receipt of a copy of this Order, transfer to the 

FTC, the Receiver, or the FTC’s designated agent all Assets, if any, 

held in the account ending in -7921 in the name of Valerie Rando. 

21. NovaTech, LTD shall, within ten (10) business days of receipt of 

a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held by Michael S. Rando. 

22. Paypal shall, within ten (10) business days of receipt of a copy of 

this Order, transfer to the FTC, the Receiver, or the FTC’s designated 

agent all Assets, if any, held by Valerie Rando. 

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23. Penn Mutual Life Insurance Company shall, within ten (10) 

business days of receipt of a copy of this Order, transfer to the FTC, the 

Receiver, or the FTC’s designated agent all Assets, if any, held in the 

account ending in -2130 in the name of Valerie Rando. 

24. Prime Corporate Service shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, including but not limited to any 

referral fees, owed to Defendants. 

25. Regions Bank shall, within ten (10) business days of receipt of a 

copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account ending in -6850 

in the name of Michael Rando. 

26. RentReporters, LLC shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, including but not limited to any 

affiliate fees, owed to Defendants. 

27. Self Financial, Inc. (d/b/a Self Lender) shall, within ten (10) 

business days of receipt of a copy of this Order, transfer to the FTC, the 

Receiver, or the FTC’s designated agent all Assets, including but not 

limited to any affiliate fees, owed to Defendants. 

28. Truist Financial Corporation shall, within ten (10) business days 

of receipt of a copy of this Order, transfer to the FTC, the Receiver, or 

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the FTC’s designated agent all Assets, if any, held in the account ending 

in -5489 in the name of Prosperity Training Technology LLC. 

29. Vystar Credit Union shall, within ten (10) business days of 

receipt of a copy of this Order, transfer to the FTC, the Receiver, or the 

FTC’s designated agent all Assets, if any, held in the account: 

i) ending in -4040 in the name of Michael Shawn Rando; 

ii) ending in -6553 in the name of Michael Shawn Rando; 

iii) ending in -1273 in the name of Michael Shawn Rando; 

iv) ending in -0516 in the name of Valerie Rando; 

v) ending in -4239 in the name of Valerie Rando; and 

vi) ending in -2389 in the name of Valerie Rando. 

30. Webull Corp. shall, within ten (10) business days of receipt of a 

copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account ending in -2278 

in the name of Michael S. Rando. 

31. Wells Fargo & Co. shall, within ten (10) business days of receipt 

of a copy of this Order, transfer to the FTC, the Receiver, or the FTC’s 

designated agent all Assets, if any, held in the account: 

i) ending in -9312 in the name of First Coast Matchmakers 

LLC; and 

ii) ending in -9338 in the name of First Coast Matchmakers 

LLC. 

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C. Upon completion of all transfers set forth in Subsection B above, the 

remainder of the judgment is suspended, subject to the Subsections below. 

D. The Commission’s agreement to the suspension of part of the judgment 

is expressly premised upon the truthfulness, accuracy, and completeness of 

Defendants’ sworn financial statements and related documents (collectively, 

“financial representations”) submitted to the Commission: 

1. The spreadsheet titled “Credit Game Academy Orders” 

submitted by Defendants’ counsel to the FTC on May 16, 2022; 

2. The Financial Statements of Corporate Defendants and other 

Documents submitted by Defendants’ counsel to the FTC on May 17, 

2022; 

3. The Financial Statements of Individual Defendants and other 

Documents submitted by Defendants’ counsel to the FTC on May 18, 

2022; 

4. The supplemental financial disclosures submitted by Defendants’ 

counsel to the FTC on May 19, 2022; 

5. The supplemental banking information and financial disclosure 

forms submitted by Defendants’ counsel to the FTC on May 23, 2022; 

6. The supplemental asset and trust information submitted by 

Defendants’ counsel to the FTC on August 4, 2022; 

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7. The supplemental asset information submitted by email from 

Defendants’ counsel Michael Freed to FTC counsel Brian Welke on 

August 17, 2022; 

8. The supplemental asset information submitted by email from 

Defendants’ counsel Michael Freed to FTC counsel Brian Welke on 

August 18, 2022; 

9. The supplemental tax information submitted by email from 

Defendants’ counsel Michael Freed to FTC counsel Brian Welke on 

September 7, 2022; 

10. The Financial Disclosures of Defendants signed by Individual 

Defendants on September 20, 2022 and submitted by email from 

Defendants’ counsel Michael Freed to FTC counsel Brian Welke on 

September 20, 2022; and 

11. The Individual Defendants’ car leasing and banking information 

submitted by email from Defendant’s counsel Michael Freed to FTC 

counsel Brian Welke on October 3, 2022. 

E. The suspension of the judgment will be lifted as to any Defendant if, 

upon motion by the Commission, the Court finds that any Defendant failed to 

disclose any material Asset, materially misstated the value of any Asset, or 

made any other material misstatement or omission in Defendants’ financial 

representations identified above. 

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F. If the suspension of the judgment is lifted, the judgment becomes 

immediately due as to that Defendant in the amount specified in Subsection A 

above (which the parties stipulate only for purposes of this Section represents 

the consumer injury alleged in the Complaint), less any payment previously 

made pursuant to this Section, plus interest computed from the date of entry of 

this Order. 

V. ADDITIONAL MONETARY PROVISONS 

IT IS FURTHER ORDERED that: 

A. Defendants relinquish dominion and all legal and equitable right, title, 

and interest in all Assets transferred pursuant to this Order identified in 

Section IV.B of this Order and may not seek the return of any of those Assets. 

B. The Receiver shall liquidate all Assets transferred to the Receiver 

pursuant to this Order. After payment to the Receiver of any expenses 

approved by the Court, all proceeds from the liquidation of those Assets shall 

be paid to the Commission. The Receiver is excused from the requirements of 

28 U.S.C. sections 2001 and 2004 in connection with any pending or 

contemplated sale by the Receiver. 

C. Any entity or person, including Defendants or any financial institution 

holding Defendants’ Assets, must transfer those Assets to the Commission or 

Receiver, in accordance with instructions provided by a representative of the 

Commission or Receiver, within seven days of receiving notice of this Order. 

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D. Once all of Defendants’ Assets are transferred in accordance with 

Subsection IV.B, the Asset freeze instituted by the Temporary Restraining 

Order (Doc. 12) and the Stipulated Preliminary Injunction (Doc. 101) shall 

dissolve with respect to Defendants. 

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. 

G. Defendants acknowledge that their Taxpayer Identification 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. 

H. 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 

23 
 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 24 of 36 PageID 1783 

money remains after such redress is completed, the Commission 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 as disgorgement. 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 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 directly or indirectly: 

A. 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. 

B. Disclosing, using, or benefitting from customer information, including 

the name, address, telephone number, email address, social security number, 

other identifying information, or any data that enables access to a customer’s 

account (including a credit card, bank account, or other financial account), 

24 
 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 25 of 36 PageID 1784 

that any Defendant obtained prior to entry of this Order in connection with 

the sale of Credit Repair Services, Business Opportunities, or Investment 

Opportunities; and 

C. Failing to destroy such customer information in all forms in their 

possession, custody, or control within 30 days after receipt of written direction 

to do so from a representative of the Commission. 

Provided, however, that customer information need not be disposed of, and 

may be disclosed, to the extent requested by a government agency or required by 

law, regulation, or court order. 

VII. RECEIVERSHIP 

IT IS FURTHER ORDERED that Maria M. Yip is hereby appointed 

equity Receiver for the Corporate Defendants for the purpose of taking the necessary 

steps to wind up the businesses of the Corporate Defendants, liquidate Assets, and 

pay any net proceeds to the Commission to satisfy the monetary judgment in this 

Order. In carrying out these duties, the Receiver shall be the agent of this Court, 

shall be accountable directly to this Court, and is authorized and directed to: 

A. Take any and all steps that the Receiver concludes are appropriate to 

wind down the affairs of the Corporate Defendants. 

B. Continue to exercise full control over the Corporate Defendants and 

continue to collect, marshal, and take custody, control, and possession of all 

the funds, property, premises, accounts, documents, mail, and other Assets of, 

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Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 26 of 36 PageID 1785 

or in the possession or under the control of the Corporate Defendants, 

wherever situated, the income and profits therefrom, and all sums of money 

now or hereafter due or owing to the Corporate Defendants. 

C. Continue to have full control over the management and personnel of 

the Corporate Defendants. 

D. Take all steps necessary or advisable, including issuing subpoenas, to 

locate and liquidate all other Assets of the Corporate Defendants, cancel the 

Corporate Defendants’ contracts, collect on amounts owed to the Corporate 

Defendants, and take such other steps as may be necessary to wind-up the 

Corporate Defendants efficiently. 

E. As soon as practicable after the entry of this Order, take exclusive 

custody, control, and possession of all Assets identified in Section IV.B of this 

Order, to the extent not already completed. 

F. Give reasonable notice to the Commission of any settlements or 

compromises by the Receiver concerning the Receivership Estate, before the 

settlement or compromise is consummated. Within 20 days of this notice, the 

Commission shall have the opportunity to object to any such settlement, by 

filing a motion with the Court. 

G. Make payments and disbursements from the Receivership Estate that 

are necessary or advisable for carrying out the directions of, or exercising the 

authority granted by, this Order. The Receiver shall apply to the Court for 

prior approval of any payment of any debt or obligation incurred by the 

26 
Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 27 of 36 PageID 1786 

Corporate Defendants prior to the date of entry of the Temporary Restraining 

Order in this action, except payments that the Receiver deems necessary or 

advisable to ensure Assets of the Corporate Defendants are not lost, stolen, or 

dissipated. 

H. Institute actions or proceedings in state, federal, or foreign courts as the 

Receiver deems necessary and advisable to preserve or recover the Assets of 

the Corporate Defendants, or that the Receiver deems necessary and advisable 

to carry out the Receiver’s mandate under this Order, including actions 

challenging fraudulent or voidable transfers. 

I. Defend any or all actions or proceedings instituted against the 

Corporate Defendants, as the Receiver deems necessary and advisable to 

preserve the Assets of the Corporate Defendants. 

J. Continue to maintain accurate records of all receipts and expenditures 

incurred as the Receiver. 

K. Perform all acts necessary or advisable to complete an accurate 

accounting of the Assets of the Receivership Estate, and prevent unauthorized 

transfer, withdrawal, or misapplication of said Assets. 

L. Continue to be entitled to reasonable compensation for the performance 

of the Receiver’s duties pursuant to this Order, including duties performed by 

the Receiver’s agents, including accountants and lawyers, and for the cost of 

actual out-of-pocket expenses incurred by them, from the Assets of the 

27 
 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 28 of 36 PageID 1787 

Receivership Estate, at the hourly rate previously agreed to by the Receiver 

and used as the bases for prior fee applications approved by the Court. 

M. Prepare and file, within 120 days of entry of this Order, a written report 

describing (1) the steps taken to implement the terms of this Order; (2) the 

value of all Assets and liabilities of the Receivership Estate; (3) whether there 

exists a need for the Receivership to continue; and (4) any other matters which 

the Receiver believes should be brought to the Court’s attention. 

VIII. 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 20 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 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 this 

Order, and all agents and representatives who participate in conduct related to 

the subject matter of this Order; and (3) any business entity resulting from any 

change in structure as set forth in the Section titled Compliance Reporting. 

28 
 

 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 29 of 36 PageID 1788 

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 Defendants deliver a copy of 

this Order, Defendants must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order. 

IX. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to 

the Commission: 

A. One year after entry of this Order, Defendants 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 activities of each 

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

advertising, marketing, and sales; (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. 

29 
Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 30 of 36 PageID 1789 

2. Additionally, Individual Defendants 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 they perform services whether as an 

employee or otherwise and any entity in which they have any 

ownership interest; and (c) describe in detail their 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 engages in any acts or practices 

subject to this Order. 

2. Additionally, Individual Defendants 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 

they perform services whether as an employee or otherwise and any 

30 
 

 

 

 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 31 of 36 PageID 1790 

entity in which they have 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. Michael Rando, et al., Matter No. X200021. 

X. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 

20 years after entry of this Order, and retain each such record for 5 years. 

Specifically, Corporate Defendants and each Individual Defendant for any business 

31 
 

 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 32 of 36 PageID 1791 

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 requests for Refunds or 

reimbursement, whether received directly or indirectly, such as through a third 

party, and any response; and 

D. All records necessary to demonstrate full compliance with each 

provision of this Order, including all submissions to the Commission. 

XI. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring 

Defendants’ compliance with this Order, including the financial representations 

upon which part of the judgment was suspended, and any failure to transfer any 

Assets as required by this Order: 

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; 

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Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 33 of 36 PageID 1792 

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 Defendants. Defendants must permit 

representatives of the Commission to interview any employee or other Person 

affiliated with Defendants 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). 

XII. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this 

matter for purposes of construction, modification, and enforcement of this Order. 

33 
TW\,0-:f1⁄4, 9:. Oc:M1(Jlfl, 

TIMOTHY J. CORRIGAN 

United States District Judge 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 34 of 36 PageID 1793 

SO ORDERED, this 10th day of January, 2023. 

34 
Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 35 of 36 PageID 1794 

FOR DEFENDANTS: 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF, FEDERAL TRADE COMMISSION: 

_____________________________________ Date: __________ 

Brian M. Welke 

Hong Park 

12/15/2022

Sana Chaudhry 

Federal Trade Commission 

600 Pennsylvania Avenue NW 

CC- 9528 

Washington, DC 20580 

Tel: 202-326-2897 (Welke), -2158 (Park), -2679 (Chaudhry) 

Fax: 202-326-3768 

Email: bwelke@ftc.gov, hpark@ftc.gov, schaudhry@ftc.gov 

10/12/22 _____________________________________ Date: __________ 

Michael R. Freed 

Florida Bar No. 69205 

mfreed@gunster.com 

Latour “LT” Lafferty 

Florida Bar No. 975575 

llafferty@gunster.com 

Nathan W. Hill 

Florida Bar No. 91473 

nhill@gunster.com 

Gunster, Yoakley & Stewart, P.A. 

1 Independent Drive, Suite 2300 

Jacksonville, FL 32202 

(904) 354-1980 

Counsel for Defendants Michael Rando, Valerie Rando, Prosperity Training 

Technology, LLC, Digital Business Scaling, LLC, First Coast Matchmakers, Inc., 

First Coast Matchmakers, LLC, and Financial Consulting Management Group, 

LLC 

// 

// 

// 

// 

// 

35 
Defendants Michael Rando, Prosperity Training Tech., LLC, Digital 

Business Scaling, LLC, First Coast Matchmakers, Inc., First Coast 

Matchmakers, LLC, and Financial Consulting Management Group, LLC 

~ Date: //J///J/;::iz__ 

MICHAi=~ ·~and as an officer of Pros~g Tech., 

LLC, Digital Business Scaling, LLC, First Coast Matchmakers, Inc., First Coast 

Matchmakers, LLC, and Financial Consulting Management Group, LLC 

Defendants Valerie Rando, Prosperity Training Tech., LLC, First Coast 

Matchmakers, Inc., and First Coast Matchmakers, LLC 

VJ--·- -~J- Date: /o/10/;t2- VALERIE RANDO, \,aividually, and as an officer of First Coast Matchmakers, 

Inc., and First Coast Matchmakers, LLC and as Marketing Director of Prosperity 

Training Tech., LLC, 

36 

Case 3:22-cv-00487-TJC-MCR Document 116 Filed 01/10/23 Page 36 of 36 PageID 1795