FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 1 of 53 * PUBLIC *; 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF THE ADMINISTRATIVE LAW JUDGE 

In the Matter of 

HOMEADVISOR, INC., 

a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED 

BY ANGI. 

Docket No. 9407 

Public

ANSWER AND DEFENSES 

OF RESPONDENT HOMEADVISOR, INC. 

Pursuant to Rule 3.12 of the Federal Trade Commission’s (“FTC”) Rules of Practice for 

Adjudicative Proceedings, Respondent HomeAdvisor, Inc. (“HomeAdvisor” or “Respondent”), 

by and through its attorneys, hereby files the following answer to the Commission’s 

Administrative Complaint (the “Complaint”): 

STATEMENT OF FACTS PURSUANT TO 16 C.F.R. § 3.12(b)(1)(i) 

The FTC’s complaint reflects fundamental misunderstandings of HomeAdvisor’s business, 

the vast service provider and homeowner networks that HomeAdvisor serves, and the lead 

generation industry generally. Based on a handful of unsubstantiated statements and out-ofcontext anecdotes, the Complaint alleges that since 2014, HomeAdvisor has been intentionally 

misleading hundreds of thousands of service providers regarding the nature and quality of the 

homeowner leads HomeAdvisor provides to its service provider members. While long on 

inflammatory accusations, the Complaint is most notable for what it lacks: any actual evidence of 

(1) systemic misrepresentations in HomeAdvisor’s marketing statements, (2) intent by 

HomeAdvisor and those who operate its business to entice membership through false promises to 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 2 of 53 * PUBLIC *; 

PUBLIC

service providers, (3) actual reliance upon alleged misrepresentations by HomeAdvisor’s service 

provider members, or (4) quantifiable financial gain by HomeAdvisor (or loss to service providers) 

that is tied to any alleged misrepresentations. 

. 

Tellingly, the Complaint ignores entirely the 

 that demonstrates the great value HomeAdvisor’s 

innovative online marketplace has provided to both service providers and homeowners for nearly 

twenty-five years, as well as the substantial filtering, vetting, and other quality-control efforts 

continually undertaken by HomeAdvisor to ensure that legitimate, high-quality leads are the norm 

on its platform and anything else is an exception to be eliminated. While going after HomeAdvisor 

has afforded an over-zealous FTC a big target and a prominent stage from which to tout its 

purported efforts to protect “small businesspeople” and “gig economy” workers, its Complaint 

here is baseless. HomeAdvisor is an honest and established business that provides genuine value 

to both its service professional members and the homeowners who hire them. 

I. HomeAdvisor Established An Innovative On-Line Marketplace Providing Great 

Value To Service Providers And Homeowners 

Formed in 1998, HomeAdvisor (known as ServiceMagic until 2012) addressed (i) the 

historical absence of any centralized means for homeowners to learn about and connect with 

service providers, and (ii) most service providers’ lack of resources to conduct broad, multichannel marketing campaigns to reach homeowners interested in home repair and improvement 

work. HomeAdvisor’s goal was to bridge the gap between homeowners and service providers 

2 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 3 of 53 * PUBLIC *; 

PUBLIC

through a single marketplace where service providers of all types could adve1iise their services 

and homeowners nationwide could locate and connect with local professionals across an aiTay of 

home service tasks. 

Achieving that goal has required extraordinaiy, and continuing, efforts from HomeAdvisor 

throughout its neai·ly 25-year histo1y. HomeAdvisor has invested tens of millions of dollai·s since 

its fonnation to refine continually its lead generation practices and improve the digital mai·ketplace 

for home services-a mai·ketplace that did not exist until HomeAdvisor created it. Online lead 

generation is complex, and even more so here given the two-sided nature of serving both service 

providers and the homeowners who use HomeAdvisor's platfonn to find and connect with them. 

HomeAdvisor's two-sided model drives an inherently balanced structure through which both 

constituencies of its consumer mai·ket (homeowners and service providers) must receive fair value 

for HomeAdvisor to succeed. HomeAdvisor thus has simultaneously sti·ived to cultivate a robust 

and geographically diverse service provider network, while atu-acting consumers seeking home 

services-all while ensuring that both the service providers and consumers can meet each other's 

needs at scale. 

In the last decade alone, HomeAdvisor has connected more than -interested 

consumers with over -service providers across hundreds of home services tasks, from 

handyman work and plumbing to landscaping and full-home remodels. And in just the last yeai·, 

HomeAdvisor's platfo1m supported-service providers across more than-home 

improvement, repair, and maintenance projects-generating billions of dollars in jobs for these 

predominantly small businesses. While the success of its innovative model has fostered 

competition from numerous companies-including household brands like Google, Yelp!, and 

3 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 4 of 53 * PUBLIC *; 

PUBLIC

Amazon—HomeAdvisor remains the industry leader for service providers seeking home services 

leads. 

Of course, trial and error is inherent in innovation. In creating and cultivating this new 

marketplace, HomeAdvisor has since its founding worked to improve the experience of all its 

users, including lead generation for service providers. This has included development of a 

complex lead filtering process designed to flag potentially faulty or illegitimate leads, a generous 

credit policy that has returned hundreds of millions of dollars of value to service providers, a robust 

customer care team dedicated to fielding questions and concerns from service providers, and the 

continued development, optimization, and monitoring of various metrics to track and improve lead 

quality over time. 

Indeed, HomeAdvisor has every reason to enhance service provider satisfaction, because 

its own success is dependent on that of its service providers. Only with a comprehensive and 

successful network of service providers can HomeAdvisor scale its business to serve adequately a 

growing homeowner base. This “flywheel” effect is critical to the success of a two-sided 

marketplace such as the HomeAdvisor platform, and HomeAdvisor could not possibly have 

remained in business for a quarter-century with a strategy of under-serving either of its two core 

constituencies. In short, providing a low-quality lead product to service providers would be 

antithetical to the interests of HomeAdvisor itself. And this is all the more so given that 

HomeAdvisor’s service providers are not a captive audience: they always can choose to enroll 

with one of HomeAdvisor’s competitors or simply forgo online marketplaces; and even after 

enrollment with HomeAdvisor, service providers can pause or terminate their memberships at any 

point if unsatisfied. 

4 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 5 of 53 * PUBLIC *; 

PUBLIC

II. HomeAdvisor Sends Service Providers Leads, Which The Service Providers Must 

Then Convert Into Jobs 

The FTC’s Complaint disregards the fundamental fact—known to service providers as a 

matter of common experience—that leads are not jobs, but instead are opportunities that service 

providers themselves must work to convert into jobs. This means that a service provider’s success 

on the HomeAdvisor platform depends on the service provider’s own efforts to convert the leads 

it receives into jobs. This is particularly important in HomeAdvisor’s transparent lead generation 

model, in which some leads can be provided to up to four service providers—providing 

homeowners with a greater array of choices—with each service provider competing to convert 

that opportunity into a job. Factors influencing service providers’ success in converting leads into 

job include (among others) the service provider’s timeliness in following up with leads, the service 

provider’s communications and rapport with the homeowner after the initial contact, the service 

provider’s reputation and ratings (as reflected in, among other things, reviews that homeowners 

can post on a service provider’s HomeAdvisor profile page, provided as a benefit of membership), 

and the service provider’s pricing. 

Certain service-provider behaviors —including rapid response time and consistent lead 

nurturing—are recognized in the lead generation industry as critical to maximizing lead contact 

and conversion. Service providers that consistently engage in these behaviors are likely to be more 

successful in converting leads to closed sales and increasing their return on investment as 

compared to service providers that do not. Indeed, HomeAdvisor’s internal data shows that about 

50% of jobs are won by the first service provider to contact the homeowner, and that making a 

second call to a homeowner increases by 87% a service provider’s likelihood of connecting with 

that homeowner. HomeAdvisor’s internal market research also shows that service providers with 

a robust profile on the HomeAdvisor platform are contacted by homeowners 60% more often than 

5 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 6 of 53 * PUBLIC *; 

PUBLIC

service providers lacking such a professional profile page. Many service providers derive 

significant and lasting value from their HomeAdvisor memberships as a result of their consistent 

and professional outreach to the leads they receive. It would be unreasonable for any service 

provider to expect it will be able to convert all, or even most, of the leads it receives from 

HomeAdvisor into jobs. But HomeAdvisor’s platform can, and does, result in significant lead 

conversion for those service providers that put in the effort to stand out to the homeowner. And 

HomeAdvisor’s leads are priced such that even converting a relatively small percentage of leads 

into jobs normally results in a positive return on the service provider’s investment in HomeAdvisor 

membership. 

The FTC’s Complaint wholly ignores that HomeAdvisor consistently represents to service 

providers that a “lead” is not a “job,” let alone a guaranteed job, and that any reasonable service 

provider knows it must work to convert a lead into a job and cannot expect to win work from every 

lead. HomeAdvisor emphasizes this fact to prospective service providers, who must listen to, and 

affirmatively confirm their understanding of, the following prompt before they can complete the 

HomeAdvisor enrollment process: “HomeAdvisor provides project leads, not guaranteed jobs. 

You will be billed for each lead that we send to you, and your success will vary depending on 

your abilities to follow up with potential prospects and sell your services.” 

In the same vein, the Complaint does not even address—let alone make any assessment 

of—the efforts individual service providers made (or did not make) to develop work from their 

leads, the particular tasks involved, or the homeowners’ respective needs, wants, likes and dislikes 

regarding the particular project at issue. The Complaint instead alleges, for example, that not all 

HomeAdvisor leads are for homeowners that are ready to hire a service provider “soon.” Compl. 

¶ 6; see also id. ¶ 31 (“Contrary to HomeAdvisor’s representations, many of the leads that 

6 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 7 of 53 * PUBLIC *; 

PUBLIC

HomeAdvisor sells to service providers do not concern people who intend to hire a service provider 

soon.”). But the FTC never defines “soon,” and instead assumes that all consumers across 

hundreds of tasks throughout the United States not only hire a service provider for every task in 

which they have expressed interest, but that they do so on the same timeline. But different tasks 

involve different levels of consideration, planning, and assessment by the homeowner, which can 

impact when an interested homeowner intends to commence any project. For example, leads for 

lower consideration tasks, like gutter cleaning, may require far less lead outreach and nurturing 

than leads for higher consideration tasks, like a full roof replacement. So too for urgent tasks, like 

fixing a leaky pipe, as opposed to long-term high-investment tasks, like a full kitchen remodel. As 

a result, service providers engaged in lower consideration or urgent tasks may close more jobs 

over a shorter period of time than service providers engaged in higher consideration or longer-term 

tasks. Moreover, regardless of task, each homeowner comes with his or her own set of preferences, 

needs, goals, and tastes, as well as his or her own sense of budget and timing, while every service 

provider brings its own set of skills, experiences, and understandings, as well as communication 

style, resources, and pricing. The service provider’s and homeowner’s subjective understandings 

of what factors matter in the process may further vary depending on the specific project, 

geographic locale, or industry at issue. And no matter what the project, homeowners typically are 

considering multiple service providers—including potentially several HomeAdvisor service 

providers and/or service providers found through other marketing channels or personal referrals— 

and thus necessarily are comparing those service providers across an individualized set of metrics 

based on their specific project and preferences. 

The FTC’s Complaint also alleges that HomeAdvisor “sold leads to service providers that 

were submitted by people who were only interested in obtaining prices,” Compl. ¶ 31, but provides 

7 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 8 of 53 * PUBLIC *; 

PUBLIC

no substantiation that this was a widespread or purposeful practice on HomeAdvisor’s part. And, 

of course, a homeowner who has merely expressed interest in a specific project and the desire to 

learn more about pricing is still a prospect for a job. If that homeowner receives a quote from a 

service provider and ultimately chooses not to hire that service provider, the Complaint does not 

explain whether, for example, the homeowner found the service provider’s quote too high and/or 

chose to hire another service provider. The Complaint similarly suggests that certain leads are 

fraudulent because the homeowner may have been interested in winning a “gift card offered 

through a promotion,” id., but again the FTC does not offer any substantiation for its assumption 

that such homeowners are not also legitimately interested in hiring a service provider or rule out 

any of the multiple other reasons why a given service provider might fail to convert such a lead to 

a job. 

III. The Complaint’s Allegations About Task And Geographic Matches Are Misdirected 

The FTC asserts that HomeAdvisor misrepresents to “service providers that the leads they 

will receive concern home services projects that match the type of work and geographic 

preferences that service providers express to HomeAdvisor.” Compl. ¶ 35. Those allegations 

ignore that service providers’ geographic service areas and specific tasks are set and controlled by 

the service providers, and HomeAdvisor matches leads to service providers algorithmically based 

on those self-selected criteria and the information submitted by homeowners. 

Specifically, when a service provider signs up for HomeAdvisor, a HomeAdvisor customer 

service representative conducts an extensive enrollment call with the service provider to address 

HomeAdvisor’s products and services and any questions the service provider may have. During 

the call, the service provider selects the specific tasks and geographic areas it wishes to service. 

These lead criteria and the accompanying lead fees are then displayed in the service provider’s 

online profile settings, which remain accessible to, and adjustable by, the service provider 

8 
-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 9 of 53 * PUBLIC *; 

PUBLIC

throughout its membership. At all times, the service provider is in total control of its HomeAdvisor 

profile criteria, including online through its HomeAdvisor portal pages, without the need even to 

speak to a customer care representative. 

On the homeowner side, HomeAdvisor collects with each service request, at minimum, the 

homeowner’s contact information, zip code, and the specific task selected. When submitting a 

service request, homeowners answer a series of multiple-choice questions about their projects, 

where each subsequent question is generated based on the project category and the response to the 

prior question. There are over 1,500 unique Task IDs that reflect the various permutations of 

homeowners’ answers to questions about their projects. The Task ID is then used to match the 

request to service providers profiled for that task. Consumers also have the opportunity to enter 

their own notes or descriptions of the project, which are visible to HomeAdvisor service providers. 

During this process, homeowners are required to provide their address in response to the question 

“where is your project located?”; and HomeAdvisor uses the zip codes provided by the 

homeowners to match the request to service providers that profiled themselves to perform work in 

that same zip code. The homeowner side of HomeAdvisor’s system does not allow a homeowner 

to submit a service request without entering a valid zip code. 

Service providers do on occasion incorrectly set up their HomeAdvisor profiles. For 

example, a service provider may wish to perform roof repairs and installations for metal roofs only, 

but mistakenly might include asphalt roofs as well in its profile. HomeAdvisor’s customer care 

records 

. Given this tendency, HomeAdvisor 

9 
 

■ 

-

-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 10 of 53 * PUBLIC *; 

PUBLIC

In addition, 

. 

Homeowners 

. 

In reality, HomeAdvisor makes great efforts to provide service providers with leads that fit 

their profile criteria, and HomeAdvisor grants credit requests for leads that do not. In fact, during 

the time period in question, HomeAdvisor generated of leads transmitted to 

service providers, and resulted in a credit request based on a task or location 

mismatch. HomeAdvisor’s commitment to matching service providers with the tasks and zip 

codes they choose is confirmed by the fact that during the period from July 2014 to September 

2019, HomeAdvisor did not send to service providers roughly of the homeowner service 

requests that were generated on HomeAdvisor’s platform—translating to of forgone 

10 
 

-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 11 of 53 * PUBLIC *; 

PUBLIC

potential gross lead revenue—because HomeAdvisor did not have service providers in its network 

who matched exactly with the task type and geographic area of the service requests. That is hardly 

the mark of a company that, as the FTC would have it, knowingly traffics in bad leads. 

IV. The Complaint’s Allegations About Leads Generated By Affiliates Are Conclusory 

And Unsupported 

The FTC also has no legitimate basis for claiming that HomeAdvisor failed to disclose that 

.” Compl. ¶ 45. While 

the FTC uses vague—and unsubstantiated—words like 

.” Compl. ¶ 43. 

. Nor are the FTC’s claims supported by 

any other materials cited in the Complaint—such as internal sales materials that merely state: 

“ 

In fact, HomeAdvisor’s use of affiliates to generate leads is no secret: HomeAdvisor 

publicly advertises its affiliate program on its website.1

 At the same time, approximately of 

the leads transmitted to service providers are, in any event, from homeowners who came directly 

to HomeAdvisor to submit their service requests. 

See HomeAdvisor Affiliate Program, https://www.homeadvisor.com/affiliate/signup 

(“HomeAdvisor’s industry-leading partner program offers aggressive payouts for qualified leads 

or calls.”). 

11 

1 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 12 of 53 * PUBLIC *; 

PUBLIC

The Complaint's allegations also rest on a false distinction between affiliate-generated 

leads and those generated directly through HomeAdvisor. The Complaint cites no evidence to 

suppo1t the claim that affiliate leads are of uniformly lower quality than those generated through 

HomeAdvisor. Nor does the Complaint offer any basis to conclude that service providers were 

haimed if they received affiliate leads. To the contraiy, the Complaint ignores the contractual and 

other controls that HomeAdvisor employs to ensure the quality of all leads from affiliates, 

including: 

I 

I 

I 

I 

I 

I 

12 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 13 of 53 * PUBLIC *; 

PUBLIC

I 

I 

I 

I 

HomeAdvisor's relationship with its affiliates fmihe1more is constantly evolving to 

provide HomeAdvisor with even deeper insight into its affiliates' business practices, -

13 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 14 of 53 * PUBLIC *; 

PUBLIC

-

Notably, the Complaint contains not a single reference to any service provider who claimed 

to be misled regarding HomeAdvisor's use of affiliates, no mention of HomeAdvisor's lead 

management and quality contrnl processes, and certainly no evidence that those processes have 

failed to increase and maintain the quality of affiliate leads. 

14 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 15 of 53 * PUBLIC *; 

PUBLIC

V. The Complaint Disregards HomeAdvisor's Extensive Lead Filtering Process 

Once HomeAdvisor captures service request infonnation, whether from an affiliate or its 

own platfo1m, HomeAdvisor then puts the request through its filter processes designed to target 

and weed out potentially illegitimate requests. 

15 
 -

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 16 of 53 * PUBLIC *; 

PUBLIC

VI. The Complaint Mischaracterizes Representations About “Win Rates” 

See Compl. ¶¶ 48–53. 

 HomeAdvisor’s Opportunity Leads require a dual opt-in process before being matched to a 

service provider. That is, both the homeowner and the service provider must affirmatively opt in 

before the match may occur. 

16 

3
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 17 of 53 * PUBLIC *; 

PUBLIC

17 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 18 of 53 * PUBLIC *; 

PUBLIC

VII. The Complaint Disregards Services Providers’ Return On Investment 

The Complaint inexcusably fails even to consider the significant value and return on 

investment service providers obtain if they convert even only a relatively small percentage of leads 

received from HomeAdvisor into jobs. As discussed above, leads are opportunities to develop and 

potentially close a sale, and the success rate for doing so depends on, among other things, the 

service provider’s own efforts in contacting the homeowner and nurturing the lead. This is distinct 

from most consumer transactions where the buyer is unilaterally paying for a specific end product 

or service. As also noted above, HomeAdvisor emphasizes this fact to prospective service 

providers, who must listen to, and affirmatively indicate their understanding of, the following 

prompt before they can complete the HomeAdvisor enrollment process: “HomeAdvisor provides 

project leads, not guaranteed jobs. You will be billed for each lead that we send to you, and your 

success will vary depending on your abilities to follow up with potential prospects and sell your 

services.” 

The raw percentage of leads converted to sales accordingly must be considered in context 

with the understanding that not all leads—and indeed often a comparatively small percentage— 

will convert to paying work. Win rates of approximately 10–20% might appear low to some. But 

18 
 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 19 of 53 * PUBLIC *; 

5 

PUBLIC

by industry standards for online lead generators, those rates meet or exceed reasonable 

expectations.5

 That is because it is widely understood in the industry—by both sellers and buyers 

of leads—that the value proposition of lead generation is not wins or losses on a lead-by-lead basis; 

rather, it is a service provider’s overall return on its investment in that lead generation service. 

The pricing of HomeAdvisor’s leads takes all this into account, seeking to ensure that 

service professionals can convert even a low percentage of the leads they receive from 

HomeAdvisor into jobs and still earn a positive return on their investment in HomeAdvisor 

membership and lead fees. HomeAdvisor prices its leads based primarily on the type of task and 

the location of the service request, and its pricing model accounts for, among other things, 

competition among service providers to win work from homeowners in that area for that task, the 

possibility that homeowners might hire a service provider unaffiliated with HomeAdvisor, and the 

possibility of a homeowner ultimately changing his or her mind and choosing not to pursue a 

previously expressed interest in a service. Generally speaking, higher consideration tasks (e.g., a 

full home remodel) result in a more expensive lead, while lower consideration tasks (e.g., a 

cleaning service) are priced lower. Pricing with the potential job value in mind is significant, as 

See, e.g., Evan Bailyn, B2B SaaS Funnel Conversion Benchmarks, (listing conversion rates 

from the top of the sales funnel to closed sale at between 0.7% to 2.3% across several industries 

and lead sources) https://firstpagesage.com/seo-blog/b2b-saas-funnel-conversion-benchmarks-fc/; 

Marketing Insider Group, Are Your Lead Conversion Rates Above Average? (showing a 3.3% 

median conversion rate in the home services industry, with 14.9% being the “[b]est”) 

https://marketinginsidergroup.com/demand-generation/are-your-lead-conversion-ratesaboveaverage/; MarketingSherpa, Case Study: Lead Generation Confessions: 17 B2C and B2B 

marketers in 12 different industries share their lead conversion rates, (reflecting 17 companies’ 

conversion rates across industries, including Loftera’s (a company similar to HomeAdvisor) with 

a top of sales funnel lead-to-customer conversion rate of 5% and a “marketing-qualified leads 

convert at 7.2%”) https://www.marketingsherpa.com/article/case-study/B2B-B2Cleadgeneration-conversion-rates; G. David Dodd, B2B Marketing Directions (2014) 

http://b2bmarketingdirections.blogspot.com/2014/09/diagnosing-performance-of-yourdemand.html. 

19 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 20 of 53 * PUBLIC *; 

PUBLIC

cost-per-lead compared to average sales price impacts a service provider’s return on investment. 

Given the FTC’s purported focus on harm to service providers from leads it somehow considers 

to be substandard, the Complaint’s complete failure to reckon with the core measure of return on 

investment is striking. 

Moreover, the direct return-on-investment attributable to won leads does not capture all the 

potential value HomeAdvisor membership affords. A service provider’s return on investment also 

can include longer-term income, when the service provider (1) offers the homeowner repeat or 

related services; (2) obtains referrals from the homeowner; or (3) receives positive online 

recommendations and reviews from the homeowner. Of course, the likelihood of generating repeat 

or related work, referrals, and online recommendations depends largely on the particular 

homeowner’s satisfaction with the work initially performed and the entire customer experience. 

But service providers that diligently pursue and succeed with HomeAdvisor leads can unlock 

tremendous value far beyond the initial sale through post-sale follow-up and communication. 

VIII. HomeAdvisor Stopped Offering mHelpDesk Over Two Years Ago 

The FTC’s claim regarding the mHelpDesk product is likewise exaggerated and 

unsupported. See Compl. ¶¶ 54–60. HomeAdvisor stopped selling mHelpDesk in January 2020, 

and the FTC offers no basis to suggest that the product could be reinstated. Accordingly, there 

can be no ongoing and actionable violation of the FTC Act attributable to any representations about 

mHelpDesk. In any event, the statements about mHelpDesk referenced in the Complaint, id. ¶ 55, 

were not encouraged or condoned by HomeAdvisor or its management, and they contradict 

HomeAdvisor’s training materials. Indeed, all of these statements were contemporaneously 

flagged by HomeAdvisor’s quality assurance team as a “coaching opportunity” for the manager to 

address with the sales representative and/or resulted in a deduction from the sales representative’s 

overall quality assurance score for the call at issue. 

20 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 21 of 53 * PUBLIC *; 

PUBLIC

VIII. Other Legal Flaws in the FTC Complaint 

The FTC’s Complaint and associated claim for monetary relief also fail to exclude leads 

sold by HomeAdvisor to service providers located in Canada through its Canadian subsidiary. The 

FTC lacks jurisdiction over such transactions because they are not “likely to cause reasonably 

foreseeable injury within the United States” and do not “involve material conduct occurring within 

the United States.” 45 U.S.C. § 45(a)(4)(A). 

In addition, while the Complaint purports to cover the period from 2014 to the present, any 

claims arising out of conduct prior to August 2, 2016 are time-barred under the three-year statute 

of limitations applicable to Section 19 of the FTC Act, 15 U.S.C. § 57b(d), which was tolled as 

of August 2, 2019 pursuant to a tolling agreement between HomeAdvisor and the FTC. 

. 

21 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 22 of 53 * PUBLIC *; 

PUBLIC

* * * * * 

The FTC’s Complaint is predicated on the false notion that the hundreds of thousands of 

service providers who enrolled in, utilized and gained great value from HomeAdvisor’s innovative 

online marketplace since 2014 were knowingly misled, unwittingly duped, and thereby harmed. 

But the Complaint is as shockingly sparse in supporting factual allegations as it is long on 

unsubstantiated and irresponsible (and agenda-influenced) assertions. In fact, the actual evidence 

is directly contrary and will show that HomeAdvisor is a legitimate and innovative company that 

provides significant value to the homeowners and service providers who have kept coming back 

to HomeAdvisor because they recognize and want the benefits HomeAdvisor provides. 

RESPONSES TO THE SPECIFIC ALLEGATIONS OF THE COMPLAINT 

1. Respondent HomeAdvisor, Inc. (“HomeAdvisor”), also doing business as Angi Leads, also 

doing business as HomeAdvisor Powered by Angi, is a Delaware corporation with its principal 

offices or places of business at 3601 Walnut Street, Denver, Colorado 80205 and 14023 Denver 

West Parkway, Golden, Colorado 80401. 

RESPONSE TO ¶ 1: 

HomeAdvisor admits that HomeAdvisor is a Delaware corporation with its principal 

offices or place of business at 3601 Walnut Street, Denver, Colorado 80205. In March 2021, 

the HomeAdvisor business became known as HomeAdvisor, powered by Angi, which is also 

known as Angi Leads. 

2. HomeAdvisor has marketed, advertised, offered for sale, and sold products to home service 

providers, including leads, HomeAdvisor memberships, and mHelpDesk. 

RESPONSE TO ¶ 2: 

HomeAdvisor denies the allegations in this paragraph to the extent that as of in or 

around January 2020, HomeAdvisor ceased selling the mHelpDesk product. HomeAdvisor 

otherwise admits the allegations in this paragraph. 

3. The acts and practices of HomeAdvisor alleged in this complaint have been in or affecting 

commerce, as commerce is defined in Section 4 of the Federal Trade Commission Act. 

22 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 23 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO, 3: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

4. HomeAdvisor collects info1mation about potential customers for home services like

kitchen remodels or lawn care, and sells that info1mation to service providers in its network, such

as general contractors and gardeners, as leads.

RESPONSE TO, 4: 

HomeAdvisor denies the allegations in this paragraph, except to admit that it collects 

information about potential customers-not guaranteed customers-in the form of service 

requests, and that it sells that information to service providers in its network in the form of 

leads. 

5. HomeAdvisor recmits service providers, primarily small businesses, through marketing

materials and-sales agents who call service providers and attempt to persuade them to

join HomeAdv1sor's network. To join HomeAdvisor's network, a service provider pays an annual

-·

membership fee of $287 .99 in addition to paying for each lead, which can range from�

RESPONSE TO, 5: 

HomeAdvisor denies the allegations in the first sentence of this paragraph, except to 

admit that (i) marketing materials and HomeAdvisor sales agents' calls to prospective 

service providers have been two of the ways-among many others, including nonHomeAdvisor sources-in which service providers can learn about HomeAdvisor's network, 

and (ii) the majority of service providers in HomeAdvisor's network are small businesses 

and local proprietorships. HomeAdvisor further denies the allegations in the first sentence 

of this paragraph to the extent that it purports to set forth all the information that service 

providers rely on in choosing to join-or not to join-HomeAdvisor's network. 

HomeAdvisor denies the allegations in the second sentence of this paragraph, except to admit 

that it has made different types of memberships available, and that some of these 

memberships cost $287.99 annually. To the extent a further response is required, 

HomeAdvisor denies the allegations in this paragraph. 

6. Since at least July 2014, HomeAdvisor, through its sales agents and marketing materials,

has made representations to service providers about the quality, characteristics, and source of

HomeAdvisor's leads that are false, misleading, or unsubstantiated. HomeAdvisor represents that

its leads concern people who intend to hire a service provider soon, even though many of them do

not. HomeAdvisor represents that service providers will only receive leads that match the types of

services they provide and their geographic preferences, even though many service providers

receive leads that do not match the types of services they provide or their geographic preferences.

HomeAdvisor represents that its leads concern people who knowingly sought its assistance in

selecting a service provider, even though many of the leads HomeAdvisor sells are purchased from

third parties who collect infonnation from potential customers without first revealing their

23 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 24 of 53 * PUBLIC *; 

PUBLIC

affiliation with HomeAdvisor. In addition, HomeAdvisor represents to service providers that its 

leads convert into jobs at rates well above what HomeAdvisor can substantiate. 

RESPONSE TO ¶ 6: 

HomeAdvisor denies the allegations in this paragraph. 

7. Since at least 2015, HomeAdvisor’s sales agents have also misrepresented the cost of an 

optional one-month subscription to a field service software, mHelpDesk, which assists service 

providers with tasks like scheduling appointments and processing payments. Whereas 

HomeAdvisor has represented to service providers that the first month of the mHelpDesk 

subscription is free with an annual membership, in fact, the first month of the subscription 

increases the cost of the annual membership by $59.99. 

RESPONSE TO ¶ 7: 

HomeAdvisor denies the allegations in this paragraph, except to admit that 

mHelpDesk is a software that assists service providers with certain tasks, including but not 

limited to scheduling appointments and processing payments. HomeAdvisor further denies 

the allegations in this paragraph to the extent they are inconsistent with the fact that 

HomeAdvisor ceased selling mHelpDesk in or around January 2020. 

8. Based on HomeAdvisor’s false, misleading, or unsubstantiated representations about the 

quality, characteristics, and source of HomeAdvisor’s leads and the rates at which those leads 

convert into jobs, service providers agree to join Home Advisor’s network, paying an upfront (and 

often inflated) membership fee, followed by additional fees for each lead they receive. Service 

providers, already busy with the demands of running small businesses, expend precious time 

following up on leads that are not of the quality HomeAdvisor promises, and still more time 

seeking, often unsuccessfully, credits and refunds from HomeAdvisor for such leads. 

RESPONSE TO ¶ 8: 

The first sentence of this paragraph sets forth legal conclusions to which no response 

is required, including assertions that HomeAdvisor’s representations were false, misleading 

or unsubstantiated. To the extent that a response is required, HomeAdvisor denies the 

allegations. HomeAdvisor denies that the leads it provides are not of the quality 

HomeAdvisor promises, and lacks sufficient information to admit or deny the remaining 

allegations in the second sentence of this paragraph. 

9. Home Advisor’s deceptive practices have caused service providers to suffer millions of 

dollars of injury. 

RESPONSE TO ¶ 9: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

24 
10. Every year, HomeAdvisor sells of leads to service providers in its network. 

the leads that HomeAdvisor sells consist of information submitted by visitors to HomeAdvisor’s I - -

-

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 25 of 53 * PUBLIC *; 

PUBLIC

website, homeadvisor.com. The website’s homepage states: “Find trusted local pros for any home 

project,” and prompts the visitor to answer a series of questions about a project and provide contact 

information. A visitor can also browse a directory of service providers on HomeAdvisor’s website. 

RESPONSE TO ¶ 10: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. HomeAdvisor otherwise admits the 

allegations in this paragraph. 

11. Using the information visitors submit to its website, HomeAdvisor sells a variety of lead 

types to service providers, including “Market Match Leads,” “Exact Match Leads,” and “Instant 

Booking Leads.” 

RESPONSE TO ¶ 11: 

HomeAdvisor denies the allegations in this paragraph to the extent that they omit all 

the processes that HomeAdvisor undertakes to evaluate the information that it receives from 

homeowners in the form of service requests before, potentially, selling that information to 

service providers in the form of leads, such as manual and automated processes that filter 

out certain service requests before they potentially can be sold as leads. HomeAdvisor 

otherwise admits the allegations in this paragraph. 

12. of the leads HomeAdvisor sells to service providers are Market Match Leads. 

HomeAdvisor generates Market Match Leads from its website when a visitor follows the prompts 

and answers several questions about a home project. With the exception of an optional field that 

allows the visitor to provide further details about the project, the questions are multiple choice 

with one answer option often pre-selected by default. Based on a subset of the visitor’s answers, 

HomeAdvisor uses an automated matching system to identify service providers in HomeAdvisor’s 

network to whom HomeAdvisor sends the information provided by the visitor as a lead. 

RESPONSE TO ¶ 12: 

HomeAdvisor admits the first sentence in this paragraph. HomeAdvisor denies the 

allegations in the remaining allegations in this paragraph, which fail to mention, among other 

things, (i) all the information that a homeowner must provide before he or she can submit a 

service request, and (ii) all the processes that HomeAdvisor undertakes to evaluate a service 

request before, potentially, selling that information to service providers in the form of leads, 

such as manual and automated processes that filter out certain service requests before they 

potentially can be sold as leads. 

13. HomeAdvisor generates Exact Match and Instant Booking Leads from visitors who browse 

the directory of service providers on HomeAdvisor’s website. The directory consists of service 

provider listings that include a description of each service provider’s work and reviews. Many 

service provider listings also include an appointment calendar. HomeAdvisor generates an Exact 

25 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 26 of 53 * PUBLIC *; 

PUBLIC

Match Lead when a visitor selects a specific service provider from the directo1y and submits 

project and contact infonnation directly to that service provider. HomeAdvisor generates an Instant 

Booking Lead when a visitor makes an appointment with a s ecific service provider via a webbased application on the directo1y. Approximately of the leads HomeAdvisor sells to 

service providers are Exact Match Leads and approximately are Instant Booking Leads. 

RESPONSE TO' 13: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. 

HomeAdvisor denies the allegations in the second and third sentences of this paragraph, 

except to admit that the Pro Directory contains a description of service providers' work and 

reviews, among other things (many of which service providers themselves decide whether to 

include), and that the service provider can elect to include an appointment calendar. 

HomeAdvisor admits the allegations in the fourth and fifth sentences of this paragraph. 

HomeAdvisor admits that HomeAdvisor's corporate witness testified that as of mid- to late 

2020, of the leads HomeAdvisor sold to service providers were Exact 

Match leads and were Instant Booking Leads. 

14. In addition to selling leads to service providers enerated from visitors' interactions · ·' with Home ite HomeAdvisor has reso ofleads that it has pmchased from 

from web-based fonns 

RESPONSE TO' 14: 

HomeAdvisor denies the allegations in this paragraph, because they allege that 

HomeAdvisor purchased "leads" from affiliates, when in fact HomeAdvisor purchased 

service requests which were then subject to further review by HomeAdvisor before 

potentially being sold as leads to service providers. HomeAdvisor admits that certain 

affiliate-generated service requests come from websites that do not identify any afflliation 

with HomeAdvisor. 

15. HomeAdvisor also sells leads to service providers that are generated when HomeAdvisor

customer representatives input infonnation provided over the hone b otential customers of

home services. HomeAdvisor's tele hone- enerated leads

26 
H Ad. d I I I th 11 ti th fi t t f th· ht th - -

I 

I I 

HomeAdvisor denies the allegations in the third 

and fourth sentences of this paragraph. HomeAdvisor denies the alle ations in the fiftll 

sentence of this ara ra h to the extent 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 27 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO, 15: 

HomeAdvisor admits the allegations in this paragraph. 

RESPONSE TO, 16: 

HomeAdvisor denies the allegations in the second sentence of this paragraph. 

HomeAdvisor denies the alle ations in the third fourth and fifth sentences of this 

RESPONSE TO, 17: 

18. In order to receive leads from HomeAdvisor, service providers must first pass a

background check and join HomeAdvisor's network by pm-chasing a membership. HomeAdvisor

27 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 28 of 53 * PUBLIC *; 

PUBLIC

regularly sold a membership package for $347.98 that included a one-month subscription to

mHelpDesk, a field service software produced by a subsidia1y of HomeAdvisor. After the first

month, the mHelpDesk subscription automatically renewed at $59.99 per month unless service

providers cancelled it. 

RESPONSE TO' 18: 

HomeAdvisor denies the allegations in the first sentence of this paragraph, except 

admits that service providers cannot be accepted into HomeAdvisor's network or receive 

leads from HomeAdvisor without having passed a background check. HomeAdvisor denies 

the allegations in the second sentence of this paragraph, except admits that HomeAdvisor 

has made different types of memberships available, including a membership package (that 

HomeAdvisor has not sold since on or about January 2020) that included a one-month 

subscription to mHelpDesk. HomeAdvisor denies the allegations in the third sentence of this 

paragraph, except with respect to those service providers that purchased a membership that 

included mHelpDesk. 

19. Upon purchasing a HomeAdvisor membership, service providers receive leads, including

Market Match, Exact Match and Instant Booking Leads. The price of a Market Match Lead ranges

from approximately • to ti, depending on the type of home project it concerns (e.g., a kitchen

remodel will typicallybe pncecl higher than house cleaning), and the geographic location of the

project. Exact Match and Instant Booking Leads cost fifty percent more than Market Match Leads

of the same p ect type and location. The average price of a lead, across lead types, is

approximately tll . 

RESPONSE TO' 19: 

HomeAdvisor denies the allegations in the first sentence of this paragraph, except 

admits that Market Match, Exact Match, and Instant Booking are types of leads that service 

providers can receive. HomeAdvisor denies the allegations in the second sentence of this 

paragraph, except admits that lead fees vary depending on the type of project and the 

geographic location of the project. HomeAdvisor admits the allegations in the third sentence 

of this paragraph, noting that the range of potential lead fees varies from service provider to 

service provider. HomeAdvisor admits the allegations in the fourth sentence of this 

paragraph, but only with respect to the time period of July 2014 through September 2019. 

HomeAdvisor denies the allegations in the fourth sentence of this paragraph with respect to 

the time periods before July 2014 and after September 2019. 

20. Service providers pay HomeAdvisor for each Market Match, Exact Match, or Instant

Booking Lead they receive. Service providers limit the number of Market Match and Exact Match . . . . L d th b tt' • I I t thl 1 d b d! t th . H Ad t 

HomeAdvisor also allows a service provider to "pause" receiving Market Match, Exact Match,

and Instant Booking Leads for a limited time, after which the leads will automatically resume. 

28 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 29 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO' 20: 

HomeAdvisor denies the allegations in the first sentence of this paragraph, except 

admits that under certain membership types, service providers pay for each lead they receive 

(though they also may receive lead credits for a variety of reasons). HomeAdvisor denies the 

allegations in the second sentence of this paragraph to the extent that they purport to state 

all the ways that a service provider can limit the number of leads it receives per month or 

otherwise. HomeAdvisor denies the allegations in the third sentence of this paragraph to the 

extent that they fail to articulate fully the nature of the spend target system that 

HomeAdvisor uses with service providers. HomeAdvisor denies the allegations in the fourth 

sentence of this paragraph, except admits that service providers can pause their leads. 

21. HomeAdvisor does not allow service providers to preview leads prior to receiving them. If

a service provider is dissatisfied with a lead she receives from HomeAdvisor, her primaiy recourse

is to request a credit to her HomeAdvisor account for the cost of the lead in question. If

HomeAdvisor grants the credit request, HomeAdvisor then applies the credit against the cost of

future leads. HomeAdvisor does not generally provide refunds for leads.

RESPONSE TO' 21: 

HomeAdvisor denies the allegations in the first sentence of this paragraph to the 

extent that they allege that service providers cannot preview the leads services that 

HomeAdvisor offers, and admits only that Market Match and Exact Match leads are 

automatically accepted based upon the tasks and geographic service areas set up on the 

service provider's profile, which the service provider selects and can adjust on its own 

throughout its membership. HomeAdvisor lacks sufficient information to admit or deny the 

allegations in the second sentence of this paragraph, including because the sentence does not 

identify the reason for which the service provider is dissatisfied. HomeAdvisor admits the 

allegations in the third sentence of this paragraph. HomeAdvisor denies the allegations in 

the fourth sentence of this paragraph because they suggest that HomeAdvisor does not 

provide refunds for leads. 

22. Service providers can submit lead credit requests by speaking with a HomeAdvisor

customer service representative who submits the credit request on the service provider's behalf.

Service providers can also submit lead credit requests online via their HomeAdvisor account. To

submit a lead credit request, a service provider must provide the reason the service provider thinks

a credit is appropriate. HomeAdvisor grants lead credit requests at its discretion based on a vai·iety

of factors, including the service rovider's stated reason whether HomeAdvisor is able to veri

the reason rovided b

.SinceJ� lead credit requests, approximately -

RESPONSE TO' 22: 

HomeAdvisor admits the allegations in the first and second sentences of this 

paragraph. HomeAdvisor denies the allegations in the third and fourth sentences of this 

29 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 30 of 53 * PUBLIC *; 

PUBLIC

paragraph. HomeAdvisor admits the alle ations in the fifth sentence of this paragraph only 

with resp�eriod of and notes that it granted a 

majority -) of lead credit requests in that period. 

23. HomeAdvisor employs -of sales agents who call service providers around the

count:Iy and attempt to persuade them to join HomeAdvisor's network. A service provider can only

join HomeAdvisor's network by speaking to a HomeAdvisor representative over the phone.

RESPONSE TO, 23: 

HomeAdvisor admits the allegations in the first sentence of this paragraph, except 

that HomeAdvisor denies those allegations to the extent that they purport to describe the 

sole purpose or goal of HomeAdvisor's sales agents, or the ways in which sales agents go 

about performing their jobs, which necessarily vary agent to agent, service provider to 

service provider, and outreach to outreach. HomeAdvisor admits the allegations in the 

second sentence of this paragraph. 

24. In their sales 

make 

calls with 

false, 

service 

misleading, 

providers, 

or unsubstantiated 

many of HomeAdvisor's 

representations 

sales 

about 

agents

the� 

,_

characteristics, and source ofHomeAdvisor's leads and the rates at which those leads convert into 

jobs. 

RESPONSE TO, 24: 

HomeAdvisor denies the allegations in this paragraph. 

25. In numerous instances, HomeAdvisor's sales agents have represented to service providers

that HomeAdvisor's leads concern people who intend to hire a service provider soon. For example,

in sales calls HomeAdvisor's sales agents have described the leads as follows:

30 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 31 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO' 25: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references call recordings, the recordings speak for themselves 

and are the best evidence of the contents of those specific calls, which represent just a few 

statements-divorced from their context-taken from a small sample of the many thousands 

of sales calls that HomeAdvisor sales agents conducted during the time period of July 2014 

to the present. HomeAdvisor further denies that any of these statements is exemplary. 

li

26. Indeed, HomeAdvisor has rovided its sales a ents with a list of marketin

ed for use in sales calls that

and' 

RESPONSE TO' 26: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. While HomeAdvisor admits that the 

quoted statements in this paragraph were among statements that were provided to sales 

agents, HomeAdvisor denies any implication that these statements are inaccurate or 

misleading or represent the complete information that was provided to the sales agents. 

27. HomeAdvisor's external marketing materials make similar representations. On its website,

HomeAdvisor prominently displays a "How It Works" video for service providers that states,

"With HomeAdvisor's patented ProFinder technology, you're only matching to serious

homeowners in your area."

RESPONSE TO' 27: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor otherwise denies the allegations this paragraph, and admits only 

that the video referenced in the second sentence of this paragraph includes, among other 

things, the language quoted in that sentence. 

28. Another po1iion of its website represents to service providers: "When you're a [ member of

HomeAdvisor's service provider network], HomeAdvisor matches you with homeowners actively

seeking the services you provide in your area."

, How will I h.-n,-fit from Hom.-Ac1111•.or Pro m.-mh.-r•,hip"' 

When you're a HomeAdv,sor Pro member. HomeAdvisor matches you with homeowners actively seeking the services you 

provide In your area - making ,t easier than ever to connect With new customers and win more 1obs. You11 also get a list1ng m 

our online directory, a business profile page on our website, access to helpful business management and marketing tools, and 

qualified new business opportunities (Pro Leads) to keep your pipeline full. 

Illustration 1: available at https://pro.homeadvisor.com/rlmembership/#membership (last visited August 9, 2021) 

31 
Benefits of Joining 

Can Ang i Leads increase a service professional's profits? 

Absolutely. You wont have lo waste your time with customers who jusl window-shop. Angi Leads allows you to spend your time with Ille righl · ready-lo-buy" customers We do 

nm hPc::I In f11llv 10rl11r;:ifp r ri~tnmi::ir<:: ~hnut lhP c::rnnP rnc:t ::mrl fiminn ni thPir nrniPM<:: ThPn w P'n m::iitrh th.Pm ,uith vn11 h~~Prl nn vn11r nrPfPrP-nrJ:i,:;, fnr inh tvnP ;:in rl lnr~tinn 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 32 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO ¶ 28: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor admits that the quoted language has appeared on HomeAdvisor’s 

website. 

29. Yet another page on HomeAdvisor’s website states, “You won’t have to waste your time 

with customers who just window-shop. Angi Leads allows you to spend your time with the right 

‘ready-to-buy’ customers.” 

Illustration 2: available at https://pro.homeadvisor.com/help/faqs/ (last visited August 9, 2021) 

RESPONSE TO ¶ 29: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor admits that the quoted language has appeared on HomeAdvisor’s 

website. 

30. Other marketing materials describe HomeAdvisor’s leads as “project requests” and 

advertise HomeAdvisor as a means for service providers to “connect with project-ready 

homeowners.” 

32 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 33 of 53 * PUBLIC *; 

PUBLIC

Illustration 3: email mark.eting sent to prospective sen1ice provider members 

RESPONSE TO, 30: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor admits the allegations in this paragraph. 

31. Contraiy to HomeAdvisor' s representations, many of the leads that HomeAdvisor sells to

service roviders do not concern eo le who intend to hire a service rovider soon.

RESPONSE TO, 31: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. 

HomeAdvisor lacks sufficient information to admit or deny the remaining allegations in this 

paragraph. 

32. Indeed, HomeAdvisor sells infonnation to service providers as leads even when internet

users affinnatively indicate that they do not intend to hire a service provider soon. For exainple,

one of the questions that a user typically must answer about a home project is whether its status is

"Ready to Hire" or only "Planning & Budgeting." Similarly, another question that a visitor

typically must answer is how soon they would like the project completed (e.g., "Timing is

flexible," "Within 1 week," "1-2 weeks," or "More than 2 weeks"). Yet another uestion asks

whether the internet user is "the owner or authorized to make ro e1 chan es."

RESPONSE TO, 32: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. 

HomeAdvisor admits the allegations in the second, third, and fourth sentences of this 

paragraph. HomeAdvisor denies the allegations in the fifth sentence of this ara ra h 

exce t to admit that the answers to these uestions are not determinative of 

33 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 34 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO, 33: 

HomeAdvisor denies the allegations in this paragraph. 

RESPONSE TO, 34: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references documents, the documents speak for themselves and 

are the best evidence of their contents. To the extent a further response is required, 

HomeAdvisor denies the allegations in the second sentence of this paragraph to the extent 

they mischaracterize the document. 

35. In numerous instances, HomeAdvisor's sales agents have told service providers that the

leads they will receive concern home services projects that match the type of work and geographic

preferences that service providers express to HomeAdvisor. For example, in sales calls

HomeAdvisor's sales agents have described the leads as follows:

RESPONSE TO, 35: 

HomeAdvisor admits the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references call recordings, the recordings speak for themselves 

and are the best evidence of the contents of those specific calls, which represent just a few 

statements-divorced from their context-taken from a small sample of the many thousands 

of sales calls that HomeAdvisor sales agents conducted during the time period of July 2014 

to September 2019. To the extent a further response is required, HomeAdvisor lacks 

34 
- SgnllpTod41y 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 35 of 53 * PUBLIC *; 

PUBLIC

sufficient information to admit or deny the allegations in this paragraph. HomeAdvisor 

further denies that any of these statements is exemplary. 

36. Indeed, scripts used by HomeAdvisor sales agents describe HomeAdvisor's leads as

follows:

( emphasis original) 

RESPONSE TO' 36: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor denies the allegations in this paragraph to the extent that the 

documents were not used in the manner alleged, including but not limited to whether they 

were to be read verbatim by sales agents across thousands of calls with thousands of different 

business owners in hundreds of different home-services industries. 

37. HomeAdvisor's marketing materials make similar representations. Its website states,

"Tell us what you do and where, and we deliver prospects that meet your exact needs."

Helping You Grow Your Business 

One Homeowner at a Time 

Le.amMo,11 t 

Illustration 4: available at https://pro.homeadvisor.com/ (last visited August 9, 2021) 

RESPONSE TO' 37: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

35 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 36 of 53 * PUBLIC *; 

PUBLIC

required, HomeAdvisor denies the allegations in this paragraph, admitting only that the 

webpage referenced includes language quoted in the second sentence of this paragraph. 

38. Another page on its website has stated, "Only Get the Leads You Want. You pick your

service types and location preferences and we bring you prospects that match what you want."

You're In Control 

Only Get the

Leads You Want 

You pick your servtce types and Joca on 

preferences and we bring you pcospects that 

match \vhBt you wanL 

Illustration 5: previously available at https:llpro.homeadvisor.com/how-it-worksl 

RESPONSE TO' 38: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. HomeAdvisor admits the allegations 

in this paragraph to the extent the quoted statement ever appeared on HomeAdvisor's 

website, but HomeAdvisor notes that this language does not appear on HomeAdvisor's 

website at this time. 

39. In fact, contnuy to HomeAdvisor's representations, many of the leads that se1vice · · providers receive do not concern the t e of work that the se1vice r

RESPONSE TO' 39: 

HomeAdvisor denies the allegations in the first and fourth sentences of this 

paragraph. HomeAdvisor lacks sufficient information to admit or deny the allegations in 

36 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 37 of 53 * PUBLIC *; 

PUBLIC

the second and third sentences of this paragraph. HomeAdvisor further denies that any of 

these alleged situations is exemplary. 

RESPONSE TO, 40: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. 

HomeAdvisor denies the alle ations in the second sentence of this ara 

that 

RESPONSE TO, 41: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references documents, the documents speak for themselves and 

are the best evidence of their contents. To the extent a further response is required, 

HomeAdvisor denies the allegations in the second sentence of this paragraph to the extent 

they mischaracterize the documents. 

42. HomeAdvisor's sales agents also have frequently represented to service providers that

HomeAdvisor's leads concern people who knowingly sought HomeAdvisor's assistance in

selecting a service provider. For example, in sales calls HomeAdvisor's sales agents have

described the somce ofHomeAdvisor's leads as follows:

37 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 38 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO' 42: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references call recordings, the recordings speak for themselves 

and are the best evidence of the contents of those specific calls, which represent just a few 

statements-divorced from their context-taken from a small sample of the many thousands 

of sales calls that HomeAdvisor sales agents conducted during the time period of July 2014 

to September 2019. To the extent a further response is required, HomeAdvisor lacks 

sufficient information to admit or deny the allegations in this paragraph. HomeAdvisor 

further denies that any of these statements is exemplary. 

RESPONSE TO' 43: 

To the extent that this paragraph references documents, the documents speak for 

themselves. To the extent a further response is required, HomeAdvisor admits only that the 

quoted language appears in documents that have been described as scripts. However, this 

does not evidence the nature and extent of the use of these statements, including but not 

limited to whether they were to be read verbatim, or in fact were read verbatim, by sales 

agents across thousands of calls with thousands of different business owners in hundreds of 

different home-services industries. 

44. HomeAdvisor's marketing materials have also represented that HomeAdvisor's leads

concern people who knowingly sought HomeAdvisor's assistance in selecting a service provider.

HomeAdvisor's website has described Market Match Leads as follows: "Consumers come to

HomeAdvisor.com and give us detailed info about their project."

Market Match 

Consumers com to Hom Adv or com nd 

grve us deta d tnto aoout Ute proJect we 

match that fo with your wor1( and area 

pr fercnc and conn Cl you th 

homeowners that m 1Ch your n eds 

Get St..uted 

38 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 39 of 53 * PUBLIC *; 

PUBLIC

Illustration 6: previously available at https:l/ww,v.homeadvisor.com/2islenrolllsppostenro111eadsdetails 

RESPONSE TO' 44: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor admits only that the quoted language has appeared in certain 

materials and further notes that this language does not appear on HomeAdvisor's website at 

this time. 

45. In fact, contraiy to HomeAdvisor's representations,. of the leads that HomeAdvisor

sells to service providers ai·e purchased from affiliates and concern individuals who did not

knowingl�omeAdvisor's assistance. Since July 2014, HomeAdvisor has sold service

providers -of leads that HomeAdvisor urchased from affiliates and did not come from

HomeAdvisor's website.

RESPONSE TO' 45: 

HomeAdvisor denies the allegations in this paragraph, because they allege that 

HomeAdvisor purchased "leads" from affiliates, when in fact HomeAdvisor purchased 

service requests which were then subject to further review by HomeAdvisor before 

potentially being sold as leads to service providers. HomeAdvisor lacks sufficient 

information to admit or deny the allegations in the final sentence of the paragraph. 

, HomeAdvisor recognizes that it has ve1y limited control over the quality of 

affiliate-generated leads. Indeed, a document HomeAdvisor's parent company filed publicly with 

the Securities and Exchange Commission acknowledged that "the quality and convertibility of 

[HomeAdvisor's] leads generated through third-pa1iy aITangements are dependent on many

factors, most of which are outside our control." 

RESPONSE TO' 46: 

HomeAdvisor denies the allegations in the first and second sentences of this 

paragraph. To the extent that this paragraph references documents, the documents speak 

for themselves and are the best evidence of their contents. To the extent a further response 

is required, HomeAdvisor denies the allegations in the third sentence of this paragraph and 

admits only that a document filed with the Securities and Exchange Commission contains 

the quoted language. 

39 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 40 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO, 47: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references documents, the documents speak for themselves and 

are the best evidence of their contents. To the extent a further response is required, 

HomeAdvisor lacks sufficient information to admit or deny the allegations in the remainder 

of this paragraph. HomeAdvisor further denies that any of these statements is exemplary. 

48. In numerous instances, HomeAdvisor's sales agents have represented to service providers

that HomeAdvisor's leads conve1i into jobs at rates well above what HomeAdvisor can

substantiate.

RESPONSE TO, 48: 

HomeAdvisor denies the allegations in this paragraph. 

to HomeAdvisor's own calculations, 

the aver�a lead pm-chased by a service provider 

provider -the "win rate") has ranged between 

since July 2014. 

RESPONSE TO, 49: 

HomeAdvisor denies the allegations in this paragraph and states that a fulsome 

calculation of win rates for HomeAdvisor leads re uires anal zin all leads individuall that 

that win rate data excludes, among other things, additional "wins" resulting from one lead, 

such as regular or repeat jobs or referrals, and that win rates vary across task and 

geographic markets. HomeAdvisor further responds that its average win rates (self40 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 41 of 53 * PUBLIC *; 

PUBLIC

reported by service providers) during the time period from July 2014 to 

September 2019. 

· · · 50. for Market 

as ranged 

between erage wm 

rate for average 

win rate for Instan oo g ea s as range 

RESPONSE TO' 50: 

HomeAdvisor denies that the average win rate for Instant Booking Leads has ranged 

between since Jul 2014. HomeAdvisor does not maintain 

, and thus denies the remaining allegations in this paragraph. 

51. Nonetheless, HomeAdvisor's sales agents have frequently represented falsely inflated win

rates to service providers. For example, in sales calls HomeAdvisor's sales agents have described

the leads as follows:

RESPONSE TO' 51: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references call recordings, the recordings speak for themselves 

and are the best evidence of the contents of those specific calls, which represent just a few 

statements-divorced from their context-taken from a small sample of the many thousands 

of sales calls that HomeAdvisor sales agents conducted during the time period of July 2014 

to September 2019. In that context, HomeAdvisor admits the allegations in the second 

sentence of this paragraph. HomeAdvisor further denies that any of these statements is 

exemplary. 

41 
V v one D 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 42 of 53 * PUBLIC *; 

PUBLIC

RESPONSE TO, 52: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent that a further response 

is required, HomeAdvisor admits only that the language quoted appears in an email between 

those individuals, and that it describes onl one office at onl oint in time. 

HomeAdvisor further notes 

53. HomeAdvisor's

RESPONSE TO, 53: 

54. In numerous instances, HomeAdvisor's sales agents have represented to service providers

that the cost of an annual membership is $347.98, and includes a free one-month subscription to

mHelpDesk.

RESPONSE TO, 54: 

HomeAdvisor denies the allegations in this paragraph, and further notes that as of in 

or around January 2020, HomeAdvisor ceased selling the mHelpDesk product. 

55. For example, in sales calls HomeAdvisor's sales agents have described mHelpDesk as

follows:

42 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 43 of 53 * PUBLIC *; 

43 

PUBLIC

RESPONSE TO, 55: 

HomeAdvisor denies the allegations in this paragraph to the extent that they describe 

any of the statements that follow as exemplary. To the extent that this paragraph references 

call recordings, the recordings speak for themselves and are the best evidence of the contents 

of those specific calls, which represent just a few statements-divorced from their contexttaken from a small sample of the many thousands of sales calls that HomeAdvisor sales 

agents conducted during the time period of July 2014 to September 2019. 

56. Indeed, HomeAdvisor's trnining materials have erpetuated sales agents' re resentations . .

RESPONSE TO, 56: 

HomeAdvisor denies the allegations in the first sentence of this paragraph. To the 

extent that this paragraph references documents, the documents speak for themselves. To 

the extent a further response is required, HomeAdvisor admits only that the quoted language 

appears in documents that have been described as scripts. However, this does not evidence 

the nature and extent of the use of these statements, including but not limited to whether 

they were to be read verbatim, or in fact were read verbatim, by sales agents across 

thousands of calls with thousands of different business owners in hundreds of different homeservices industries. 

57. Similarly, until at least 2016, the fonn email that HomeAdvisor sent service providers

confmning their purchase of an annual membership represented that $347.98 was the cost of the

annual membership and a "free" month of mHelpDesk.

RESPONSE TO, 57: 

To the extent that this paragraph references documents, the documents speak for 

themselves and are the best evidence of their contents. To the extent a further response is 

required, HomeAdvisor admits that at some point in time, certain service providers were 

sent an email consistent with the language in this paragraph, but HomeAdvisor lacks 

sufficient information to admit or deny that such language was used during the entire time 

frame referenced in this paragraph. 

58. In fact, the cost of an annual membership is $287.99. The $347.98 price has represented

the cost of an annual membership plus one month of mHelpDesk, an optional, add-on product that

costs $59.99 per month and automatically renews after the first month. If a service provider does
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 44 of 53 * PUBLIC *; 

PUBLIC

not want a one-month subscription to mHelpDesk, she can pm-chase an annual membership for 

$287.99. 

RESPONSE TO' 58: 

HomeAdvisor denies the allegations in this paragraph, except to admit that 

HomeAdvisor has made different types of memberships available, that some of these 

memberships cost $287.99 annually and that some annual memberships previously sold, but 

that have not been sold since early 2020, included one month of mHelpDesk for a total price 

of $347.98. 

59. After HomeAdvisor' s sales agents have added a month of mHelpDesk to service providers'

annual memberships, service providers frequently have not learned that they were charged an

additional $59.99 because the $347.98 char e has a eared as a sin le line item on the service

RESPONSE TO' 59: 

HomeAdvisor lacks sufficient information to admit or deny the allegations in this 

paragraph, because the alle e what "service roviders frequently have not learned" and 

60. Of the more than-service providers who have been char ed $347.98 for an annual

membershi and a one-m�scription to mHelpDesk,

because the 

RESPONSE TO' 60: 

HomeAdvisor lacks sufficient information to admit or deny the allegations in this 

paragraph. 

Count! 

Misrepresentations About the Quality, Characteristics, and Source of Leads 

61. In numerous instances in connection with the adve1tising, marketing, promotion, offering

for sale, or sale of leads, HomeAdvisor represents to service providers, directly or indirectly,

expressly or by implication, that the leads service providers will receive:

a. concern individuals who intend to hire a service provider soon;

b. concern projects that match the types of services that service providers have

expressed they perfonn;

c. concern projects that match the geographic areas that service providers have

expressed they serve; or

44 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 45 of 53 * PUBLIC *; 

PUBLIC

d. concern individuals who knowingly sought HomeAdvisor for assistance in 

selecting a service provider. 

RESPONSE TO ¶ 61: 

HomeAdvisor denies the allegations in this paragraph (and its subparts) because they 

are incomplete, out of context and/or inaccurate. 

62. In truth and in fact, in numerous instances in which HomeAdvisor has made the 

representations set forth in Paragraph 61, the leads service providers received, respectively: 

a. did not concern individuals who intend to hire a service provider soon; 

b. did not concern projects that match the types of services that service 

providers have expressed they perform; 

c. did not concern projects that match the geographic areas that service 

providers have expressed they serve; or 

d. did not concern individuals who knowingly sought HomeAdvisor for 

assistance in selecting a service provider. 

RESPONSE TO ¶ 62: 

HomeAdvisor denies the allegations in this paragraph (and its subparts). 

63. Therefore, HomeAdvisor’s representations as set forth in Paragraph 61 are false or 

misleading. 

RESPONSE TO ¶ 63: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

Count II 

Misrepresentations About the Rates at which Leads Convert into Jobs 

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

for sale, or sale of leads, HomeAdvisor represents to service providers, directly or indirectly, 

expressly or by implication, that the leads convert into jobs at or above the rates that HomeAdvisor 

states. 

RESPONSE TO ¶ 64: 

HomeAdvisor denies the allegations in this paragraph. 

45 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 46 of 53 * PUBLIC *; 

PUBLIC

65. The representations set forth in Paragraph 64 are false or misleading or were not 

substantiated at the time the representations were made. 

RESPONSE TO ¶ 65: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

Count III 

Misrepresentations Regarding mHelpDesk 

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

for sale, or sale of leads, HomeAdvisor has represented to service providers, directly or indirectly, 

expressly or by implication, that the first month of mHelpDesk is free. 

RESPONSE TO ¶ 66: 

HomeAdvisor denies the allegations in this paragraph, and further states that in or 

around January 2020, HomeAdvisor ceased selling the mHelpDesk product. 

67. In truth and in fact, in numerous instances in which HomeAdvisor has made the 

representations set forth in Paragraph 66, the first month of mHelpDesk is not free. 

RESPONSE TO ¶ 67: 

HomeAdvisor denies the allegations in this paragraph because they are predicated on 

“the representations set forth in Paragraph 66.”. 

68. Therefore, HomeAdvisor’s representations as set forth in Paragraph 66 are false or 

misleading. 

RESPONSE TO ¶ 68: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

Violations of Section 5 

69. The acts and practices of HomeAdvisor as alleged in this complaint constitute unfair or 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act. 

RESPONSE TO ¶ 69: 

This paragraph sets forth legal conclusions to which no response is required. To the 

extent that a response is required, HomeAdvisor denies the allegations. 

46 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 47 of 53 * PUBLIC *; 

PUBLIC

AFFIRMATIVE DEFENSES 

HomeAdvisor asserts the following defenses, without assuming the burden of proof on 

such defenses that would otherwise rest with the FTC. A concise statement of the facts constituting 

each ground of defense is set forth in the Statement of Facts above. 

1. The Complaint fails to state a claim on which relief can be granted. 

2. The FTC’s allegations are too speculative to support any claim on which relief can 

be granted. 

3. The FTC’s claims are barred, in whole or in part, by the three-year statute of 

limitations under Section 19 of the FTC Act, 15 U.S.C. § 57b(d). 

4. The FTC’s claims are moot, in whole or in part, as HomeAdvisor discontinued the 

allegedly unfair and deceptive practices long before the institution of the current proceeding, and 

thus there is no basis for injunctive relief because there is no risk of recurrence of similar alleged 

violations and the FTC’s requested relief is not reasonably related to the alleged violations. 

5. The FTC’s claims under Count III relating to mHelpDesk are moot because 

HomeAdvisor has not sold mHelpDesk since around January 2020, and thus there is no basis for 

injunctive relief because there is no risk of recurrence of similar alleged violations and the FTC’s 

requested relief is not reasonably related to the alleged violations. 

6. The FTC’s claims are barred, in whole or in part, because the claims asserted 

require the improper extraterritorial application of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

7. The FTC’s claims are barred, in whole or in part, because the losses or injuries 

allegedly suffered were not proximately caused by any act or omission of HomeAdvisor. The 

FTC’s claims fail to take into account that a service provider’s success on the HomeAdvisor 

platform depends on, among other things, the service provider’s own efforts to contact, develop, 

and ultimately convert the leads it receives into jobs. Moreover, despite the robust processes it has 

47 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 48 of 53 * PUBLIC *; 

PUBLIC

in place for ensuring lead quality, HomeAdvisor cannot control homeowners’ ultimate behavior 

and preferences, including but not limited to whether a homeowner will hire a HomeAdvisor 

service provider or a service provider made available to the homeowner through any number of 

other available sources, such as personal referrals. 

8. The FTC’s claims are barred, in whole or in part, because HomeAdvisor’s 

competitive acts and/or practices at issue were not unfair, deceptive, or unconscionable under 

applicable law, nor were they likely to confuse or cause mistake or misunderstanding as to the 

nature of HomeAdvisor’s business and/or services. 

9. The FTC’s claims reflect improper selective enforcement of the competition laws. 

10. The FTC’s claims are barred, in whole or in part, by failure to show any plausible 

harm to consumers or consumer welfare or any plausible anticompetitive effect. 

11. The Complaint fails to comply with Section 5(b) of the Federal Trade Commission 

Act, 15 U.S.C. § 45(b), because the issuance of the Administrative Complaint and the 

contemplated relief are not in the public interest. HomeAdvisor has robust compliance processes 

for ensuring that the information it conveys to service providers is accurate and not misleading, 

and has a multi-layered process for ensuring lead quality. 

12. The relief that the FTC seeks is inconsistent with the public interest. 

13. The FTC’s actions in instituting this Complaint amount to arbitrary and capricious 

conduct, overstep the FTC’s authority, and are otherwise contrary to law under the Administrative 

Procedure Act, 5 U.S.C. § 500 et seq. (“APA”), and the Federal Trade Commission Act, 15 U.S.C. 

§ 41 et seq. (“FTC Act”). This includes, but is not limited to, the FTC staff’s affirmative 

misconduct pursuing these claims, including by knowingly engaging in discussions with civil 

48 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 49 of 53 * PUBLIC *; 

PUBLIC

litigation counsel who were bound by a court-issued protective order not to use confidential 

information outside the confines of the action in which it was produced. 

14. The FTC’s claims are barred, in whole or in part, by equitable estoppel, because of 

the FTC staff’s affirmative misconduct pursuing these claims. 

15. The FTC’s claims are barred, in whole or in part, by the doctrines of in pari delicto 

and unclean hands, because of the FTC staff’s affirmative misconduct pursuing these claims. 

16. The FTC’s claims are barred because HomeAdvisor is immune from liability under 

Section 230 of the Communications Decency Act, 47 U.S.C. §230. 

17. The FTC Act and the FTC’s other information or guidance failed to provide 

HomeAdvisor with fair notice that its conduct was a violation of law, in contravention of 

HomeAdvisor’s due process rights. 

18. The FTC Act and other FTC information and guidance, as interpreted by the FTC, 

are unconstitutionally vague to the extent they have the meaning the FTC now espouses. 

19. The FTC’s claims are barred, in whole or in part, by laches. 

20. These proceedings are invalid because the constraints on removal of the FTC 

Commissioners violate Article II of the Constitution and the separation of powers. 

21. These proceedings are invalid because the constraints on removal of the 

Administrative Law Judge violate Article II of the Constitution and the separation of powers. 

22. These proceedings are invalid because adjudication of this matter by the 

Administrative Law Judge and, in turn, the Commission violates Article III of the Constitution and 

the separation of powers. 

23. These proceedings are invalid because adjudication of this matter by the 

Administrative Law Judge and, in turn, the Commission violates the right to due process of law 

49 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 50 of 53 * PUBLIC *; 

PUBLIC

under the Fifth Amendment to the Constitution, including because of the lack of a neutral decisionmaker. 

24. These proceedings violate the right to due process under the Fifth Amendment to 

the Constitution, which requires equal protection of the laws. 

25. HomeAdvisor reserves the right to assert any other available defenses. 

NOTICE 

HomeAdvisor states that the Notice of the Complaint is a restatement of the rules of the 

FTC to which no response is required. To the extent that a response is required, HomeAdvisor 

denies the allegations in the Notice of the Complaint, except for the statement that the FTC has 

provided notice of a hearing date on November 9, 2022. 

NOTICE OF CONTEMPLATED RELIEF 

HomeAdvisor states that the Notice of Contemplated Relief is a restatement of the rules of 

the FTC to which no response is required. To the extent that a response is required, HomeAdvisor 

denies the allegations in the Notice of Contemplated Relief. 

THEREFORE, HomeAdvisor respectfully request that the Administrative Law Judge: 

(i) deny the FTC’s requested relief; (ii) dismiss the Complaint in its entirety with prejudice; 

(iii) award to HomeAdvisor its costs of suit, including expert fees and reasonable attorneys’ fees, 

as may be allowed by law; and (iv) award to HomeAdvisor such other and further relief as the 

Administrative Law Judge deems just and appropriate. 

50 
 

 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 51 of 53 * PUBLIC *; 

Dated: April 6, 2022 

PUBLIC 

Respectfully Submitted, 

/s/ William A. Burck 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

William A. Burck 

Dawn Y. Yamane Hewett 

Kyra R. Simon 

1300 I Street NW, 9th Floor 

Washington, DC 20005 

(202) 538-8000 

williamburck@quinnemanuel.com 

dawnhewett@quinnemanuel.com 

kyrasimon@quinnemanuel.com 

Stephen R. Neuwirth 

Jennifer J. Barrett 

Neil T. Phillips 

George T. Phillips 

Jared Ruocco 

51 Madison Avenue, 22nd Floor 

New York, NY 10010 

(212) 849-7000 

stephenneuwirth@quinnemanuel.com 

jenniferbarrett@quinnemanuel.com 

neilphillips@quinnemanuel.com 

neilphillips@quinnemanuel.com 

jaredruocco@quinnemanuel.com 

Attorneys for Respondent HomeAdvisor, Inc. 

51 
 

 

 

 

 

 

 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 52 of 53 * PUBLIC *; 

CERTIFICATE OF SERVICE 

I hereby certify that on April 6, 2022, I filed the foregoing document electronically using the 

Administrative E-File System (AEFS), which will send notification of such filing to: 

April Tabor The Honorable D. Michael Chappell 

Office of the Secretary Administrative Law Judge 

Federal Trade Commission Federal Trade Commission 

Constitution Center 600 Pennsylvania Ave., NW, Rm. H-110 

400 Seventh Street, SW, Suite 5610 Washington, D.C. 20580 

Washington, D.C. 20024 OALJ@ftc.gov 

ElectronicFilings@ftc.gov 

I further certify that on April 6, 2022, I caused the foregoing document to be served via 

email to: 

Sophia H. Calderón 

Colin D. A. MacDonald 

Breena M. Roos 

M. Elizabeth Howe 

Federal Trade Commission, Northwest Region 

915 Second Ave., Suite 2896 

Seattle, WA 98174 

scalderon@ftc.gov 

cmacdonald@ftc.gov 

broos@ftc.gov 

mhowe@ftc.gov 

Counsel Supporting the Complaint 

April Tabor 

Office of the Secretary 

Federal Trade Commission 

Constitution Center 

400 Seventh Street, SW, Suite 5610 

Washington, D.C. 20024 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, D.C. 20580 

OALJ@ftc.gov 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 4/6/2022 | Document No. 604328 | PAGE Page 53 of 53 * PUBLIC *; 

I further certify that the electronic copy sent to the Secretary of the Commission is a true 

and correct copy of the paper original and that I possess a paper original of the signed document 

that is available for review by the parties and the adjudicator. 

Dated: April 6, 2022 By:s/ William A. Burck 

William A. Burck 

Counsel for Respondent HomeAdvisor, Inc.