Case 0:22-cv-60924-XXXX Document 1 Entered on FLSD Docket 05/16/2022 Page 1 of 17 

UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION,

 Plaintiff,

 v. 

R360 LLC, a limited liability company, and 

STEVEN DOUMAR, individually and as an 

officer of R360 LLC, 

 Defendants. 

Case No. ____________ 

COMPLAINT FOR CIVIL 

PENALTIES, PERMANENT 

INJUNCTION, AND OTHER 

RELIEF 

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

alleges that: 

1. The FTC brings this action under Sections 5(a)(1), 5(m)(1)(A), 13(b), 16(a), and 

19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 

53(b), 56(a), and 57b, and Section 8023 of the Opioid Addiction Recovery Fraud Prevention Act 

of 2018 (“OARFPA”), 15 U.S.C. § 45d, to obtain monetary civil penalties, a permanent 

injunction, monetary relief, and other relief for Defendants’ violations of Section 5 of the FTC 

Act and Section 8023 of OARFPA. 

JURISDICTION AND VENUE 

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

and 1345. 

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3. Venue is proper in this District under 15 U.S.C. § 53(b) and 28 U.S.C. 

§§ 1391(b)-(c) and 1395(a). 

PLAINTIFF 

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

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

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

§ 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. The FTC 

also enforces OARFPA, which prohibits unfair or deceptive acts or practices with respect to any 

substance use disorder treatment service or substance use disorder treatment product. 15 U.S.C. 

§ 45d(a). 

DEFENDANTS 

5. Defendant R360 LLC is a Florida limited liability company formed in 2016 with 

its principal place of business at 6330 N. Andrews Avenue, Ft. Lauderdale, Florida 33309. R360 

LLC transacts or has transacted business in this District and throughout the United States. At all 

times material to this Complaint, acting alone or in concert with others, R360 LLC has 

advertised substance use disorder treatment services to consumers throughout the United States. 

6. Defendant Steven Doumar (“Doumar”) is the sole officer, director, employee, and 

owner of R360 LLC. At all times material to this Complaint, acting alone or in concert with 

others, he has formulated, directed, controlled, had the authority to control, or participated in the 

acts and practices of R360 LLC, including the acts and practices set forth in this Complaint. In 

connection with the matters alleged herein, Doumar transacts or has transacted business in this 

District and throughout the United States. 

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COMMERCE 

7. At all times material to this Complaint, Defendants have maintained a substantial 

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

BACKGROUND ON SUBSTANCE USE DISORDERS AND TREATMENT 

8. Substance use disorders occur when recurrent use of alcohol or drugs (or both) 

causes clinically significant impairment, including health problems, disability, or failure to meet 

major responsibilities at work, school, or home. According to the results of the 2018 National 

Survey on Drug Use and Health, (“NSDUH 2018”) conducted by the Substance Abuse and 

Mental Health Services Administration (“SAMHSA”) of the United States Department of Health 

and Human Services, approximately 20.3 million people aged 12 or older had a substance use 

disorder in 2018 related to the use of alcohol or illicit drugs. Also according to NSDUH 2018, 

approximately 21.2 million people aged 12 or older – or about 1 in 13 people in that age group – 

needed substance use treatment for problems related to use of alcohol or illicit drugs in the 

previous year. However, only 3.7 million people received any type of treatment, including 

counseling, attendance at self-help group meetings, or treatment for medical problems associated 

with alcohol or drug use. Of those who received treatment, an estimated 2.4 million received 

substance use treatment from a specialty facility, including a hospital (on an inpatient basis), 

mental health center, or drug or alcohol rehabilitation facility (as either an outpatient or 

inpatient). 

9. Individuals who seek treatment for a substance use disorder at a specialty alcohol 

or drug rehabilitation center have many options to choose from. SAMHSA conducts an annual 

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census of facilities providing substance abuse treatment throughout the country and publishes 

data on their characteristics. The 2018 National Survey of Substance Abuse Treatment Services 

report summarizes responses from 14,809 different facilities. The characteristics of the facilities 

varied widely. While most offered outpatient treatment (83%), far fewer offered residential 

treatment (24%) or hospital inpatient (5%) options. Only ten percent of the treatment facilities 

offered opioid treatment programs that were certified by SAMHSA for the provision of 

medication-assisted therapy with methadone, buprenorphine, or naltrexone. While 83 percent of 

facilities offered at least one program tailored for specific types of clients, half or fewer offered a 

treatment program tailored to individuals with co-occurring mental and substance abuse 

disorders (50%), adult women (49%), clients who have experienced trauma (40%), clients who 

have experienced sexual abuse (26%), adolescents (25%), pregnant women (23%), seniors or 

older adults (21%), LGBT clients (20%), or active-duty military members (11%). Fifty-one 

percent of facilities offered treatment services in languages other than English. Only 20% of the 

facilities offered any type of detoxification services. Ninety percent of facilities reported 

accepting cash or self-payment for services, while 71% accepted private insurance, 66% 

accepted Medicaid, and 36% accepted Medicare. 

10. According to NSDUH 2018, the majority of individuals who recognize that they 

need treatment for a substance use disorder make no effort to seek substance abuse treatment at a 

specialty facility. Among those individuals who recognized that they needed treatment and yet 

did not receive it, commonly stated reasons for failing to obtain treatment included not being 

able to afford the cost (32.5%), and not knowing where to get treatment (21.1%). 

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DEFENDANTS’ BUSINESS ACTIVITIES 

11. Since at least early 2017, R360 LLC has provided marketing services to 

companies that provide treatment services to consumers suffering from substance use disorders 

(“Treatment Centers”). R360 LLC promoted its client Treatment Centers by running television 

advertisements for the “R360 Network,” purported to be a nationwide network of addiction 

recovery specialists. To become a member of the R360 Network, Treatment Centers entered into 

contracts with R360 LLC that required the payment of monthly or annual fees to R360 LLC. 

Consumers who called in response to ads for the R360 Network would be routed to one of the 

Treatment Centers that had entered into such a contract with R360 LLC. In addition to monthly 

or annual marketing fees, Treatment Centers also typically paid R360 LLC a fee for each call 

they received from a consumer responding to an ad for the R360 Network. 

12. Ads for the R360 Network did not mention any particular Treatment Centers by 

name. Instead, advertisements promised consumers that the R360 Network would direct persons 

seeking help with substance use disorders to ethical, high-quality, hand-selected Treatment 

Centers. Doumar had sole creative and editorial control over all television advertising for the 

R360 Network, as well as the R360 Network website and Facebook page. 

13. Beginning in early 2017, Defendants began airing 30-second and 60-second shortform television ads promoting R360 Network. Doumar wrote all of the scripts for the ads. 

These ads featured Kenneth Seeley (“Seeley”), a well-known interventionist who has regularly 

appeared on the A&E television show Intervention. In the ads, Seeley – identified as an author, 

former addict, and “Addiction Recovery Specialist” – implored viewers struggling with drug or 

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alcohol addiction to call the R360 Network’s “Nationwide Network of Addiction Specialists” to 

get the help they needed. 

14. These short-form ads first aired between approximately January and April 2017. 

During that time, the R360 Network had only one Treatment Center as a member. Any 

consumer who called a telephone number displayed during the short-form ads would be 

connected to this Treatment Center, which had a single location in Florida. Defendants also ran 

these short-form ads from approximately March 2018 through February 2019. 

15. In approximately April 2017, Defendants filmed a long-form television ad for the 

R360 Network. The ad had a talk-show format and was hosted by journalist and author Jane 

Velez-Mitchell. The ad also featured Seeley and Dr. Harry Haroutunian, the former medical 

director of the Betty Ford Center. In the ad, R360 LLC represented that the R360 Network was 

comprised only of the highest quality, cream of the crop, ethical Treatment Centers that had been 

hand-picked by Seeley. This advertisement contained the following statements, among others 

(Exhibit A): 

A. JANE VELEZ-MITCHELL: Well, speaking of treatment centers, getting 

into the right treatment center is perhaps the most crucial decision you can 

make when you’re getting sober. So how do people do that? 

KEN SEELEY: Well, I’m fortunate because I’ve been working in the field 

for so long, so I’ve been out there to all these treatment centers all over the 

country and I was able to see which ones are doing things ethically. So we 

handpicked those. 

JANE VELEZ-MITCHELL: So you apparently have a system – 

KEN SEELEY: Yes. 

JANE VELEZ-MITCHELL: – to get the cream of the crop – 

KEN SEELEY: Yes. 

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B. 

C. 

JANE VELEZ-MITCHELL: – when it comes to treatment centers and get 

rid of the bad guys. 

KEN SEELEY: Yeah. And seeing the bad guys and hearing about the bad 

guys and all the negative things that they’re doing, I mean, they’re patient 

brokering, they’re overbilling for urine tests, they’re doing all these 

unethical practices that are creating a bad name for all the treatment 

centers. But because we hand-selected the good ones and we know who 

they are, that’s the way to find them is, you know, let us show you the 

ones of the 17-plus years of me out there working in the trenches, let’s 

give you the right treatment centers. 

JANE VELEZ-MITCHELL: So how do people, through you, get to those 

good treatment centers. 

KEN SEELEY: Here, call us now. 

ON SCREEN: R360Network 

Call Now: 

Help is Standing By: 

FEMALE ANNOUNCER: If you or someone you love are struggling with 

addiction, you need to call the R360Network now. 

ON SCREEN: R360Network Treatment Centers 

Selected From The Very Best In The Nation 

CALL NOW 

R360Network 

The call is FREE Secure and Confidential 

FEMALE ANNOUNCER: R360 treatment centers are selected from the 

very best in the nation. 

KEN SEELEY: I want to introduce you to Madison, who’s been through 

numerous treatment centers.... 

KEN SEELEY: And explain how it was for you when you first had to pick 

up that phone and the fears that you had. 

ON SCREEN: MADISON H. 

RECOVERING ADDICT 

 R360Network. 

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MADISON H.: – I didn’t know who to call, I didn’t know where to look. I 

had no idea about treatment or detox or what it entailed.... 

JANE VELEZ-MITCHELL: Let me ask you this, do you wish you had 

had a number that you could have called that would have streamlined the 

whole process for you and put you in the treatment center that was right 

for you? 

MADISON H.: That would have made it a lot easier, yeah, definitely. 

KEN SEELEY: And you’re already struggling, you’re already struggling 

at that – 

MADISON H.: Yeah. 

KEN SEELEY: – crucial time, and trying to figure out where to go makes 

it even much more difficult. So having this number to call that we vetted 

and found treatment facilities that are the best of the best, the cream of the 

crop. And that’s what this is really about, is helping people that were 

sitting where you are right now and getting to the place where you’re at 

because going to treatment does help. 

JANE VELEZ-MITCHELL: Because you don’t always find the right 

treatment center on your own. So how many treatment centers have you 

been to? 

MADISON H.: Probably around eight or ten. 

JANE VELEZ-MITCHELL: Whoa. 

KEN SEELEY: Whew. 

JANE VELEZ-MITCHELL: And what – what made some better than 

others? 

MADISON H.: The staff that was there definitely had a huge influence on 

being able to talk openly to them; the activities they had us do; the 

structure for sure; and the facility as a whole, I mean, like you want it to 

be attractive and fun and appealing. 

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D. 

*** 

KEN SEELEY: And that’s so important. Finding the right staff and 

finding the right facility, that’s what we’re going to do for you. We’re 

going to help you find the place that will help you unravel that trauma and 

get a comfortable place where you could – go through there and nurture 

yourself, learn how to love yourself, and get the help that you desperately 

need. That’s what we’re here to do. 

JANE VELEZ-MITCHELL: So you’re an expert. How do you figure out 

what treatment center to go to? I mean, obviously, Betty Ford, you’ve 

treated many celebrities. That’s perhaps the most famous treatment center 

in the entire world. But not everybody can go to Betty Ford. Are there 

other good treatment centers out there and how do you find them? 

DR. HARRY HAROUTUNIAN: There are many good treatment centers 

out there, but I should say that celebrity was just a small portion of the 

people we treated at the Betty Ford Center. So, first of all and foremost, 

addiction is not the same in every person and treatment should be 

individualized. That starts out with a thorough evaluation. This is a 

psychosocial, biological and spiritual disease. 

*** 

JANE VELEZ-MITCHELL: ... I want to know what happens in a 

treatment center. 

DR. HARRY HAROUTUNIAN: It really depends on how sick a person is 

when they come in.... And so a typical day is to get up in the morning 

early, go to an AA meeting or other 12-step kind of meeting – 

KEN SEELEY: Yeah. 

DR. HARRY HAROUTUNIAN: – depending on the drug being used, go 

to the gym, have a good breakfast, get to your first primary therapeutic 

group, which is critical, probably one-on-one therapy during the course of 

the day. There are specialty groups and relapse prevention and education 

about the nature and the disease of alcoholism, family issues. 

KEN SEELEY: And that’s one of the things we look at when we have 

somebody deciding to be a part of our network. We want to make sure that 

they’re the best. 

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DR. HARRY HAROUTUNIAN: But the beautiful part about the network 

is that you’re guaranteeing that the personnel that are delivering the 

personalized service are qualified. 

KEN SEELEY: Yes. 

DR. HARRY HAROUTUNIAN: That’s critical. You want to have 

Master’s level at least or doctoral level therapists working on a patient, 

who can specifically deal with the patient. You want to be able to treat the 

person for all of the co-occurring experiences, co-dependents, chronic pain 

issues, trauma, but not too early in the treatment experience. 

KEN SEELEY: Sure. 

*** 

JANE VELEZ-MITCHELL: .... Well, I think this is a huge leap that now 

there is a number to call where people can get help and it filters everybody 

through to the best treatment centers. Don’t you think that’s kind of 

revolutionary, Doctor? 

DR. HARRY HAROUTUNIAN: From my perspective, it saves me a lot 

of work. Do you have any idea how many patients I’ll treat that have made 

the wrong decision on the wrong center? 

KEN SEELEY: Mm-hmm. 

DR. HARRY HAROUTUNIAN: It wasn’t right for them or were sold a 

bill of goods or the staff was not engaged or they just didn’t have the 

credentials. 

JANE VELEZ-MITCHELL: If there’s a person out there watching who 

knows they have a relative, a son, a daughter, a wife, mother, who has a 

problem, what would you tell that relative to do, vis-a-vis, calling that 

number? 

DR. HARRY HAROUTUNIAN: I would say that you have to act like 

death is imminent, that you will save a life.... 

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16. At the time that the infomercial was filmed, in approximately April 2017, the 

R360 Network had zero members. 

17. Defendants aired the infomercial nationwide beginning in approximately May or 

June 2017, until early 2019. During that period, no more than four Treatment Centers were 

members of the R360 Network at any given time, although some of the Treatment Centers had 

more than one location. 

18. Calls that were received in response to the infomercial were automatically routed 

to a Treatment Center that was an R360 Network member. Incoming calls were not first 

screened by anyone to assess the caller’s particular needs. Therefore, callers had no opportunity 

to indicate their preferences for treatment characteristics – for instance, whether the caller 

desired residential or outpatient treatment, whether the caller desired a medical detox, whether 

the caller was willing to travel to a distant geographical location for treatment, whether the caller 

needed a Treatment Center that would accept Medicaid, or whether the caller wanted a singlesex treatment program – before being transferred directly to an R360 Network member. 

19. Doumar was responsible for recruiting Treatment Centers to become members of 

the R360 Network. Doumar had no educational or professional experience in the fields of 

substance use disorder, addiction treatment, or mental health. Several other individuals also 

performed services for R360 LLC and communicated with Treatment Centers on R360 LLC’s 

behalf, but with the exception of Seeley, none of them had any educational or professional 

experience in the fields of substance use disorder, addiction treatment, or mental health. 

20. When R360 LLC began to recruit Treatment Centers to join the R360 network, 

Seeley provided R360 LLC with the names of dozens of Treatment Centers that Seeley 

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recommended and whose owners Seeley knew. However, almost all of these Treatment Centers 

declined to join the R360 Network. Doumar then compiled lists of additional Treatment Centers 

that he considered potential candidates to join the R360 Network and directed others to conduct 

outreach efforts to attempt to get the Treatment Centers to join. Doumar compiled these lists of 

potential R360 Network members after conducting internet searches and walking through booths 

at industry trade shows. 

21. Doumar was responsible for assessing the quality of Treatment Centers that might 

join the R360 Network, and he made the ultimate decision as to which Treatment Centers would 

join. At most, Doumar’s evaluation consisted of asking Treatment Center personnel general 

questions, such as whether their facilities were accredited, had liability insurance, had a medical 

director, had licensed staff, and met local fire codes. Doumar took any responses he received on 

these topics at face value and did not conduct any independent research to verify that the 

information provided by representatives of the Treatment Centers was in fact true. 

22. To the extent Doumar communicated with Treatment Centers about these topics, 

he did so in only the broadest terms. For instance, if he asked a Treatment Center representative 

whether it had liability insurance, he did not inquire as to the amount of insurance coverage or 

whether any injury or malpractice claims had been filed against the Treatment Center. If 

Doumar asked if the Treatment Center had a medical director, he did not inquire as to the 

director’s educational background, work experience, or particular qualifications for the position. 

In no instance did Seeley, or anyone with expertise in substance use disorder treatment acting on 

R360 LLC’s behalf, visit a Treatment Center in person, or speak to current or former patients of 

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a Treatment Center, to assess whether the quality of services provided met any particular 

standards required to join the R360 Network. 

23. Given the large number of Treatment Centers in the United States, in many 

instances, Seeley had no prior professional experience or direct knowledge of the practices of 

specific Treatment Centers that R360 LLC was considering to bring on as members of the R360 

Network. Doumar signed up numerous Treatment Centers as members of the R360 Network 

even when Seeley lacked any personal knowledge regarding those Treatment Centers’ business 

practices. 

VIOLATION OF THE OPIOID ADDICTION RECOVERY 

FRAUD PREVENTION ACT OF 2018 

24. The Opioid Addiction Recovery Fraud Prevention Act of 2018 (“OARFPA”), 

P.L. 115-271, 15 U.S.C § 45d, was enacted on October 24, 2018. OARFPA prohibits unfair or 

deceptive acts or practices with respect to any substance use disorder treatment service or 

substance use disorder treatment product. 15 U.S.C. § 45d(a). Section 8022 of OARFPA 

defines “substance use disorder treatment service” to mean “a service that purports to provide 

referrals to treatment, treatment, or recovery housing for people diagnosed with, having, or 

purporting to have a substance use disorder, including an opioid use disorder.” P.L. 115-271 

§ 8022. 

25. Pursuant to 15 U.S.C. § 45d(b)(1), a violation of 15 U.S.C. § 45d(a) shall be 

treated as a violation of a rule under Section 18(a) of the FTC Act, 15 U.S.C. § 57a(a), regarding 

unfair or deceptive acts or practices. 

26. Defendants violated OARFPA as described below, with the knowledge required 

by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A). 

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27. Each dissemination of an advertisement in which Defendants violated OARFPA 

by making one or more of the deceptive representations described below after October 24, 2018, 

constitutes a separate violation for which Plaintiff seeks monetary civil penalties. 

28. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as modified by 

Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 1990, 28 U.S.C. § 2461, the 

Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, Public Law 114-74, 

sec. 701, 129 Stat. 599 (2015), and Section 1.98(d) of the FTC’s Rules of Practice, 16 C.F.R. 

§ 1.98(d), authorizes this Court to award monetary civil penalties of not more than $46,517 for 

each violation of OARFPA after January 10, 2022, including penalties whose associated 

violation predated January 10, 2022. 

Count I 

29. In numerous instances in connection with the advertising, marketing, and 

promotion of substance use disorder treatment services after October 24, 2018, including through 

the means described in Paragraphs 11-17, Defendants have represented, directly or indirectly, 

expressly or by implication, that: 

a. Consumers who called the telephone numbers provided in ads for the R360 

Network would be connected to an addiction treatment specialist who would 

consider the caller’s individual needs and make a personalized assessment to 

refer the caller to the best Treatment Center for his or her particular situation; 

b. Seeley used his expertise in substance use disorders and addiction treatment to 

evaluate Treatment Centers in the R360 Network and hand selected each 

R360 Network member; and 

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c. Defendants evaluated each of the Treatment Centers in the R360 Network 

against meaningful, rigorous, objective criteria. 

30. In truth and in fact: 

a. Consumers who called the telephone numbers provided in ads for the R360 

Network received no personal assessment, but were instead immediately 

routed to a Treatment Center without regard for their individualized needs; 

b. Seeley did not use his expertise in substance use disorders and addiction 

treatment to evaluate Treatment Centers in the R360 Network and did not 

hand select each R360 Network member; and 

c. Defendants did not evaluate the Treatment Centers in the R360 Network 

against meaningful, rigorous, objective criteria. 

31. Therefore, the making of the representations as set forth in Paragraph 29 

constitutes a deceptive act or practice in violation of Section 8023(a) of OARFPA, 15 U.S.C. 

§ 45d(a). 

VIOLATION OF THE FTC ACT 

32. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” Misrepresentations or deceptive omissions of material 

fact constitute deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

Count II 

33. In numerous instances in connection with the advertising, marketing, and 

promotion of substance use disorder treatment services, including through the means described 

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in Paragraphs 11-17, Defendants have represented, directly or indirectly, expressly or by 

implication, that: 

a. Consumers who called the telephone numbers provided in ads for the R360 

Network would be connected to an addiction treatment specialist who would 

consider the caller’s individual needs and make a personalized assessment to 

refer the caller to a Treatment Center appropriate for his or her particular 

situation; 

b. Seeley used his expertise in substance use disorders and addiction treatment to 

evaluate Treatment Centers in the R360 Network and hand selected each 

R360 Network member; and 

c. Defendants evaluated each of the Treatment Centers in the R360 Network 

against meaningful, rigorous, objective criteria. 

34. In truth and in fact: 

a. Consumers who called the telephone numbers provided in ads for the R360 

Network received no personal assessment, but were instead immediately 

routed to a Treatment Center without regard for their individualized needs; 

b. Seeley did not use his expertise in substance use disorders and addiction 

treatment to evaluate Treatment Centers in the R360 Network and did not 

hand select each R360 Network member; and 

c. Defendants did not evaluate the Treatment Centers in the R360 Network 

against meaningful, rigorous, objective criteria. 

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35. Therefore, the making of the representations as set forth in Paragraph 33 

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

§ 45(a). 

CONSUMER INJURY 

36. Consumers have suffered substantial injury as a result of Defendants’ violations 

of the FTC Act and OARFPA. Absent injunctive relief by this Court, Defendants are likely to 

continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

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

OARFPA by Defendants; 

B. Award Plaintiff monetary civil penalties from Defendants for each violation of 

OARFPA alleged in this Complaint; 

C. Award monetary and other relief within the Court’s power to grant; and 

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

Respectfully submitted, 

Dated: ____________________ _________________________________ 

CHRISTINE L. DELORME 

(Special Bar ID A5502888) 

KAREN MANDEL (Special Bar ID A5501752) 

Attorneys, Division of Advertising Practices 

Federal Trade Commission 

600 Pennsylvania Ave. NW 

Washington, DC 20580 

Tel: 202-326-2095, -2491 

Fax: 202-326-3259 

cdelorme@ftc.gov 

kmandel@ftc.gov 

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