Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 1 of 36 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

FEDERAL TRADE COMMISSION, Case No. ____________ 1:22-cv-7389

PEOPLE OF THE STATE OF CALIFORNIA, COMPLAINT FOR PERMANENT 

INJUNCTION, MONETARY 

STATE OF COLORADO, RELIEF, AND OTHER RELIEF 

STATE OF FLORIDA, 

PEOPLE OF THE STATE OF ILLINOIS, 

COMMONWEALTH OF MASSACHUSETTS, 

and 

PEOPLE OF THE STATE OF STATE OF NEW 

YORK, 

Plaintiffs, 

v. 

ROOMSTER CORP., a corporation, 

JOHN SHRIBER, individually and as an officer of 

Roomster Corp., 

ROMAN ZAKS, individually and as an officer of 

Roomster Corp., and 

JONATHAN MARTINEZ, individually and doing 

business as AppWinn, 

Defendants. 

Plaintiffs, the Federal Trade Commission (“FTC”), and the People of the State of 

California, Attorneys General of the States of Colorado, Florida, Illinois, and the Commonwealth 

of Massachusetts, and the People of the State of New York (“Plaintiff States,” and together with 

the FTC, “Plaintiffs”), for their Complaint allege: 
 

 

 

 

 

 

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1. The FTC brings this action under Section 13(b) of the Federal Trade Commission 

Act (“FTC Act”), 15 U.S.C. § 53(b), which authorizes the FTC to seek, and the Court to order, 

permanent injunctive 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). 

2. The Plaintiff States bring this action by and through their attorneys general, who 

are the chief legal officers for their respective states and commonwealth. The Plaintiff States 

bring this action pursuant to consumer protection and business regulation enforcement authority 

conferred on their attorneys general by state and common law authority. These state laws 

authorize the Plaintiff States to seek, and the Court to order, temporary, preliminary, and 

permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of 

monies paid, disgorgement of ill-gotten monies, and other equitable relief for Defendants’ state 

law violations. These laws also authorize the Plaintiff States to obtain civil penalties, attorneys’ 

fees, expenses, and costs. 

SUMMARY OF CASE 

3. Roomster Corp., John Shriber, and Roman Zaks (the “Roomster Defendants”) 

operate an internet-based room and roommate finder platform called “Roomster.” Since at least 

2016, the Roomster Defendants, with the help of Defendant Jonathan Martinez also doing 

business as AppWinn (“Martinez”), have inundated the internet with tens of thousands of fake 

positive reviews to bolster their false claims that properties listed on their Roomster platform are 

real, available, and verified. In addition, the Roomster Defendants, either directly or through 

their affiliates, have peppered the internet with fake listings to drive traffic to their platform. 

4. Although the Roomster Defendants claim that their Roomster platform provides 

“verified” and “authentic” living arrangement listings, in many instances it does not. Instead, the 

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Roomster Defendants rely on fake reviews (thousands of which were purchased from Defendant 

Martinez alone) and fake listings to get consumers to pay for access to rental information that is 

unverified and, in many instances, does not exist. 

5. In this manner, the Roomster Defendants have taken tens of millions of dollars 

from consumers who can least afford to lose their money and who need reliable housing the 

most. Consumers injured by Defendants’ conduct are typically students, lower-income 

individuals, and those desperate for safe, low-cost housing in markets where such housing is 

extremely hard to find. According to the Roomster Defendants, Roomster customers are in the 

lowest end of the rental market, they generally have limited funds, and every dollar counts. 

6. In addition, the Roomster Defendants’ misrepresentations about the authenticity 

of their Roomster listings have lured these same consumers into paying substantially more 

money to fraudsters who have flooded the Roomster platform with their own fake and unverified 

listings. During the pandemic, these rental listing scammers have had free rein to exploit the 

platform, with many fraudsters attempting to collect deposits or rental payments upfront under 

the guise that COVID-19 prevents them from showing the properties. 

JURISDICTION AND VENUE 

7. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345 and supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367. 

8. Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2), (b)(3), 

(c)(1), (c)(2), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFFS 

9. The FTC is an independent agency of the United States Government created by 

the FTC Act, which authorizes the FTC to commence this district court civil action by its own 

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attorneys. 15 U.S.C. §§ 41–58. The FTC enforces Section 5(a) of the FTC Act, 

15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. 

10. The People of the State of California (“California”) bring this action by and 

through Attorney General Rob Bonta, who is authorized by California Business and Professions 

Code §§ 17535 and 17536 to enforce the California False Advertising Law, California Business 

and Professions Code § 17500 et seq., and authorized by California Business and Professions 

Code §§ 17203, 17204, and 17206 to enforce the California Unfair Competition Law, California 

Business and Professions Code § 17200 et seq. Among other relief, California Business and 

Professions Code §§ 17203 and 17535 authorize the Attorney General to obtain injunctive relief 

to halt violations of, and enforce compliance with the Unfair Competition Law and False 

Advertising Law, respectively, and also authorize the Attorney General to seek all orders or 

judgments as may be necessary to restore to any person in interest any money or other property 

acquired through violations of the Unfair Competition Law and False Advertising Law. The 

Attorney General is also authorized by California Business and Professions Code §§ 17206 and 

17536 to obtain civil penalties. 

11. The State of Colorado brings this action by and through Attorney General Philip 

J. Weiser pursuant to the Colorado Consumer Protection Act, Colo. Rev. Stats. §§ 6-1-101, et 

seq., (“CCPA”), which prohibits unfair and deceptive trade practices in the course of a 

defendant’s business or occupation. The CCPA authorizes the Colorado Attorney General to 

seek, and the Court to grant, civil penalties, injunctive relief, and such orders as may be 

necessary to prevent the use or employment of deceptive trade practices, to completely 

compensate or restore to the original position of any person injured, or to prevent any unjust 

enrichment. Colo. Rev. Stats. §§ 6-1-110 and 112. 

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12. The Office of the Attorney General, State of Florida, Department of Legal Affairs 

(“State of Florida”) brings this action by and through Attorney General, Ashley Moody, under 

the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes 

(“FDUTPA”), which authorizes the State of Florida to seek, and the Court to order, permanent 

injunctive relief, recission or reformation of contracts, consumer restitution, the refund of monies 

paid, disgorgement of ill-gotten monies, attorney’s fees, civil penalties, and other equitable relief 

for Defendants’ acts or practices in violation of FDUTPA. Fla. Stat. §§ 501.207(1)(b), 

501.207(3), 501.2075, and 501.2077. The State of Florida is the enforcing authority under 

FDUTPA pursuant to Section 501.203(2), Florida Statutes. Conduct that violates Section 5(a) of 

the FTC Act also violates Section 501.204 of the FDUTPA. Fla. Stat. §§501.203(3), 501.204(2). 

The provisions of FDUTPA shall be “construed liberally” to promote and “protect the 

consuming public and legitimate business enterprises from those who engage in unfair methods 

of competition, or unconscionable, deceptive or unfair acts or practices in the conduct of any 

trade or commerce.” Fla. Stat. § 501.202. The State of Florida has conducted an investigation 

and determined that an enforcement action serves the public interest as required by FDUTPA 

Section 501.207(2). 

13. The People of the State of Illinois (“State of Illinois”) bring this action by and 

through Attorney General Kwame Raoul pursuant to the provisions of the Consumer Fraud and 

Deceptive Business Practices Act (“Illinois Consumer Fraud Act”), 815 ILCS 505/1 et seq., 

which prohibits unfair or deceptive acts or practices in or affecting commerce and authorizes the 

Illinois Attorney General to obtain injunctive and other relief to halt violations of, and enforce 

compliance with, the Illinois Consumer Fraud Act. 

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14. The Commonwealth of Massachusetts brings this action by and through Attorney 

General Maura Healey, who is authorized by Mass. Gen. Laws ch. 12, § 10 and Mass. Gen. Laws 

ch. 93A, § 4 to commence this legal action in the public interest. The Massachusetts Attorney 

General enforces the Massachusetts Consumer Protection Act, Mass. Gen. Laws ch. 93A, §§ 2 

and 4, and the regulations promulgated thereunder, which prohibit unfair or deceptive acts or 

practices in trade or business, and which authorize the Massachusetts Attorney General to seek 

civil penalties, injunctive relief, restitution, attorneys’ fees, costs, and any other equitable relief 

deemed appropriate. In accordance with Mass. Gen. Laws ch. 93A, § 4, the Commonwealth of 

Massachusetts provided the statutorily required notice to Defendants more than five days prior to 

commencing this action. 

15. The People of the State of New York (“State of New York”) bring this action by 

and through Attorney General Leticia James under N.Y. Executive Law § 63(12), which 

authorizes the New York Attorney General (“NYAG”) to seek, and the Court to order, 

permanent injunctive relief, restitution, damages, and disgorgement against any person or 

business which has engaged in any repeated or persistent fraud or illegality in the conduct of its 

business, and N.Y. General Business Law (“GBL”) Article 22-A, which authorizes the NYAG to 

seek, and the Court to order, permanent injunctive relief, restitution, and civil penalties for 

deceptive acts or practices and false advertising under N.Y. GBL § 350, and for such order to 

provide for nationwide restitution where the business is located in the State of New York as is 

the case in this action. In accordance with GBL §§ 349(c) and 350-c, the State of New York 

provided the statutorily required notice to Defendants. 

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DEFENDANTS 

16. Defendant Roomster Corp. (“Roomster”) is a New York corporation with its 

principal place of business at 285 W Broadway, Suite 410, New York, New York 10013. 

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

Roomster is a small company that is co-owned by Defendants John Shriber and Roman Zaks. 

17. Defendant John Shriber (“Shriber”) is the co-founder, co-owner, and Chief 

Executive Officer of Roomster. 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. Shriber exercises control over all aspects of 

Roomster’s business operations, including the creation of Roomster’s policies, procedures, and 

business practices, including its advertising practices, marketing practices, billing practices, 

charge disputes, affiliate program, handling of consumer complaints, consumer review practices, 

and responses to allegations of fraud, scams, or abuse. Shriber is also responsible for approving 

Roomster-supplied platform content. Defendant Shriber 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. 

18. Defendant Roman Zaks (“Zaks”) is the Chief Technology Officer, and along with 

Defendant Shriber, the co-founder and co-owner of Roomster. 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. Zaks also 

exercises control over all aspects of Roomster’s business operations, including the creation of 

Roomster policies, procedures, and business practices. Along with Shriber, Zaks also manages 

Roomster’s advertising and marketing practices, billing practices, charge disputes, affiliate 

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program, handling of consumer complaints, and responses to allegations of fraud, scams, or 

abuse, and he is likewise responsible for approving Roomster-supplied platform content. 

Defendant Zaks 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. 

19. Defendant Jonathan Martinez (“Martinez”) is an individual also doing business as 

AppWinn. At all times relevant to this Complaint, acting alone or in concert with others, he has 

provided fake reviews for the Roomster Defendants’ platform. Defendant Martinez resides in 

California and, in connection with the matters alleged herein, transacts or has transacted business 

in this District and throughout the United States. 

COMMERCE 

20. 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, and as trade or commerce is defined in Plaintiff States’ statutes. 

DEFENDANTS’ BUSINESS ACTIVITIES 

21. The Roomster Defendants advertise that their Roomster platform, available 

through their website and corresponding mobile applications, allows users to post and search 

listings for living arrangements, including rental properties, room rentals, sublets, and roommate 

requests. 

22. The Roomster Defendants claim that the listings provided on their platform are 

real, available, and verified. These representations have been published to millions of people. 

23. In numerous instances and on various locations on their website, the Roomster 

Defendants state that Roomster has “authentic” listings and that the Roomster Defendants 

“mak[e] sure the Roomster profiles and the listings on the site are complete, accurate, updated 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 9 of 36 

and yes...authentic.” 

24. Similarly, until they received notice of this investigation, the Roomster 

Defendants claimed on their mobile device applications to have “millions of verified listings” in 

a “safe community with real members worldwide:” 

25. In reality, the Roomster Defendants do not verify listings or ensure that their 

listings are real or authentic. The Roomster Defendants post listings on their Roomster platform 

immediately upon request, as long as the street address associated with the listing is recognized 

by the platform. The Roomster Defendants do not determine whether their listings are authentic 

and, despite purporting to offer only residential listings, do not verify whether the listed address 

is residential or commercial. 

26. For example, an undercover investigation shows that the Roomster Defendants 

immediately accepted and published a fake listing with a U.S. Postal Office commercial facility 

address. The fake listing also contained fictitious rental specifications that included an apartment 

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at less than half the price and twice the square footage as those in the represented market. That 

listing has remained active for several months. The Roomster Defendants have not contacted the 

lister to verify the address, the specifications, or the legitimacy of the email or other personal 

information of the lister. 

27. To lend credence to their misrepresentations that their listings are authentic and 

verified, the Roomster Defendants, often with the help of Defendant Martinez, saturate the 

internet with tens of thousands of 4 and 5 star fake reviews, including through app stores, where 

the Roomster Defendants do most of their business. 

28. App stores provide mobile application users the opportunity to leave customer 

reviews. Reviews provide a forum for sharing authentic feedback so consumers can make 

informed decisions about the products and services they use. Fictitious reviews distort the 

market. They are also illegal. 

29. Contrary to the law and app store terms of service that prohibit manipulating 

reviews or ratings, inflating rankings or ratings with paid, incentivized, fraudulent, or fake 

reviews or feedback, or otherwise cheating the system, the Roomster Defendants, directly and 

through others, including Martinez, posted mass quantities of positive reviews. 

30. Although the Roomster Defendants claim they do not pay for reviews, the 

Roomster Defendants bought over 20,000 reviews from Defendant Martinez alone. 

31. Defendant Martinez utilized more than 2,500 fake iTunes accounts, as well as 

fake gmail accounts, to push out fake reviews on Roomster’s apps. Before Martinez became 

aware of this investigation, his website stated “Buy app reviews & boost your app ranking.” By 

selling fake reviews to the Roomster Defendants, Defendant Martinez helped the Roomster 

Defendants distort the market and deceive potential users of the Roomster platform. 

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32. For over four years, the Roomster Defendants engaged in what Defendant 

Martinez referred to as “drip campaigns,” which involve “the steady flow of reviews.” The 

Roomster Defendants only paid for fake reviews that “stuck” (i.e., those that passed app store 

algorithms and were visible to consumers). At various times, Defendant Martinez told 

Defendants Shriber and Zaks that fake reviews had to be “dripped” at a “slower pace” because 

many were not “sticking.” 

33. Similarly, Defendant Shriber directed Defendant Martinez to spread out the 

reviews to be “constant and random.” 

34. In addition, Defendant Shriber instructed Defendant Martinez to produce “lots of 

5 star IOS app reviews” and stated that he “would like to be #1” for people searching for 

roommates. 

35. Along with the drip campaigns, Defendants also blasted hundreds of reviews at 

once when it suited their purposes. For example, Defendant Shriber stated “I need to get to the 

top of ‘rooms for rent’. [W]hat can be done?” Defendant Martinez responded, “We can blast 

100-200 reviews for that keyword to get some movement.” 

36. The Roomster Defendants also required that fictitious reviews post in random 

amounts. For example, they emailed Defendant Martinez the following: 

We are ready to place an order. 500 reviews for iTunes and 300 for 

Android for US market. 

. . . 

Post a random number every day and no more then [sic] 20 for 

iTunes, 15 for Android, please. 

37. The Roomster Defendants also directed that reviews post in random amounts for 

several countries across the globe, specifying in their orders how many reviews should go to 

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each country. For example, in one email alone, the Roomster Defendants directed Defendant 

Martinez as follows: 

Total number of reviews for iTunes platform shouldn’t ecceed [sic] 

50 per day. 

Please, post a random number of reviews between 18 - 30 

US market - 500 

500 for markets from this list 

random number of reviews between 4 - 10: 

Australia - 50 

Norway - 50 

random number of reviews between 1 - 8: 

Austria - 20 

Belgium - 20 

Bulgaria - 20 

Croatia - 20 

Czech Republic - 20 

Denmark - 20 

Estonia - 20 

Finland - 20 

France - 20 

Germany - 20 

Greece - 20 

Hungary - 20 

Ireland - 20 

Italy - 20 

Latvia - 20 

Lithuania - 20 

Luxembourg - 20 

Macedonia - 20 

Moldova - 20 

Netherlands - 20 

38. Even after receiving notice of the FTC’s investigation, the Roomster Defendants 

continued to instruct that reviews post in random amounts in order to appear natural, at one point 

emailing Defendant Martinez: 

Just as a reminder, please make sure it’s always a random number 

of reviews, so it looks more natural. 

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39. Examples of 5-star reviews that the Roomster Defendants bought include: 

a. Wonderful! 

Roomster is better then others. Very easy to use. Tons of 

listing. No scammers, all users are real. Easy to 

communicate with owners. In a single word FANTASTIC! 

b. Awesome! 

I found Roomster very useful for students who are 

searching for a place to live or friends to live with. It gives 

reasonable price, a lot of useful suggestions. 

c. Roomster is great! 

Especially for low-income people who need rented 

accom[m]odation or those students who need to rent a 

room because [i]t provides the service with a reasonable 

price range period. 

d. like! 

I’m a student with a small budget, so I love going through 

Roomster for sharing my room. It makes finding 

roommates faster and more efficient. Roomster is a good 

choice for me! 

e. Awesome! 

Roomster helps me save time and[] is a trusted name for 

me to post & search for accommodations around the world 

with other like minded individuals. 

f. Fantastic!!!! 

Roomster is easy to find roommates and apartments. All are 

shown obviously on the map. Secure and easier to be able 

to chat with your roommates. 

g. Fantastic!!! 

I found a ton of verified listings in Roomster. It is easy for 

everyone to find a great roommate. 

h. Love it! 

Everyone should use Roomster for finding roommates. I 

did & it worked great. Being able to click through to 

people’s Facebook is such a good idea. 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 14 of 36 

i. God job guys! 

I personally enjoyed using Roomster. I got all the help 

required from the[m] and also the genuine chat. 

j. Incredibly useful! 

Needed a roommate to share my place. Download 

Roomster. Got some great leads right away. 

k. Excellent! 

Good job ..lots of users ...very useful to find genuine users 

..no time wastage with brokers. Excellent! 

l. So useful! 

Roomster is really excellent. Best app for finding rooms & 

roommates shortly. So useful & very fast. 

40. The reviews in Paragraph 39 were fabricated. 

41. The sheer volume of the Roomster Defendants’ fake reviews dilutes reviews from 

real users, such as the following 1-star reviews: 

a. Full of scammers 

I highly highly suggest that you do not use this site! 

Because you will get scammed. This app is loaded with 

people trying to scam you! Out of every 10 post 8 are 

scammers DO NOT USE THIS APP!! 

b. Don’t waste your time 

I couldn’t give it zero. It won’t let me view things so I got a 

7 day subscription. Reached out to 38 listers. Got response 

from only 1 legitimate lister. The rest was all scam and 5 

days of headache. Steer clear. They don’t vet 

c. Worst app ever waste of money 

If I could give a negative 100 star I would. Idk of all those 

good reviews are fakes too or what. But I literally reach out 

to atleast 50-60 people and I received few msg offering a 

place. And all of them just fake. Same exact email you give 

the deposit and first month rent and they will mail you the 

key. Cause they “at funeral, in different country, traveling, 

blah blah blah blah.” Cause honestly if you make a app 

specific for room rental then should be vetted or something, 

not 99.9 fake once’s, and now they spamming craigslist 

with their fake posts. I used AirBnB which is free to use 

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and never had issue with them. They really need to change 

this website ASAP. I bet all of these 5 star reviews are all 

fake. How many people I know they all say the same about 

this website. 

d. Scams 

This site is full of scams. I have been contacted by multiple 

people on this app saying they can’t show me the room 

because they’re out of town but that I should send them the 

deposit and they’ll send me the key. It’s the same storyline 

every time. They also have bugs on Craigslist. There are 

listings on Craigslist that I email n they email back telling 

me to sign up for roomies [Roomster] and nothing else. A 

very disappointing app 

e. too bad 

most information are fake, administrator dont have any 

rules to prevent this issue. after i request renting from 

someone, she/he ask me for giftcard payment. ridiculous!!! 

f. Fake Scam Beware! 

This app charges you 7.95 then 24.95 then another 24.95. 

There’s absolutely no rooms. They are all scams! They 

don’t message back and refuse to give you your money 

back. I can’t believe this app is allowed. Please Do Not 

Download it! They lie, cheat and steal your $ with no 

return. 

g. Rip Off 

This site is full of fake ads to get you to pay $7.99 per 

week. They lure you in on Craigslist with an enticing ad 

and the only way to communicate is to sign up and pay. 

Funny thing is, they never answer. :(( 

h. You thought ! 

Worst app ever tons of scam artists it’s a fake app do not 

waste your money do not contact anyone it is a scam app 

people will try and hack your phone do not buy this app or 

download it beware 

i. Scam 

This app is garbage. I had higher hopes but it completely let 

me down. Every profile on here seems to be a fake profile 

and every message I got from people said almost exactly 

the same thing. Not worth it. 

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42. To further induce consumers to pay for their Roomster platform, the Roomster 

Defendants, either directly or through their affiliates, bait the internet with advertisements for 

fake listings, including on Craigslist. Through these fake listings, consumers are directed to 

Defendants’ platform and encouraged to sign up and pay a fee to obtain information necessary to 

secure the rental. Consumers who sign up soon learn that the listings that drove them to the 

Roomster Defendants’ platform do not exist. 

43. In addition, consumers are soon bombarded by fraudsters with more fake listings 

and are asked to pay hundreds or thousands of dollars to secure a rental, sight unseen, often 

under the guise that COVID-19 prevents the lister from showing the property. 

44. The Roomster Defendants have taken in excess of $27 million from consumers, 

many of whom can least afford to lose money. According to Defendant Zaks, “a Roomster 

customer is an individual in the lowest end of the rental market, they generally have limited 

funds, and every dollar counts.” Similarly, according to Defendant Shriber, the Roomster 

Defendants “are servicing the most affordable end of the [r]eal estate market. Searching for 

housing is stressful in all price points, but for Roomster customers even more so . . . generally for 

financial reasons. For Roomster customers every penny counts.” Compounding that injury, 

consumers have paid hundreds and even thousands of dollars more to fraudsters who take 

advantage of the Roomster Defendants’ non-existent verification protocols. 

45. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that the Roomster Defendants are violating or are about to violate laws 

enforced by the Commission, because, among other things, they engaged in their unlawful acts 

and practices repeatedly over a period of at least four years, they engaged in their unlawful acts 

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and practices willfully and knowingly, and they continued their unlawful acts or practices despite 

knowledge of numerous complaints and this investigation. 

46. In addition, based on the facts and violations of law alleged in this Complaint, the 

FTC has reason to believe that Defendant Martinez is violating or is about to violate laws 

enforced by the Commission because, among other things, he engaged in the unlawful acts and 

practices alleged repeatedly over a period of approximately four years, he did not cease doing 

business with the Roomster Defendants until after the FTC began its investigation, and Martinez 

has provided the same or similar services for other businesses. 

VIOLATIONS OF THE FTC ACT 

Count I 

False Endorsements 

(Against all Defendants) 

47. Through the means described above, Defendants have represented, directly or 

indirectly, expressly or by implication, that certain reviews of the Roomster platform were 

truthful reviews by actual users of the Roomster Defendants’ services. 

48. In truth and in fact, in numerous instances in which Defendants have made the 

representations set forth in Paragraphs 47 of this Complaint, the reviews of the Roomster 

platform were not truthful reviews by actual users of the platform, but instead were fabricated by 

one or more third parties who were paid to generate reviews. 

49. Therefore, the making of the representations as set forth in Paragraph 47 of this 

Complaint constitutes a deceptive act or practice and the making of false advertisements, in or 

affecting commerce, in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

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Count II 

Misrepresentations that Listings Are Verified, Authentic, or Available 

(Against the Roomster Defendants) 

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

offering for sale, or sale of services related to living arrangement listings, the Roomster 

Defendants, directly or through affiliates acting on their behalf and for their benefit, have 

represented, directly or indirectly, expressly or by implication, that the listings on their Roomster 

platform are verified, authentic, or available. 

51. The representations set forth in Paragraph 50 are false or misleading or were not 

substantiated at the time the representations were made. 

52. Therefore, the making of the representations as set forth in Paragraph 50 

constitutes a deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 

45(a). 

VIOLATIONS OF STATE LAWS 

Count III 

Violations of New York Executive Law Section 63(12) 

(By Plaintiff People of the State of New York Against All Defendants) 

53. As set forth in Paragraphs 1 through 46 above, which allegations are incorporated 

as if set forth herein, Defendants have committed acts and practices that constitute repeated or 

persistent fraudulent and illegal conduct in violation of N.Y. Executive Law § 63(12). 

Count IV 

Violations of New York General Business Law Article 22-A 

(By Plaintiff People of the State of New York Against All Defendants) 

54. As set forth in Paragraphs 1 through 46 above, which allegations are incorporated 

as if set forth herein, Defendants have committed acts and practices that are deceptive business 

practices and false advertising in violation of GBL §§ 349 and 350. 

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Count V 

Violations of California Business and Professions Code § 17500 et seq. 

(False or Misleading Statements) 

(By Plaintiff People of the State of California Against All Defendants) 

55. Plaintiff the People of the State of California allege and incorporate by reference 

paragraphs 1 through 52 above as though fully set forth herein. 

56. Defendants have engaged, and continue to engage in, aided and abetted, and 

conspired to engage in acts or practices that constitute violations of Business and Professions 

Code § 17500 et seq. by making or disseminating, or causing to be made or disseminated, false 

or misleading statements with the intent to induce members of the public to purchase 

Defendants’ services or products when Defendants knew, or by the exercise of reasonable care 

should have known, that the statements were false or misleading. 

57. The Roomster Defendants’ false or misleading statements include, but are not 

limited to, the following: 

a) falsely representing that certain reviews of the Roomster platform were 

truthful reviews by actual users when in actuality those reviews were not truthful 

reviews by actual users of the Roomster platform. 

b) falsely representing that the listings on the Roomster platform are verified, 

authentic, or available. 

58. Defendant Martinez’s false or misleading statements include, but are not limited 

to, the following: 

a) Falsely representing that certain reviews of the Roomster platform were 

truthful reviews by actual users when in actuality those reviews were not truthful 

reviews by actual users of the Roomster platform. 

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Count VI 

Violations of California Business and Professions Code § 17200 et seq. 

(Unlawful, Unfair, and/or Fraudulent Business Practices) 

(By Plaintiff People of the State of California Against All Defendants) 

59. Plaintiff the People of the State of California reallege and incorporate by 

reference Paragraphs 1 through 52 and 55 through 58 as though fully set forth herein. 

60. Defendants have engaged, and continue to engage, aided and abetted, and 

conspired to engage in acts or practices that are unlawful, unfair, or fraudulent, and which 

constitute unfair competition within the meaning of California Business and Professions Code 

§ 17200. These acts or practices include, but are not limited to, the following: 

a) Defendants have violated Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), 

as alleged herein; 

b) Defendants have violated Business and Professions Code § 17500 et seq. 

as alleged in Count V; 

c) The Roomster Defendants have violated the California Consumer Legal 

Remedies Act, California Civil Code § 1770(5), by representing that their goods 

or services have sponsorship, approval, characteristics, ingredients, uses, benefits, 

or quantities that they do not have; 

d) The Roomster Defendants have violated the California Consumer Legal 

Remedies Act, California Civil Code § 1770(7), by representing that their goods 

or services are of a particular standard, quality, or grade, when they are of 

another; 

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e) The Roomster Defendants have violated the California Consumer Legal 

Remedies Act, California Civil Code § 1770(9), by advertising goods or services 

with intent not to sell them as advertised. 

Count VII 

Violations of the Colorado Consumer Protection Act (CCPA) 

(Knowingly or recklessly making a false representation as to the source, sponsorship, 

approval, or certification of goods, services, or property, C.R.S. § 6-1-105(1)(b)) 

(By Plaintiff State of Colorado Against the Roomster Defendants) 

61. Plaintiff State of Colorado incorporates herein by reference all allegations set 

forth above. 

62. In the course of their business or occupation, the Roomster Defendants violated, 

and may continue to violate, the CCPA by knowingly or recklessly making false representations 

in advertisements and other communications. 

63. The Roomster Defendants’ false or misleading statements as to the certification of 

goods, services, or property include, but are not limited to: 

a) falsely representing that certain reviews of the Roomster platform were 

truthful reviews by actual users when those reviews were not truthful reviews by 

actual users of the Roomster platform; 

b) falsely representing that certain listings on the Roomster platform are 

verified, authentic, or available. 

64. The Roomster Defendants’ false and misleading acts and practices had a 

significant public impact. 

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Count VIII 

Violations of the Colorado Consumer Protection Act (CCPA) 

(Knowingly or recklessly making false representations as to affiliation, connection, or 

association with or certification by another, C.R.S. § 6-1-105(1)(c)) 

(By Plaintiff State of Colorado Against All Defendants) 

65. Plaintiff State of Colorado incorporates herein by reference all allegations set 

forth above. 

66. In the course of their business or occupation, Defendants violated, and may 

continue to violate, the CCPA by knowingly or recklessly making false representations in 

advertisements and other communications regarding the source of certain consumer reviews for 

the Roomster platform and the affiliation, connection, association, or certification of those 

reviews with or by real consumers of the Roomster platform. 

67. Defendants’ false or misleading statements include, but are not limited to, falsely 

representing that those reviews were truthful reviews by actual users of the Roomster platform 

when those reviews were not truthful reviews by actual users of the Roomster platform. 

68. Defendants’ false and misleading acts and practices had a significant public 

impact. 

Count IX 

Violations of the Colorado Consumer Protection Act (CCPA) 

(Knowingly or recklessly engaging in any unfair, unconscionable, deceptive, deliberately 

misleading, false, or fraudulent act or practice, C.R.S. § 6-1-105(1)(kkk)1) 

(By Plaintiff State of Colorado against the Roomster Defendants) 

69. Plaintiff State of Colorado incorporates herein by reference all allegations set 

forth above. 

1 Effective October 1, 2022, C.R.S. § 6-1-105(1)(kkk) will be recodified to C.R.S. 6-1-105(1)(rrr). Colo. 

Gen. Assembly HB 22-1287, § 27 (May 26, 2022). The statute’s language will not change. 

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70. In the course of their business or occupation, the Roomster Defendants violated, 

and may continue to violate the CCPA by knowingly or recklessly making false representations 

in advertisements and other communications. 

71. The Roomster Defendants’ deliberately misleading, false, or fraudulent acts or 

practices include, but are not limited to: 

a) falsely representing that certain reviews of the Roomster platform were 

truthful reviews by actual users when those reviews were not truthful reviews by 

actual users of the Roomster platform; 

b) falsely representing that the listing on the Roomster platform are verified, 

authentic, or available. 

Count X 

Violations of the Florida Deceptive and Unfair Trade Practices Act (FDUTPA) 

(False Endorsements) 

(By Plaintiff State of Florida Against All Defendants) 

72. As set forth in Paragraphs 1 through 46 above, which allegations are incorporated 

as if set forth herein, in the course of Defendants’ trade or commerce, Defendants have 

committed acts and practices that are unfair or deceptive in violation of FDUTPA. 

73. Section 501.204(1), Florida Statutes, declares that “unfair or deceptive acts or 

practices in the conduct of any trade or commerce are hereby declared unlawful.” 

74. Section 501.203(8), Florida Statutes, defines “trade or commerce” as “the 

advertising, soliciting, providing, offering, or distributing, whether by sale, rental, or otherwise, 

of any good or service, or any property, whether tangible or intangible, or any other article, 

commodity, or thing of value, wherever situated. “Trade or commerce” shall include the conduct 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 24 of 36 

of any trade or commerce, however denominated, including any nonprofit or not-for-profit 

person or activity.” 

75. Through the means described above, Defendants have represented, directly or 

indirectly, expressly or by implication, that certain reviews of the Roomster platform were 

truthful reviews by actual users of the Roomster Defendants’ services. 

76. In truth and in fact, in numerous instances in which the Defendants have made the 

representations set forth in Paragraph 75 of this Complaint, the reviews of the Roomster platform 

were not truthful reviews by actual users of the platform, but instead were fabricated by one or 

more third parties who were paid to generate reviews. 

77. Therefore, the making of the representations as set forth in Paragraph 75 of this 

Complaint constitutes a deceptive act or practice and the making of false advertisements, in or 

affecting commerce in violation of Section 501.204(1), Florida Statutes. 

78. Shriber, Zaks, and Martinez are personally liable for the unlawful acts and 

practices described above, as Shriber, Zaks, and Martinez have the authority and power to 

control or direct the conduct at issue herein and/or actually participated in and directed the 

conduct at issue herein. 

Count XI 

Violations of the Florida Deceptive and Unfair Trade Practices Act (FDUTPA) 

(Misrepresentations that Listings Are Verified, Authentic, or Available) 

(By Plaintiff State of Florida Against the Roomster Defendants) 

79. As set forth in Paragraphs 1 through 46 above, which allegations are incorporated 

as if set forth herein, in the course of the Roomster Defendants’ trade or commerce, the 

Roomster Defendants have committed acts and practices that are unfair or deceptive in violation 

of FDUTPA. 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 25 of 36 

80. Section 501.204(1), Florida Statutes, declares that “unfair or deceptive acts or 

practices in the conduct of any trade or commerce are hereby declared unlawful.” 

81. Section 501.203(8), Florida Statutes, defines “trade or commerce” as “the 

advertising, soliciting, providing, offering, or distributing, whether by sale, rental, or otherwise, 

of any good or service, or any property, whether tangible or intangible, or any other article, 

commodity, or thing of value, wherever situated. “Trade or commerce” shall include the conduct 

of any trade or commerce, however denominated, including any nonprofit or not-for-profit 

person or activity.” 

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

offering for sale, or sale of services related to living arrangement listings, the Roomster 

Defendants, directly or through affiliates acting on their behalf and for their benefit, have 

represented, directly or indirectly, expressly or by implication, that the listings on their Roomster 

platform are verified, authentic, or available. 

83. The representations set forth in Paragraph 82 are false or misleading or were not 

substantiated at the time the representations were made. 

84. Therefore, the making of the representations as set forth in Paragraph 82 

constitutes a deceptive act or practice in violation of Section 501.204(1), Florida Statutes. 

85. Shriber and Zaks are personally liable for the unlawful acts and practices of 

Roomster, as Shriber and Zaks have the authority and power to control or direct the conduct at 

issue herein and/or actually participated in and directed the conduct at issue herein. 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 26 of 36 

Count XII 

Violations of the Illinois Consumer Fraud and Deceptive Business Practices Act 

(Misrepresentations) 

(By Plaintiff State of Illinois Against All Defendants) 

86. Plaintiff State of Illinois alleges and incorporates by reference paragraphs 1 

through 46 above as though fully set forth herein. 

87. In numerous instances, in connection with their website and corresponding mobile 

applications and posting of consumer reviews related to these products, and while engaged in a 

course of trade or commerce, Defendants have violated Section 2 of the Illinois Consumer Fraud 

Act, 815, ILCS 505/2, by representing to consumers, directly or indirectly, expressly or by 

implication, with the intent that consumers rely on the representations, that certain reviews of the 

Roomster platform were truthful reviews by actual users when in actuality those reviews were 

not truthful reviews by actual users of the Roomster platform. 

Count XIII 

Violations of the Illinois Consumer Fraud and Deceptive Business Practices Act 

(Misrepresentations) 

(By Plaintiff State of Illinois against the Roomster Defendants) 

88. Plaintiff State of Illinois alleges and incorporates by reference paragraphs 1 

through 46 above as though fully set forth herein. 

89. In numerous instances, in connection with their website and corresponding mobile 

applications and posting of consumer reviews related to these products, and while engaged in a 

course of trade or commerce, the Roomster Defendants have violated Section 2 of the Illinois 

Consumer Fraud Act, 815 ILCS 505/2, directly or through affiliates acting on their behalf and for 

their benefit, by representing, directly or indirectly, expressly or by implication, with the intent 

that consumers rely on the misrepresentations, that that the listings on the Roomster platform are 

verified, authentic, or available when such was not the case. 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 27 of 36 

Count XIV 

Violations of the Massachusetts Consumer Protection Act 

(Unfair or Deceptive Acts and Practices) 

(By Plaintiff Commonwealth of Massachusetts Against All Defendants) 

90. Plaintiff Commonwealth of Massachusetts realleges paragraphs 1 through 52 of 

this Complaint. 

91. Defendants falsely and deceptively represented, directly or indirectly, that certain 

reviews of the Roomster platform were truthful reviews by actual users of Roomster’s services. 

This conduct constitutes unfair and deceptive acts and practices that violate the Massachusetts 

Consumer Protection Act, Mass. Gen. Laws ch. 93A, §2, and rules and regulations promulgated 

thereunder, including 940 Mass. Code Regs. §§ 3.05(1) and 3.16(4). 

Count XV 

Violations of the Massachusetts Consumer Protection Act 

(Unfair or Deceptive Acts and Practices) 

(By Plaintiff Commonwealth of Massachusetts Against the Roomster Defendants) 

92. Plaintiff Commonwealth of Massachusetts realleges paragraphs 1 through 52 of 

this Complaint. 

93. The Roomster Defendants falsely and deceptively represented, directly or 

indirectly, that the housing listings on the Roomster platform are verified, authentic, or available. 

This conduct constitutes unfair and deceptive acts and practices that violate the Massachusetts 

Consumer Protection Act, Mass. Gen. Laws ch. 93A, §2, and rules and regulations promulgated 

thereunder, including 940 Mass. Code Regs. §§ 3.05(1), 3.16(2) and (4), and 6.04(1)-(2). 

CONSUMER INJURY 

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

injury as a result of Defendants’ violations of the FTC Act, N.Y. Executive Law § 63(12) and 

N.Y. GBL §§ 349 and 350, California False Advertising Law and California Unfair Competition 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 28 of 36 

Law, the CCPA, the FDUTPA, the Illinois Consumer Fraud Act, and the Massachusetts 

Consumer Protection Act. Absent injunctive relief by this Court, Defendants are likely to 

continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiffs request that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC Act and 

Plaintiff States’ laws by Defendants; 

B. Award monetary and other relief within the Court’s power to grant, including 

restitution to injured consumers nationwide as provided under state law; 

C. Award Plaintiff States civil penalties for each violation of their respective state 

laws, including: 

1) Pursuant to New York GBL § 350-d, award the State of New York civil 

penalties in an amount up to $5,000 for each violation of New York GBL §§ 349 

and 350; 

2) Pursuant to California Business and Professions Code section 17536, 

award California civil penalties of $2,500 for each violation of California 

Business and Professions Code section 17500, as proved at trial, and pursuant to 

California Business and Professions Code section 17206, award the State of 

California civil penalties of $2,500 for each violation of California Business and 

Professions Code section 17200, as proved at trial; 

3) Pursuant to C.R.S. § 6-1-112(1)(a), award the State of Colorado civil 

penalties of up to $20,000 per violation of the CCPA; 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 29 of 36 

4) Pursuant to Section 501.2075, Florida Statutes, award the State of Florida 

civil penalties of up to $10,000 per violation of FDUTPA for any person who has 

willfully engaged in an unfair or deceptive act or practice, and pursuant to Section 

501.2077, Florida Statutes, award the State of Florida civil penalties up to 

$15,000 per violation for any person willfully using an act or practice that violates 

FDUTPA which victimizes a senior citizen, or a person who has a disability, or is 

directed at a military servicemember or the spouse or dependent child of a 

military servicemember; 

5) Pursuant to Section 7 of the Illinois Consumer Fraud Act, 815 ILCS 505/7, 

award the State of Illinois civil penalties up to $50,000 per deceptive or unfair act 

or practice, and an additional amount of $50,000 for each act or practice found to 

have been committed with intent to defraud; and 

6) Pursuant to Massachusetts Gen. Laws ch. 93A, § 4, award the 

Commonwealth of Massachusetts civil penalties up to $5,000 for each violation of 

the Massachusetts Consumer Protection Act, Mass. Gen. Laws ch. 93A, § 2, and 

rules and regulations promulgated thereunder, including 940 Mass. Code Regs. §§ 

3.05(1), 3.16(2) and (4), and 6.04(1)-(2); 

D. Award Plaintiff States attorneys’ fees, costs, and expenses as provided under state 

law; and 

E. Award any additional relief as the Court determines to be just and proper. 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 30 of 36 

Respectfully submitted, 

FOR THE FEDERAL TRADE COMMISSION: 

Dated: ____________________ 

ANGELEQUE P. LINVILLE (pro hac vice 

application pending) 

8/30/22

alinville@ftc.gov; (404) 656-1354 

VALERIE M. VERDUCE (pro hac vice application 

pending) 

vverduce@ftc.gov; (404) 656-1355 

Federal Trade Commission 

233 Peachtree Street, Suite 1000 

Atlanta, GA 30303 

Facsimile: (404) 656-1379 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 31 of 36 

FOR THE PEOPLE OF THE STATE OF CALIFORNIA: 

Dated: ROB BONTA 

Attorney General, State of California 

NICKLAS A. AKERS 

Senior Assistant Attorney General 

____________________ 8/29/22

EMILY KALANITHI (NY 4191805)

Deputy Attorney General

emily.kalanithi@doj.ca.gov; (415) 510-3468 

JON F. WORM (pro hac vice application pending)

Supervising Deputy Attorney General 

jon.worm@doj.ca.gov; (619) 738-9325 

CAROLINE E. WILSON (pro hac vice application 

pending) 

Deputy Attorney General 

callie.wilson@doj.ca.gov; (415) 229-0106 

California Department of Justice

Office of the Attorney General

455 Golden Gate Ave., 11th Fl. 

San Francisco, CA 94102 

Attorneys for Plaintiff

PEOPLE OF THE STATE OF CALIFORNIA 

31 
L M. HINCHCL 

Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 32 of 36 

FOR THE ST ATE OF COLORADO: 

PHILIP J. WEISER 

Attorney General 

State ofColorado 

AB 

application pending) 

First Assistant Attorney General 

Abigail.Hinchcliff@coag.gov; (720) 508-6000 

BRADY J. GRASSMEYER (pro hac vice 

application pending) 

Assistant Attorney General 

Brady.Grassmeyer@coag.gov; (720) 508-6000 

1300 Broadway, 10th Floor 

Denver, CO 80203 

Attorneys for Plaintiff 

STATE OF COLORADO 

32 
FOR THE STATE OF FLORIDA: 

ASHLEY MOODY 

Attorney General, State of Florida 

Ryann H. Flack hac vice application pending) 

Ryann.Flack@myfloridalegal.com; (786) 792-6249 

Miles Vaughn (pro hac vice application pending) 

Miles.Vaugh@myfloridalegal.com; (8 I 3) 287-7257 

Office of the Attorney General 

Consumer Protection Division 

SunTrust International Center 

I S.E. 3rd A venue, Suite 900 

Miami, FL 33131 

Attorneys for Plaintiff 

STA TE OF FLORrDA 

33 

Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 33 of 36 
FOR THE PEOPLE OF THE STATE OF ILLINOIS: 

KWAMERAOUL 

Attorney General of Illinois 

~-

SSANDRA Ml2Ud~ HALM (pro hac vice application 

pending) 

Assistant Attorney General 

Cassandra.Halm@ilag.gov; (217) 725-9591 

ELIZABETH BLACKSTON (pro hac vice 

application pending) 

Bureau Chief 

Elizabeth.Blackston@ilag.gov; (217) 725-8649 

Office of the Illinois Attorney General 

500 South Second Street 

Springfield, IL 62701 

Attorneys for Plaintiff 

THE PEOPLE OF THE STATE OF ILLINOIS 

34 

Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 34 of 36 
FOR THE COMMONWEAL TH OF MASSACHUSETTS: 

MAURA HEALEY 

Attorney General 

Commonwealth of Massachusetts 

Mychii S ape (MS1544) 

Assistant Attorney General 

Mychii.Snape@mass.gov; (617) 727-2200 

Consumer Protection Division 

Office of the Attorney General 

One Ashburton Place 

Boston, MA 02108, I 8th Floor 

Attorney for Plaintiff 

COMMONWEAL TH OF MASSACHUSETTS 

35 

Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 35 of 36 
 

Case 1:22-cv-07389 Document 4 Filed 08/30/22 Page 36 of 36 

FOR THE PEOPLE OF THE STATE OF NEW YORK: 

Dated: ____________________ 8/30/2022 LETITIA JAMES 

Attorney General of the State of New York 

S/ Melvin L. Goldberg

MELVIN L. GOLDBERG (NY 1828284) 

Assistant Attorney General 

Melvin.Goldberg@ag.ny.gov; (212) 416-8296 

28 Liberty Street 

New York, New York 10005 

Facsimile: 212-416-6003 

Attorney for Plaintiff 

PEOPLE OF THE STATE OF NEW YORK 

and 

JANE M. AZIA 

Bureau Chief 

Consumer Frauds and Protection Bureau 

LAURA J. LEVINE 

Deputy Bureau Chief 

Bureau of Consumer Frauds and Protection 

Of Counsel for Plaintiff 

PEOPLE OF THE STATE OF NEW YORK 

36