UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

__________________________________________ 

 ) 

In the Matter of ) 

 ) 

Prudential Security, Inc., ) 

a corporation, ) 

 ) 

Prudential Command Inc., )

a corporation, ) File No. 221-0026 

 ) 

Greg Wier, ) 

a natural person, ) 

) 

and )

 ) 

Matthew Keywell, )

a natural person. )

__________________________________________) 

AGREEMENT CONTAINING CONSENT ORDER

 The Federal Trade Commission initiated an investigation of certain acts and 

practices of Prudential Security, Inc. (“Prudential Security”); Prudential Command Inc. 

(“Prudential Command”); Greg Wier, individually and as an officer and owner of 

Prudential Security, Inc. and Prudential Command Inc.; and Matthew Keywell, 

individually and as an officer and owner of Prudential Security, Inc. and Prudential 

Command Inc. (collectively “Proposed Respondents”). The Bureau of Competition and 

Proposed Respondents enter into this Agreement Containing Consent Order (“Consent 

Agreement”) to cease and desist from engaging in certain acts and practices and to 

provide for other relief to resolve the allegations in the Draft Complaint through a 

proposed Decision and Order, which is attached, to present to the Commission. 

 IT IS HEREBY AGREED by and between Proposed Respondents, by their duly 

authorized officer and attorneys, and counsel for the Commission that: 

1. Proposed Respondent Prudential Security, Inc. (a.k.a. Trollpru, Inc.) is a 

corporation organized and existing under, and by virtue of, the laws of the State of 

Michigan that, prior to August 26, 2022, maintained its executive offices and 

principal place of business at 20600 Eureka Road, Suite 900 Taylor, MI 48180. 

2. Proposed Respondent Prudential Command Inc. (a.k.a. Commandbabyyoda, Inc.) 

is a corporation organized and existing under, and by virtue of, the laws of the 

State of Michigan that, prior to August 26, 2022, maintained its executive offices 

and principal place of business at 20600 Eureka Road, Suite 900 Taylor, MI 

48180. Prudential Command Inc. is an affiliate of Respondent Prudential 

Security, Inc. 
In re Prudential Security, Inc., File No. 211-0026 

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3. Proposed Respondent Greg Wier is a natural person with his principal office or 

place of business located at . 

4. Proposed Respondent Matthew Keywell a natural person with his principal office 

or place of business located at . 

5. Proposed Respondents admit all the jurisdictional facts set forth in the Draft 

Complaint. 

6. Proposed Respondents waive: 

a. any further procedural steps; 

b. the requirement that the Decision and Order contain a statement of findings of 

fact and conclusions of law; 

c. all rights to seek judicial review or otherwise to challenge or contest the 

validity of the Decision and Order entered pursuant to this Consent 

Agreement; and 

d. any claim under the Equal Access to Justice Act. 

7. This Consent Agreement is for settlement purposes only and does not constitute 

an admission by Proposed Respondents that the law has been violated as alleged 

in the Draft Complaint, or that the facts as alleged in the Draft Complaint, other 

than jurisdictional facts, are true. 

8. Proposed Respondents shall submit an initial compliance report, pursuant to 

Commission Rule 2.33, 16 C.F.R. § 2.33, no later than 30 days after the date on 

which Proposed Respondent execute this Consent Agreement, and subsequent 

compliance reports every 30 days thereafter until the Decision and Order becomes 

final. After the Decision and Order become final, the reporting obligations 

contained in the Decision and Order shall control and the reporting obligations 

under this Consent Agreement shall cease. Each compliance report shall set forth 

in detail the manner in which Proposed Respondents have complied, have 

prepared to comply, are complying, and will comply with the Consent Agreement 

and the Decision and Order. Proposed Respondents shall provide sufficient 

information and documentation to enable the Commission to determine 

independently whether Proposed Respondents are in compliance with the Consent 

Agreement and the Decision and Order. 

9. Each compliance report submitted pursuant to Paragraph 8 above shall be verified 

in the manner set forth in 28 U.S.C. § 1746 by the Chief Executive Officer or 

another officer or employee specifically authorized to perform this function. 

Commission Rule 2.41(a), 16 C.F.R. § 2.41(a), requires that the Commission 

receive an original and one copy of each compliance report. Proposed 

Respondents shall electronically file an original of each compliance report with 
In re Prudential Security, Inc., File No. 211-0026 

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the Secretary of the Commission at ElectronicFilings@ftc.gov, and with the 

Compliance Division at bccompliance@ftc.gov. 

10. This Consent Agreement, and any compliance report filed pursuant to this 

Consent Agreement, shall not become part of the public record of the proceeding 

unless and until the Commission accepts the Consent Agreement. If the 

Commission accepts this Consent Agreement, the Commission will place it, 

together with the Complaint, the proposed Decision and Order, an explanation of 

the provisions of the proposed Decision and Order, and any other information that 

may help interested persons understand the order on the public record for the 

receipt of comments for 30 days. 

11. This Consent Agreement contemplates that, if the Commission accepts the 

Consent Agreement, the Commission thereafter may withdraw its acceptance of 

this Consent Agreement and notify Proposed Respondents, in which event the 

Commission will take such action as it may consider appropriate. If the 

Commission does not subsequently withdraw such acceptance pursuant to the 

provisions of Commission Rule 2.34, 16 C.F.R. § 2.34, the Commission may, 

without further notice to Proposed Respondents, issue its Complaint and the 

attached Decision and Order containing an order to cease and desist and to 

provide for other relief in disposition of the proceeding. 

12. The Decision and Order shall become final upon service. Delivery of the 

Complaint and the Decision and Order to Proposed Respondents by any means 

provided in Commission Rule 4.4(a), 16 C.F.R. § 4.4(a), or by delivery to United 

States counsel for Proposed Respondents identified in this Consent Agreement, 

shall constitute service to Proposed Respondents. Proposed Respondents waive 

any rights they may have to any other manner of service. Proposed Respondents 

also waive any rights they may otherwise have to service of any appendices 

attached to or incorporated by reference into the Decision and Order, if Proposed 

Respondents are already in possession of such Appendices, and agree that they 

are bound to comply with and will comply with the Decision and Order to the 

same extent as if it had been served with copies of the Appendices. 

13. The Complaint may be used in construing the terms of the Decision and Order, 

and no agreement, understanding, representation, or interpretation not contained 

in the Decision and Order or the Consent Agreement may be used to vary or 

contradict the terms of the Decision and Order. 

14. By signing this Consent Agreement, Proposed Respondents represent and warrant 

that: 

a. they can fulfill all the terms of and accomplish the full relief contemplated by 

the Decision and Order; and 

b. all parents, subsidiaries, affiliates, and successors necessary to effectuate the 

full relief contemplated by this Consent Agreement and the Decision and 

Order are parties to this Consent Agreement and are bound as if they had 
In re Prudential Security, Inc., File No. 211-0026 

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signed this Consent Agreement and were made parties to this proceeding, or 

are within the control of parties to this Consent Agreement and the Decision 

and Order. 

15. Proposed Respondents have read the Draft Complaint and the proposed Decision 

and Order. Proposed Respondents agree to comply with the terms of the proposed 

Decision and Order from the date it signs this Consent Agreement. Proposed 

Respondents understand that once the Commission has issued the Decision and 

Order, it will be required to file one or more compliance reports setting forth in 

detail the manner in which it has complied, has prepared to comply, is complying, 

and will comply with the Decision and Order. When final, the Decision and 

Order shall have the same force and effect and may be altered, modified, or set 

aside in the same manner and within the same time as provided by statute for 

other orders. Proposed Respondents further understand that they may be liable 

for civil penalties in the amount provided by law for each violation of the 

Decision and Order.