UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF FLORIDA 

TAMPA DIVISION 

FEDERAL TRADE COMMISSION, and Case No. 8:23-cv-796-MSS-CPT 

OFFICE OF THE ATTORNEY GENERAL, STIPULATED ORDER FOR 

STATE OF FLORIDA, DEPARTMENT OF PERMANENT INJUNCTION, LEGAL AFFAIRS, MONETARY RELIEF, STATUTORY 

RELIEF, AND FINAL JUDGMENT 

Plaintiffs, 

V. 

GLOBAL E-TRADING, LLC, a limited liability 

company, also d/b/a CHARGEBACKS911, 

GARY CARDONE, individually and as an officer 

of GLOBAL E-TRADING, LLC, and 

MONICA EATON, individually and as an officer of 

GLOBAL E-TRADING, LLC, 

Defendants. 

THIS CAUSE comes before the Comt on stipulation of the Paities. The Comt finds that it has 

jmisdiction over this matter and without fmther factual findings by the Comt enters Judgment on the 

following stipulations of the Pa1t ies: 

Plaintiffs, the Federal Trade Commission ("Commission" or "FTC") and the Office of the 

Attorney General, State of Florida, Depa1tment of Legal Affairs ("Florida Attorney General") 

(collectively, "Plaintiffs"), filed their Complaint for Pennanent Injunction, Monetaiy Relief, and 

Other Statuto1y Relief ("Complaint"), for a pe1manent injunction and equitable and statuto1y 

relief in this matter, pmsuant to Section 13(b) of the Federal Trade Commission Act ("FTC Act"), 

15 U.S.C. § 53(b), and the Florida Deceptive and Unfair Trade Practices Act ("FDUTPA"), 

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Chapter 501, Part II, Florida Statutes (2021). Plaintiffs and Defendants stipulate to the entry of 

this Stipulated Order for Permanent Injunction, Monetary Relief, Statutory Relief, and Final 

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

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

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

violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and the Florida Deceptive and Unfair 

Trade Practices Act (“FDUTPA”), Chapter 501, Part II in submitting misleading documentation 

in connection with disputing consumer Chargeback requests on behalf of their clients; ignoring 

red flags indicating that the documentation was misleading; and in effecting, or causing to be 

effected, Microtransactions that artificially lowered a merchant’s overall Chargeback Rate by 

inflating the total number of transactions run through the merchant’s account. 

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

as specifically stated in this Judgment 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 Judgment 

Order, and agree to bear their own costs and attorney fees. 

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

contest the validity of this Judgment Order. 

DEFINITIONS 

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

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A. “Acquirer” means a business organization, financial institution, or an agent of a 

business organization or financial institution that has authority from an organization that operates 

or licenses a credit card system (e.g., Visa, MasterCard, American Express, and Discover) to 

authorize Merchants to accept, transmit, or process payment by credit card through the credit card 

system for money, goods, services, or anything else of value. 

B. “Affiliate” means any Person, including any third-party marketer, who participates 

in an Affiliate Program. 

C. “Affiliate Network” means any Person who provides another Person with 

Affiliates for an Affiliate Program or with whom any Person contracts as an Affiliate to promote 

any product, service, or program. 

D. “Affiliate Program” means any arrangement under which any Person pays, or 

offers to pay, or provides, or offers to provide, any form of consideration to any third party, either 

directly or through an Affiliate Network, to provide such Person with, or refer to such Person, 

potential or actual customers. 

E. “Alert” means a pre-Chargeback notification that allows merchants to prevent a 

Chargeback by cancelling an order, halting an ongoing subscription, providing a credit, 

processing a refund, or voiding a sale upon receipt. 

F. “Chargeback” means a procedure whereby an issuing bank or other financial 

institution charges all or part of an amount of a Person’s credit or debit card transaction back to 

the Acquirer or other financial institution. 

G. “Chargeback Mitigation Services” means services that assist Merchants in: 

disputing Chargebacks; preventing, reducing, managing, or analyzing Chargebacks or their 

Chargeback Rate; or complying with credit card system requirements for Merchants with an 

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excessive number of Chargebacks and/or an elevated Chargeback Rate. For purposes of this 

Order, Chargeback Mitigation Services do not include Alerts. 

H. “Chargeback Rate” means the proportion (expressed as a percentage) of 

Chargebacks out of the total number of attempted credit or debit card sales transactions. 

I. “Covered Client” means a customer of Defendants that uses Affiliate Networks to 

acquire customers; uses a Negative-Option Feature for the sale of products or services online; and 

sells the following goods: Cosmetics, Dietary Supplements, or Drugs. Covered Clients do not 

include companies that are publicly traded on a national stock exchange or companies with annual 

revenues over $100 million. 

J. “Cosmetic” means: 

1. articles to be rubbed, poured, sprinkled, or sprayed on, introduced into, or 

otherwise applied to the human body or any part thereof intended for cleansing, beautifying, 

promoting attractiveness, or altering the appearance; and 

2. articles intended for use as a component of any such article, except that 

such term shall not include soap. 

K. “Defendants” means all of the Individual Defendants and the Corporate 

Defendant, individually, collectively, or in any combination. 

1. “Corporate Defendant” means Global E-Trading, LLC, d/b/a 

Chargebacks911 and its successors and assigns. 

2. “Individual Defendants” means Gary Cardone and Monica Eaton. 

L. “Dietary Supplement” means: 

1. any product labeled as a dietary supplement or otherwise represented as a 

dietary supplement; or 

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2. any pill, tablet, capsule, powder, softgel, gelcap, liquid, or other similar 

form containing one or more ingredients that are a vitamin, mineral, herb or other botanical, 

amino acid, probiotic, or other dietary substance for use by humans to supplement the diet by 

increasing the total dietary intake, or a concentrate, metabolite, constituent, extract, or 

combination of any ingredient described above, that is intended to be ingested, and is not 

represented to be used as a conventional food or as a sole item of a meal or the diet. 

M. “Drug” means: 

1. articles recognized in the official United States Pharmacopoeia, official 

Homeopathic Pharmacopoeia of the United States, or official National Formulary, or any 

supplement to any of them; 

2. articles intended for use in the diagnosis, cure, mitigation, treatment, or 

prevention of disease in humans or other animals; 

3. articles (other than food) intended to affect the structure or any function of 

the body of humans or other animals; and 

4. articles intended for use as a component of any article specified in 

Subsection (1), (2), or (3); but does not include devices or their components, parts, or accessories. 

N. “Merchant” means a Person who is authorized under a written contract with an 

Acquirer or a Payment Processor to honor or accept credit cards, or to transmit or process for 

payment credit card payments, for the purchase of goods or services or a charitable contribution. 

O. “Merchant Account” means any account with an Acquirer or other financial 

institution, service provider, Payment Processor, independent sales organization, payment 

facilitator, or other entity that enables an individual, a business, or other organization to accept 

payments of any kind. 

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P. “Microtransactions,” also referred to as Value Added Promotions or VAP, means 

a sales transaction where no goods or services are exchanged. 

Q. “Negative-Option Feature” means, in an offer or agreement to sell or provide any 

good or service, a provision under which the consumer’s silence or failure to take affirmative 

action to reject a good or service, or to cancel the agreement, is interpreted by the Merchant or 

provider as acceptance or continuing acceptance of the offer. 

R. “Payment Processing” means transmitting sales transaction data on behalf of a 

Merchant or providing a Person, directly or indirectly, with the means used to charge or debit 

accounts through the use of any payment method or mechanism, including, but not limited to, 

credit cards, debit cards, prepaid cards, stored value cards, ACH debits, and remotely created 

payment orders. Whether accomplished through the use of software or otherwise, Payment 

Processing includes, among other things: (a) reviewing and approving Merchant applications for 

payment processing services; (b) transmitting sales transaction data or providing the means to 

transmit sales transaction data from Merchants to Acquirers, Payment Processors, independent 

sales organizations, or other financial institutions; (c) clearing, settling, or distributing proceeds of 

sales transactions from Acquirers or financial institutions to Merchants; (d) processing 

Chargebacks or returned remotely created payment orders or ACH debits; or (e) signing a 

merchant acceptance agreement on behalf of an Acquirer, or receiving settlement of transaction 

proceeds from an Acquirer, on behalf of a sponsored merchant. Provided, however, that a Person 

does not provide Payment Processing services to a client where such Person provides to that client 

only payment gateway services. 

S. “Payment Processor” means any Person providing Payment Processing services 

in connection with another Person’s sale of goods or services, or in connection with any 

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charitable donation. 

T. “Person” means any natural person, organization, or legal entity, including a 

corporation, limited liability company, partnership, proprietorship, association, cooperative, 

government or governmental subdivision or agency, or any other group or combination acting as 

an entity. 

ORDER 

I. PROHIBITIONS AGAINST UNFAIR CHARGEBACK PRACTICES 

IT IS 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 Judgment Order, whether acting directly or indirectly, are permanently restrained and 

enjoined from: 

A. Providing Chargeback Mitigation Services to any Covered Client; 

B. In providing Chargeback Mitigation Services, whether on behalf of themselves or 

others, submitting, or assisting others in submitting, directly or indirectly, any documentation that 

Defendants know or should know is misleading or materially inaccurate, or failing to disclose any 

information that Defendants know or should know is relevant and material; 

C. When submitting documents or information in connection with a Chargeback, 

including screenshots of webpages that Defendants know or should know are materially different 

from the webpages the consumer saw at the time of the transaction; 

D. Engaging, or assisting others in engaging, directly or indirectly, in any prohibited 

or unlawful tactics to avoid fraud and risk monitoring programs established by any financial 

institution, Acquirer, or the operators of any payment system, including, but not limited to: 

1. Balancing or distributing sales transaction volume or sales transaction 

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activity among multiple Merchant Accounts or merchant billing descriptors to avoid fraud and/or 

risk monitoring programs established by any financial institution, Acquirer, or the operators of 

any payment system; 

2. Splitting a single sales transaction into multiple smaller transactions to 

avoid fraud and/or risk monitoring programs established by any financial institution, Acquirer, or 

the operators of any payment system; or 

3. Causing, or causing to be effected, a sham sales transaction, including 

Microtransactions or sales transactions by a Merchant to itself to avoid fraud and/or risk 

monitoring programs established by any financial institution, Acquirer, or the operators of any 

payment system. 

II. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment is hereby entered against Defendants, jointly and severally, for civil 

penalties in the amount of One Hundred Thousand Dollars ($100,000) (the “Penalty Amount”). 

See §§ 501.2075; 501.2077, Florida Statutes. 

B. The Attorney General is entitled to payment of its attorney’s fees and costs in the 

amount of Fifty Thousand Dollars ($50,000). Judgment is hereby entered against Defendants, 

jointly and severally, for attorney’s fees and costs in the amount of $50,000 (the “Fee Amount”). 

See §§ 501.2075; 501.2105, Florida Statutes. 

C. Therefore, the total final judgment amount consisting of the Penalty Amount and 

the Fee Amount is $150,000 (the “Judgment Amount”). 

D. Defendants have agreed and are hereby ordered to pay the total Judgment Amount 

simultaneously upon execution of this Judgment Order by Defendants. All payments made 

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pursuant to this Judgment Order shall be made by wire transfer, cashier’s check, or other certified 

funds payment to the Department of Legal Affairs and shall be sent to the attention of Jennifer 

Hayes Pinder, Tampa Assistant Bureau Chief, Office of the Attorney General, Consumer 

Protection Division, 3507 East Frontage Road, Suite 325, Tampa, Florida 33607. 

III. ADDITIONAL MONETARY PROVISIONS 

IT IS FURTHER ORDERED that: 

A. Defendants further agree not to object or otherwise dispute any claim for nondischargeability of the Judgment Amount in any voluntary or involuntary bankruptcy proceeding. 

In any bankruptcy proceeding relating to the non-dischargeability of the Judgment Amount, 

Defendants stipulate that the allegations of the Complaint and the filings of this Court may be 

taken as true and correct without further proof. Further, Defendants agree that the facts alleged 

in the Complaint establish all elements necessary to find the Judgment Amount is not subject to 

discharge pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, and this Judgment Order will 

have collateral estoppel effect for such purposes. 

B. Defendants agree that the Judgment Amount imposed in connection with this case 

is not subject to discharge under the Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7). 

C. In the event any Defendant files bankruptcy, or an involuntary bankruptcy 

proceeding is commenced, within 90 days after making any payment pursuant to this Judgment 

Order, the applicable Defendant shall remain liable for the full balance of the Judgment Amount 

as agreed upon herein. The Judgment Amount may be asserted by the Florida Attorney General 

in any subsequent proceeding to enforce this Judgment Order, whether through execution, 

garnishment, or other legal proceedings, or through a proof of claim in any bankruptcy 

proceeding of any Defendant. 

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IV. ORDER ACKNOWLEDGMENTS 

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

Judgment Order: 

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

both Plaintiffs an acknowledgment of receipt of this Judgment Order sworn under penalty of 

perjury. 

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

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

the majority owner or controls directly or indirectly, and Corporate Defendant, must deliver a 

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

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

matter of the Judgment Order and all agents and representatives who participate in conduct related 

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

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

within 7 days of entry of this Judgment Order for current personnel. For all others, delivery must 

occur before they assume their responsibilities. 

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

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

of receipt of this Judgment Order. 

V. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to both Plaintiffs, 

as set forth below: 

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

compliance report, sworn under penalty of perjury: 

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

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

Plaintiffs 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, and the involvement of any other Defendant (which Individual 

Defendants must describe if they know or should know due to their own involvement); (d) 

describe in detail whether and how that Defendant is in compliance with each Section of this 

Judgment Order; and (e) provide a copy of each Order Acknowledgment obtained pursuant to this 

Judgment Order, unless previously submitted to both Plaintiffs. 

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

numbers and all physical, postal, email and Internet addresses, including all residences; (b) 

identify all business activities, including any business for which such Defendant performs 

services whether as an employee or otherwise and any entity in which such Defendant has any 

ownership interest; and (c) describe in detail such Defendant’s involvement in each such business, 

including title, role, responsibilities, participation, authority, control, and any ownership. 

B. For 5 years after entry of this Judgment 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 Corporate Defendant or any entity that Defendant has any 

ownership interest in or controls directly or indirectly that may affect compliance obligations 

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arising under this Judgment 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 Judgment 

Order. 

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

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

activity, including any business for which such Defendant performs services whether as an 

employee or otherwise and any entity in which such Defendant has any ownership interest, and 

identify the name, physical address, and any Internet address of the business or entity. 

C. Each Defendant must submit to both Plaintiffs 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 either Plaintiff required by this Judgment 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 Judgment 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. Global E-Trading, 

LLC. 

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F. Unless otherwise directed by a representative of the Florida Attorney General in 

writing, all submissions to the Florida Attorney General pursuant to this Judgment Order must be 

emailed to oag.ec.tpa@myfloridalegal.com and Jennifer.pinder@myfloridalegal.com or sent by 

overnight courier (not the U.S. Postal Service) to: Florida Office of the Attorney General, 

Consumer Protection Division, 3507 E. Frontage Roade, Suite 325, Tampa, FL 33607. The 

subject line must begin: FTC v. Global E-Trading, LLC. 

VI. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 5 years after 

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

Defendant, in connection with offering Chargeback Mitigation Services, and each Individual 

Defendant for any business that such Defendant, individually or collectively with any other 

Defendants, is a majority owner or controls directly or indirectly, must create and retain the 

following records: 

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

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

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

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

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

Judgment Order, including all submissions to the Commission; and 

D. a copy of all data submitted in connection with disputing Chargeback requests. 

VII. COMPLIANCE MONITORING 

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

with this Judgment Order: 

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

Plaintiff, each Defendant must: submit additional compliance reports or other requested 

information, which must be sworn under penalty of perjury; appear for depositions; and produce 

documents for inspection and copying. Both Plaintiffs are 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 Judgment Order, both Plaintiffs are authorized to 

communicate directly with each Defendant. Defendant must permit representatives of Plaintiffs 

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

an interview. The person interviewed may have counsel present. 

C. Both Plaintiffs 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 Judgment 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 either Plaintiff, 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). This authorization 

shall remain in effect until such time that the monetary terms of this Judgment Order are satisfied. 

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VIII. RETENTION OF JURISDICTION 

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

of construction, modification, and enforcement of this Judgment Order. 

DONE and ORDERED in Tampa, Florida, this 29th day of November 2023. 

Copies furnished to: 

Counsel of Record 

Any Unrepresented Person 

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