Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 1 of 22 PageID 1 

UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

TAMPA DIVISION 

UNITED STATES OF AMERICA, Case No. 8:23-cv-1575 

Plaintiff, 

COMPLAINT FOR 

v. PERMANENT INJUNCTION, 

CIVIL PENALTIES, AND 

YODEL TECHNOLOGIES, LLC, a OTHER RELIEF 

limited liability company, also d/b/a Yodel 

Technology Services; and 

ROBERT W. PULSIPHER, individually 

and as an officer of Yodel Technologies, 

LLC, 

Defendants. 

Plaintiff, the United States of America, acting upon notification and 

authorization to the Attorney General by the Federal Trade Commission (“FTC”), 

pursuant to Section 16(a)(1) of the Federal Trade Commission Act (“FTC Act”), 15 

U.S.C. § 56(a)(1), for its Complaint alleges: 

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

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

45(m)(1)(A), 53(b), and 57b, and Section 6 of the Telemarketing and Consumer 

Fraud and Abuse Prevention Act (“Telemarketing Act”), 15 U.S.C. § 6105, to obtain 

monetary civil penalties, a permanent injunction, and other equitable relief for 
 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 2 of 22 PageID 2 

Defendants’ violations of the FTC’s Telemarketing Sales Rule (“TSR”), as 

amended, 16 C.F.R. Part 310. 

2. Defendants are telemarketers who have bombarded U.S. consumers 

with over one billion calls, including hundreds of millions of calls that were either 

robocalls, delivered to numbers on the National Do-Not-Call Registry, or both. 

Attempting to justify this barrage of illegal calls, Defendants have purchased or have 

otherwise obtained leads that bundled consumers’ contact information and purported 

consent to receive telemarketing calls from "consent farm” websites, which mislead 

consumers by failing to clearly disclose that the purpose for which consumers 

provide information. But the purported consent Defendants have obtained is 

insufficient under the TSR. Thus, Plaintiff files this lawsuit to recover civil penalties 

and halt Defendants’ deceptive acts and practices. 

JURISDICTION, VENUE, AND DIVISION ASSIGNMENT 

3. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 

§§ 1331, 1337(a), 1345, and 1355, because it involves claims arising under federal 

laws regulating commerce and is commenced by the United States. The claims arise 

under 15 U.S.C. §§ 45(m)(1)(A), 53(b), and 56(a). 

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

(c)(2), and (d) and 1395(a), as well as 15 U.S.C. § 53(b)(2), because Defendants 

2 
 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 3 of 22 PageID 3 

reside and transact business in this District, and a substantial part of the events or 

omissions giving rise to the claims occurred in this District. 

5. Assignment to the Tampa Division is proper pursuant to Local Rule 

1.04, because Defendants principally transacted business from Pinellas County. 

DEFENDANTS 

6. Defendant Yodel Technologies, LLC, also doing business as Yodel 

Technology Services (“Yodel”), is a Delaware limited liability company with its 

principal place of business at 989 Georgia Avenue, 1st Floor, Palm Harbor, Florida 

34683. Yodel transacts or has transacted business in this District and throughout the 

United States. At all times relevant to this Complaint, acting alone or in concert with 

others, Yodel has initiated outbound telemarketing calls to consumers throughout 

the United States. 

7. Defendant Robert W. Pulsipher (“Pulsipher”) has been the sole owner 

and Chief Operating Officer of Yodel at all times relevant to this Complaint. At all 

times relevant to this Complaint, acting alone or in concert with others, he has 

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

acts and practices of Yodel, including the acts and practices set forth in this 

Complaint. His responsibilities with Yodel have included compliance, complaint 

response, and complaint monitoring. Pulsipher resides in this District and in 

3 
 

 

 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 4 of 22 PageID 4 

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

this District and throughout the United States. 

COMMERCE 

8. At all times relevant to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44. 

THE TELEMARKETING SALES RULE 

9. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101-6108. The FTC adopted the original TSR in 1995, extensively 

amended it in 2003, and amended certain sections thereafter. 16 C.F.R. Part 310. 

10. Under the TSR, an “outbound telephone call” means a telephone call 

initiated by a telemarketer to induce the purchase of goods or services or to solicit a 

charitable contribution. Id. § 310.2(x). A “seller” means any person who, in 

connection with a telemarketing transaction, provides, offers to provide, or arranges 

for others to provide goods or services to the customer in exchange for consideration. 

Id. § 310.2(dd). A “telemarketer” means any person who, in connection with 

telemarketing, initiates or receives telephone calls to or from a customer or donor. 

Id. § 310.2(ff). 

4 
 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 5 of 22 PageID 5 

11. As amended, effective September 1, 2009, the TSR prohibits initiating 

any outbound telephone call that delivers a prerecorded message (“robocall”) to 

induce the purchase of any good or service, unless the seller has obtained from the 

recipient of the call an express agreement, in writing, that evidences the willingness 

of the recipient of the call to receive calls that deliver prerecorded messages by or 

on behalf of a specific seller. Id. § 310.4(b)(l)(v). The express agreement the seller 

has obtained from the recipient of the call must include: (i) A clear and conspicuous 

disclosure that the purpose of the agreement is to authorize the seller to place 

prerecorded calls to such person; (ii) Evidence that the seller obtained without 

requiring, directly or indirectly, that the agreement be executed as a condition of 

purchasing any good or service; (iii) Evidence of the willingness of the recipient of 

the call to receive calls that deliver prerecorded messages by or on behalf of a 

specific seller; and (iv) The recipient’s telephone number and signature. Id. § 

310.4(b)(l)(v)(A). 

12. Additionally, the 2003 amendments to the TSR established the National 

Do-Not-Call Registry (“Registry”), maintained by the FTC, of consumers who do 

not wish to receive certain types of telemarketing calls. Consumers can register their 

telephone numbers on the Registry without charge either through a toll-free 

telephone call or over the Internet at donotcall.gov. 

5 
 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 6 of 22 PageID 6 

13. The TSR prohibits sellers and telemarketers from initiating an 

outbound telephone call to a number on the Registry unless the seller or telemarketer 

can demonstrate that the seller (1) has obtained the consumer’s express agreement, 

in writing, to place such calls, or (2) has an established business relationship with 

that consumer, and the consumer has not stated that he or she does not wish to receive 

such calls. Id. § 310.4(b)(l)(iii)(B). Valid written consent to receive a live 

telemarketing call to a number on the Registry requires: (1) a writing signed by the 

consumer, (2) clearly evidencing authorization to receive calls placed by or on behalf 

of a specific party, and (3) stating the telephone number to which such calls may be 

placed. Id. § 310.4(b)(l)(iii)(B)(l). 

14. Consumers who receive telemarketing calls to their registered numbers 

can complain of Registry violations the same way they registered, through a toll-free 

telephone call or over the Internet at donotcall.gov, or by otherwise contacting law 

enforcement authorities. 

15. The FTC allows sellers, telemarketers, and other permitted 

organizations to access the Registry over the Internet at telemarketing.donotcall.gov, 

to pay the fee(s) if required, and to download the numbers not to call. 

16. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), 

a violation of the TSR is treated as a violation of an FTC rule under Section 18 of 

the FTC Act, 15 U.S.C. § 57a, regarding unfair or deceptive acts or practices. In turn, 

6 
 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 7 of 22 PageID 7 

under Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation of the TSR 

constitutes an unfair or deceptive act or practice in or affecting commerce, in 

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

DEFENDANTS’ UNLAWFUL CONDUCT 

17. From at least 2015 through 2021, Defendants have operated a massive 

robocalling enterprise, targeting millions of consumers on behalf of clients who sold 

various products and services, including auto insurance, cruises, medical devices, 

life insurance, credit repair, extended auto warranties, health insurance, Medicare 

supplements, and supposed assistance with Social Security benefits. 

18. To sustain this enterprise, Defendants have employed “soundboard” 

technology that allows their call center agents to play pre-recorded audio clips using 

“response keys” to engage consumers. Defendants used those keys to ask automated 

questions like “Can you hear me okay?” or “Sounds great right?” These tactics make 

it appear as though consumers are talking to a live human rather than software. 

Defendants’ pre-recorded questions are actually part of a sales pitch intended to keep 

consumers from hanging up until Defendants could transfer the call to any one of 

their clients, whose live telemarketers would then pitch their services. 

19. The scale of Defendants’ calling operation is massive. Between January 

2018 and May 2021, Defendants made over 1.4 billion calls to U.S. consumers. 

Upon information and belief, Defendants employed this soundboard technology in 

7 
 

 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 8 of 22 PageID 8 

all or a substantial amount of these calls. At times, Defendants have initiated over 

two-and-a-half million calls in a single day. Of the billion-plus calls during this timeperiod, over 500 million went to consumer numbers that were listed on the Registry. 

Consumers have filed over 100,000 consumer complaints with the FTC against 

telephone numbers associated with Defendants. 

Defendants Have Engaged in Unlawful Telemarketing 

20. In order to sustain this operation, Defendants have obtained millions of 

“leads” from other companies, which bundle consumers’ personal information and 

purported consent to receive telemarketing calls (including robocalls). Defendants 

have then proceeded to inundate these consumers with illegal robocalls, pitching a 

myriad of products and services offered by their many clients. 

21. The companies have generated these leads through “consent farm” 

websites, which deceptively induce consumers to provide their information and click 

in such a way as to give purported consent for robocalling and telemarketing, even 

if their numbers were listed on the Registry. The companies controlling these 

websites have sought such consent not on their own behalf, but so that they could 

sell leads to sellers or telemarketers like Defendants, who pitch various products and 

services. 

22. Defendants have blasted calls to consumers who submitted personal 

information to many different kinds of lead generation websites—including sites that 

8 
 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 9 of 22 PageID 9 

claimed to help consumers to obtain insurance quotes, find employment, get workout 

videos, vitamins, and supplements, obtain a free gift or coupon code for a reducedprice item, obtain rewards, get paid for taking surveys, enter sweepstakes, and many 

other purported goods or services. 

23. In several instances, these websites have made prominent, brightly 

colored, boldface promises about the goods or services they claimed to offer 

consumers. The websites have also elicited consumers’ personal information, 

including their names and telephone numbers, based on the representation that 

submitting that personal information was needed to obtain the good or service. At 

the same time, these websites have disclosed only in fine print that consumers who 

submitted their personal information and proceeded through these websites were 

purportedly agreeing to receive telemarketing calls, including robocalls. The 

operators of these websites have then packaged and sold information submitted by 

consumers to Defendants and other third parties which, in turn, bombarded them 

with telemarketing calls. 

Quick-Jobs.com 

24. Defendants have made more than 13 million calls to consumers whose 

contact information they obtained from a website called Quick-Jobs.com. Upon 

information and belief, all or a substantial number of these calls were robocalls, and 

nearly six million calls went to numbers that were listed on the Registry. 

9 
 

 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 10 of 22 PageID 10 

25. Quick-Jobs.com has claimed to help consumers find jobs by providing 

them with customized, aggregated, third-party employment listings. Consumers 

have begun this job search process by entering a “job title” and zip code, at which 

point the website presents a pop-up for consumers to complete to receive job 

opportunities. 

26. The pop-up window claims in bold black and red text that there are jobs 

available nearby. See Attach. 1 at 1 (“We found 310 Jobs in 89117!”). Consumers 

are directed to “Complete the form below to get started!” There are fields to enter 

their first and last name, email address, and telephone number. 

27. Each of the information fields is designated with bold blue identifying 

text and a red asterisk next to it, a symbol that is commonly used on websites to 

designate a required field, or one that must be completed to move to the next screen. 

Id. The design of the pop-up window thus makes it appear that the consumer must 

complete it, and that the purpose of completing the form is to view the job search 

results. The page also presents a big blue “continue” button to indicate to the 

consumer that they must click the button to receive the job search results. Id. 

28. Only in very small print, sandwiched between the prominent contact 

information fields and the similarly prominent “continue” button, does the website 

disclose the true consequences of clicking the “continue” button in pursuit of job 

opportunities. Specifically, consumers are informed that they are giving their 

10 
 

 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 11 of 22 PageID 11 

purported consent to be robocalled by Quick Jobs and its “partners,” which appear 

to sell unrelated products or services. The website’s design features overwhelm this 

disclosure and lead the consumer to believe that the purpose of the form and the 

“continue” button is to pursue job search assistance. 

29. Consumers cannot bypass this purported consent except by locating one 

of two small, indistinct, not prominently placed links—a “skip here” link at the end 

of this small-text disclosure, or a faint, gray “continue to results” link at the very 

bottom of the pop-up. These links are not as colorful or prominent as the claims 

about jobs results or the “continue” button. 

30. The “partners” from whom consumers purportedly consent to receive 

calls, including robocalls, are not identified on the page. Instead, consumers must 

access the list of partners only by hovering over the “partners” link in the fine print 

disclosure. See id. at 2. This “partners” list has included at least 90 different names 

at once, many of which are assumed names (or “DBAs”) for telemarketers or sellers, 

selling a variety of goods or services that appear to be entirely unrelated to job search 

assistance, such as, for example, energy services, cruises, and insurance. Many of 

the DBAs do not meaningfully identify a specific telemarketer or seller but instead 

are used for telemarketing campaigns made on behalf of multiple sellers. See id. 

(including DBAs such as “Premier Disability”). 

24. In the case of Yodel, this webpage has used the DBA “Consumer 

11 
 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 12 of 22 PageID 12 

Counsil [sic]” to identify Yodel’s clients. “Consumer Counsil” does not identify 

Yodel or a specific seller. Yodel has used this DBA (spelled as “Consumer Council”) 

for campaigns that are entirely unrelated to job searches, including auto insurance. 

Bestquotes.com 

25. Defendants have made more than seven million calls to numbers 

obtained from bestquotes.com, which has claimed to offer insurance quotes. Upon 

information and belief, all or a substantial number of these calls were robocalls, and 

nearly four million calls were directed to numbers that were listed on the Registry. 

26. Bestquotes.com has claimed to provide consumers with automobile 

insurance quotes. Based on certain vehicle specifications, the website promises to 

allow consumers to “get my quotes.” Id. at 3. 

27. This website states in bold at the top that the consumer is “almost done” 

and directs consumers to enter “your contact information,” which, the website 

assures, “will be used for providing quotes only.” Reinforcing that the consumer is 

close to obtaining quotes, the website displays a status bar suggesting that the 

consumer is “92%” complete. The page also includes a prominent, brightly colored 

arrow claiming that consumers can “save up to $469/yr” and pointing to the portion 

of the page where consumers enter their contact information. It also claims to have 

helped numerous people save, and it displays the logos of insurance companies it 

claims are “top” insurance providers in the consumer’s state. Id. at 3-4. 

12 
 

 

 

 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 13 of 22 PageID 13 

28. To proceed through the website, the page also displays a prominent red 

button urging consumers to “Get My Quotes!” Id. The net impression of the page 

conveys the message that the purpose of submitting personal information and 

clicking “Get My Quotes” is to get quotes for automobile insurance and that 

consumers must submit their information and click this button to see the quotes. The 

webpage presents no clear method to receive quotes without pressing the button. 

29. Only in very small print has the website disclosed the true consequences 

of consumers submitting their personal information and clicking the button. 

Specifically, the consumer will receive robocalls and other telemarketing calls from 

“insurance companies, their agents, and marketing partners,” and will be contacted 

even if on the Registry. Even this small print has not disclosed the identity of these 

“insurance companies, their agents, and marketing partners.” Rather, this text is a 

hyperlink, which the consumer must click on or hover over to access a scroll-through 

list of several dozen DBAs. See id. at 4. 

30. The phrase “insurance companies, their agents, and marketing 

partners” is itself misleading because it suggests that any calls will be related to 

insurance. That is not the case. The website has used the DBA “Disability Advisor” 

to identify Yodel’s clients. This is a generic DBA that does not identify a specific 

seller. Consumers who have clicked on the “Get My Quotes!” link on this webpage 

had their contact information sold to Yodel and dozens of other entities. In turn, 

13 
 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 14 of 22 PageID 14 

Yodel has bombarded them with robocalls from a “Social Security Disability 

Advisor” purporting to offer assistance with obtaining Social Security benefits. 

The “Consent Farm” Websites Do Not Provide Valid 

Consent for Telemarketing under the TSR 

31. The “consent farm” websites described above, as well as other websites 

that Defendants have relied upon for purported consent, have utilized a variety of 

design elements known as dark patterns, which interfere with consumers’ ability to 

make informed choices about the use of their data and their willingness to receive 

robocalls and calls after adding their telephone numbers to the Registry. 

32. Among other things, these websites have not clearly disclosed to 

consumers that they are providing consent to receive robocalls and other 

telemarketing solicitations, including because they have: 

a. Used disclosures that are disproportionally small or faint 

compared to more prominent messages and other distractions on the same page; 

b. Used buttons labeled “continue,” “get my quotes,” or other 

verbiage that do not put consumers on notice of the purported legal significance of 

the actions they are taking; and 

c. Induced consumers to believe that they are required to provide 

consent through the use of hidden or non-existent methods of exiting the consent and 

information collection process. 

33. The websites from which Defendants have obtained leads do not 

14 
 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 15 of 22 PageID 15 

evidence the willingness of consumers to receive calls delivering prerecorded 

messages “by or on behalf of a specific seller,” as required by the TSR, 16 C.F.R. 

§310.4(b)(1)(v)(A)(iii) (emphasis added). The websites have also purported to 

obtain consent on behalf of numerous and varied entities, not a specific seller. 

34. Even when the websites have listed DBAs provided by Yodel, these 

have used generic DBAs which do not identify Yodel or specific sellers by name. 

Yodel has placed calls to leads obtained pursuant to these generic assumed names 

on behalf of multiple sellers. Even these generic DBAs have often been buried within 

a small-print list of dozens of “marketing partners” or hidden behind hyperlinks. 

35. Finally, the consent forms that have been used by these websites do not 

meet the TSR’s requirement that, for calls delivering prerecorded messages, the 

“seller has obtained from the recipient of the call an express agreement, in writing” 

to receive the call, 16 C.F.R. § 310.4(v)(A) (emphasis added). 

Defendants’ Knowledge That They Engaged in 

Unlawful Telemarketing 

36. In November 2016, FTC staff issued an opinion letter concluding that 

telemarketing calls utilizing soundboard technology are subject to the prerecorded 

message provisions of the TSR. Since at least mid-2018, Yodel has known about 

that opinion letter. 

37. Yodel litigated the issue of whether its soundboard technology used “an 

artificial or prerecorded voice to deliver a message” for purposes of 47 U.S.C. 

15 
 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 16 of 22 PageID 16 

§ 227(b)(1)(B) of the Telephone Consumer Protection Act (“TCPA”), which 

prohibits robocalling without prior express consent. In July 2019, a court held that 

Yodel had in fact delivered pre-recorded messages. See Braver v. NorthStar Alarm 

Servs., LLC, No. 17-CV-0383, 2019 WL 3208651, at *6 (W.D. Okla. July 16, 2019). 

38. Yodel also petitioned the Federal Communications Commission 

(“FCC”) for a declaratory ruling that soundboard calls were not covered by the 

TCPA prohibition in September of 2019 and did not prevail. Pulsipher directly 

participated in this process by meeting with the FCC in connection with the petition. 

39. Furthermore, Defendants have been aware of the contents of the 

“consent farm” websites from which they obtained leads, including the features that 

caused them to be non-compliant with the TSR. Defendants have represented to the 

FCC that Yodel reviewed the contents of its source websites on a weekly basis. 

40. Defendants have also received inquiries or complaints, or have been 

notified of litigation related to their delivery of prerecorded messages, calls to 

numbers that were registered on the Registry, and other telemarketing calls. In 

response to such inquiries, complaints, and litigation, Defendants frequently have 

been required to provide proof of their purported consents. This proof commonly 

included screenshots of the website from which the purported consent was obtained. 

41. For example, USTelecom, a telecommunications industry association, 

served Yodel with “traceback” requests seeking information about specific calls that 

16 
 

 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 17 of 22 PageID 17 

appear to be illegal robocalls. Yodel provided consent website screenshots as part of 

its responses. Yodel also solicited consent information from its lead sources in order 

to defend itself or seller-clients against private TCPA litigation filed on behalf of 

individual consumers or classes of consumers, even going so far as to solicit or 

develop affidavits that contained detailed descriptions of the consent flow. And 

Yodel provided screenshots in response to inquiries by attorney general offices. 

42. Lastly, Defendants were well aware that the generic DBAs they have 

provided to website operators to purportedly identify Defendants as a “marketing 

partner” do not actually identify them, and that they were using these DBAs to make 

calls on behalf of a variety of sellers, such that the DBA does not correspond to, let 

alone identify, any one seller. 

Ongoing Conduct 

43. Based on the facts and violations of law alleged in this Complaint, the 

FTC has reason to believe that Defendants are violating or are about to violate laws 

enforced by the FTC, because, among other things: 

a. Defendants have engaged in numerous and continuous 

violations; 

b. Defendants have continued to engage in such violations after 

receiving the FTC’s Civil Investigative Demand in December 2020; 

c. Defendants have continued to engage in such violations after 

17 
 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 18 of 22 PageID 18 

being contacted by the FCC in March 2021; 

d. Defendants have continued to engage in such violations after 

receiving numerous complaints and lawsuits alleging that consumers did not want 

these calls and did not agree to receive them; 

e. Pulsipher has continued to work in telemarketing and exercise 

control over Yodel’s soundboard infrastructure; and 

f. Defendants maintain the means, ability, and incentive to engage 

in similar conduct in the future. 

COUNT I 

Initiating Calls to Numbers on the National Do Not Call 

Registry in Violation of the Telemarketing Sales Rule 

44. In numerous instances, in connection with telemarketing, Defendants 

have initiated, or caused others to initiate, an outbound telephone call to a person’s 

telephone number on the National Do Not Call Registry in violation of the TSR, 16 

C.F.R. § 310.4(b)(l)(iii)(B). 

45. Defendants’ violations were committed with the knowledge required 

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

18 
 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 19 of 22 PageID 19 

COUNT II 

Initiating Robocalls in Violation of the 

Telemarketing Sales Rule 

46. In numerous instances, in connection with telemarketing, Defendants 

have initiated, or caused others to initiate, outbound telephone calls delivering 

prerecorded messages to induce the purchase of goods or services in violation of the 

TSR, 16 C.F.R. § 310.4(b)(1)(v)(A). 

47. Defendants’ violations were committed with the knowledge required 

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

CONSUMER INJURY 

48. Consumers in the United States have suffered and will continue to 

suffer substantial injury as a result of Defendants’ violations the TSR. Absent 

injunctive relief by this Court, Defendants are likely to continue to injure consumers 

and harm the public interest. 

THE COURT’S POWER TO GRANT RELIEF 

49. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court 

to grant injunctive and such other relief as the Court may deem appropriate to halt 

violations of any provision of law enforced by the FTC, including the Telemarketing 

Act and the TSR. 

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

Section 3(c) of the Telemarketing Act, 15 U.S.C. § 6102(c), as modified by Section 

19 
 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 20 of 22 PageID 20 

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, 

Pub. L. No. 114-74 § 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 for each violation of the TSR committed with actual knowledge or 

knowledge fairly implied. 

51. Section 19(b) of the FTC Act, 15 U.S.C. § 57b(b), and Section 3(c) of 

the Telemarketing Act, 15 U.S.C. § 6102(c), authorize this Court to grant such relief 

as the Court finds necessary to redress injury to consumers resulting from 

Defendants’ violations of the TSR, including rescission or reformation of contracts, 

refund of money or return of property, payment of damages, and public notification 

respecting Defendants’ violations, or unfair or deceptive acts or practices. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

A. Enter judgment against Defendants and in favor of Plaintiff for each 

violation alleged in this Complaint; 

B. Enter a permanent injunction to prevent future violations of the TSR by 

Defendants; 

C. Award Plaintiff monetary civil penalties from each Defendant for every 

violation of the TSR; 

20 
 

 

 

 

 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 21 of 22 PageID 21 

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

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

Dated: July 14, 2023 

Respectfully submitted, 

Of Counsel: 

JASON C. MOON 

JOHN R. O’GORMAN 

Attorneys 

Federal Trade Commission 

1999 Bryan Street, Suite 2150 

Dallas, TX 75201 

FOR THE UNITED STATES OF 

AMERICA: 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney 

General Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General 

AMANDA N. LISKAMM 

Director 

Consumer Protection Branch 

RACHAEL L. DOUD 

Assistant Director 

Consumer Protection Branch 

/s/ Zachary L. Cowan 

ZACHARY L. COWAN (NCBN 53432) 

Trial Attorney 

Consumer Protection Branch 

U.S. Department of Justice 

450 5th Street, N.W. 

Washington, D.C. 20530 

Tel: 202-353-7728 

Fax: 202-514-8742 

Zachary.L.Cowan@usdoj.gov 

21 
 

 

Case 8:23-cv-01575 Document 1 Filed 07/14/23 Page 22 of 22 PageID 22 

ROGER B. HANDBERG 

United States Attorney 

Middle District of Florida 

LACY R. HARWELL, JR. 

(Florida Bar No. 714623) 

Assistant United States Attorney 

Middle District of Florida 

400 North Tampa Street, Suite 3200 

Tampa, FL 33602 

Phone: (813) 301-3008 

Fax: (813) 274-6358 

Randy.Harwell@usdoj.gov 

22 
Case 8:23-cv-01575 Document 1-1 Filed 07/14/23 Page 1 of 5 PageID 23 

Attachment 1 
We found 310 lobs in 89117! 

Complete the form below to get started! 

*First Name: *Last Name: 

*Email Address: *Phone: 

~ uiclr-Jobs.com J-\C•-•-

By dicking lhe button, I agree Iha\ rm a U.S. Resident over the age of 18 and I agree to this site's tenns and~-~-I also 

agree to be contacted by Qvidc: Jobs, Fuentes, Of its P.!!:rtners regarding career alerts or other opportuMies via text. phone, emal, 

al'tificial voice messages witt1 an automated telephone dialing system and Pferec:orded messages. Message frequency may vary. 

This is not required as a condition of purchasllQ any goods or setVices et for employment. I may revoke consent at anytme. 

Messaging and data rates may apply. Text STOP to opt out Text HELP to receive help.~ if you are not interested 

D R"'""JooAlerts>iaSMS 

Messaging and data rates may apply. Text STOP to opt oot. Text HELP to receive help. 

CONTINUE> 

Case 8:23-cv-01575 Document 1-1 Filed 07/14/23 Page 2 of 5 PageID 24 

1 
We found 823 lobs in 89122! 

Complete the form below to get started! 

*First Name: 

*Email Address: 

email123@gmail.com 

*Last Name: 

*Phone: 

702 

..,L ""'c Quick ____ -lob_ s.com 

537 2872 

By clici<ing the button. I agree that I'm a U.S. Resident over the age of 18 and I agree to this site's tQ!Dll and Rt!l'acy_~ icy. I also 

agree to be contacted by Quiel< Jobs, Fuentes, or Its Rirlnm regarding career alerts or other opportunities via text, phone, email, 

artificial voice messages with an automated telephone dialing system and prerecOl'ded messages. Message frequency may vary. 

This is not required as a condition of purchasing any goods or services or for employment. I may revoke consent at anytime. 

Messaging and data rates may apply. Text STOP to opt out. Text HELP to receive help. SklR..tlm if you are not Interested 

0 Receive Job Alerts via SMS 

Messaging and data rates may apply. Text STOP to opt out. Text HELP to receive help. 

CONTINUE> 

• qulck-Jobs.com/hlringjobsqj partners link 

[Jv , o\ @ Cl_ rh 

qulck•Jobs.com/hlrlng]obsqj partners link 

Career Placement Advisors, MyJobHunter, My Job Group, Home Protect()(S, Iberdrola, Nordic Energy Services, LLC, American 

Dlsabili'X Helpline, United States Disability, Email Magic LLC. Home Support Group, Heard anc Smith, Premier Disability, Advocacy 

Center, Consumer Counlil, Medical Support Group, Horne Support Group, Advocator Group, Citizens Disability, Miami Media, Insurance 

Proz, royal sea cruises, Gerber Life Insurance, Blogly, Transparent Truth, DMS, SOS Team, National Disability, Disability Advisor, 

AiMediaOne. Help Advi=. Debt Help Express. SMG. Follow My Lead, Job Funnel, Insurance Guide, Complete Home Services. 

American Pollca Officers Alliance, Fit Funnel, FlndCredit, EZLlving, Direct Energy, Discount Power, Eligo Energy, Indra Energy, WGL 

Energy, Titan Gas & Power, Park Power, Utilities Marketing Group LLC, Nexxt. 

Case 8:23-cv-01575 Document 1-1 Filed 07/14/23 Page 3 of 5 PageID 25 

2 
besct-m iB4i com LAS VEGAS, NV 

1i' Name, you are a lmos t done. 

Your contact Information will be used for provfdlng quotes only. 

Address: 

Phone : e 

Bv cllek,ng Gel MY Ouolea, I l'Qf - 10 U... TMTDI! Qt' .Sft!'Yk<e •l'td Pmo.cy POiiey 

~ 

end •vlhonze ~-~Q 

\0 conl8<:1 ~ ebout 111uto 1 .... ,N,nc. end 00..r non-tnaur11nc>e 

o"•,.. b)' l9"9phone c10fl• !'Ind , • ..-1 ,....NO!J99 to llie numb•r I pr<,v!tt9d 

•bov• I •9'- to ~-,- te lwn>e1'<tlll'IQ ci•II• (llf'd --,-.corded ,...•••Iii•• Yla ,;,,n •utQ(ll,,tl9d phone •v•l•;.,n . • _.. ,1 my t•1<1op~.,, ""'"'h<H I• • mol>lle n"'m.t.i.<- tt>•I !• °""""UY 1 .. ,.., C>rl •nv (l,Ulole. f-.:ie,,..1 or Ql'>fPOr1't11 "OQ N(><I: e.,11• h ,i;I I un~<111•n<1 tt<o,u my cxi,n_,1 • oot l'I 

Pl)O<jlllo,n Qf ""roh"- or "">' gQQQ• or •CNVIO<JS 4'lt(I u,., I m,;,y NVQQ 

my Q00-.1 a t eny tl ...... l Vl'ld,o,-sU,,n(t tti.1 IJtAO(;Hor(ll mc1•~ •nd d•t• 

rot•• m.-y •ppty 

Cit y, Stat e , Z ip C o de: 

LAS VEGAS, NV, 69122 

Em a il: e 

Get My Quotesl 

8 Your Info I• Safe & a.cuf■, 

Wa,, t to finish thia over the phone? 

~ 888-237-8786 

92% 

Real Fact 

wo·ve holp&d 

8 4 , 6 5 2,. 5 6 6 

people save. We can 

help you too. 

g- YourC 

1 1998 HYUNDAI El~ntnt 

g- Cover J• 

State Mlnlm1,,1m 

g- Orfver Dlsaounta 

.~~ 

Case 8:23-cv-01575 Document 1-1 Filed 07/14/23 Page 4 of 5 PageID 26 

3 
best1.t~111k4i""" LAs veaAs. Nv 

B N a m e, you a re a lmost done. 

Vol#' contact lnlorm1;1tlon wlll be us.ad for provkjing quotoa only. 

Add ress: City. Stato. Zip Codo: 

Phone,: e 

p~-~•MlNKrKOE ~ 

Ry~ 0.-...... 0-0... I aoi-kt_.,.~ ~-sw ...... ...... ~ 

tdm .. -,__,.. .... to _____ _ 

~ Iii\-'....,._~ aNfW~I ~ ,0 ... - ID"~ ---~~~-lf-.,yt~ INIO'l,l9 1-,- ... -~~--·---­ ----~------,.--.,,y- o,_..."Og,NQ4c.ll"'.._! l~anQlhfiol""I'~•-• ......_.,a,.,.,,_flf...,OOod•cw_.__....,.._,_.,_ 

....,._ .. _....,_ l~W>dlt>,>1.-...-.,,...~..ngd,.o,CIO 

.. ,--)'~ 

• • • Auto ln•u••n<:• Comp•n••• I lo< ♦ 

LAS VEGAS. NV, 89122 

Email: C> 

Get M y Quotes! 

C Iii bo~tquolo ,t.,.-.. , r ::Ill- e ln< ogn,to ( :l) : 

~ Compt<>l•cl r ... 1o.. Q fmn,l ,. T,0110 t:::J Doc• t=J 'l'odot URL• R 

01....el o.t,,e.r,i,I 

Olr.cl Modl11 P11r1ners 

01,ec:1 P,op,i,rty & ca..,aliy 

Olt~ PtOl~ 8e<)u,flty 

01.-.c1w.-,.-.c,~•,..,o 

--

01..aounl ,,,__,_ ouot- 01ac.ovo,OPO 

"'"'" OOCAuto 

0oo Aulo lnaurlllna• l'l.genay 

Oout)i.~th,. 

O riVe Stnfllt1 W(lr..-amy 

Wont to nnl• h thia over the phone? 

~ 888-237-8786 

92% 

Real Fact 

Wo"v.hol~ 

8 4 , 6 5 24 5 6 6 

people -v• We can holp you 100 

~ You, 

1 199& MYUNOA.I Elent,. 

~ Ori ,or Dl•count• 

~~ 

ff Contoct 

a 

Top NV Provldors 

,A.State Farm 

9_.~ ...... ...._.I-0,..1D-~lf~VM'df1l'fmll~---of--..... --lO __ t,,y!f-. la<OU-,.,._I _ _.._,,._,,.._, -.,.,, .. .._.. ....... ..,.....11 .... upic, ...... -..-......,__ .,_ ..... ,._,......_.....,,,_,__,,_..._ ___ l......,_lil>c•~-o,IO--~ •~-~ ___ _,.,_au-, .. lhM_....,. __ .....,......,.._,....,..._.__._ ---~ ........ - -~,,,._,_,,.,,,_...,_.,..__,_ ._,,, ... __ ,_, ~,.,.,(1 ......... - _____ ,,a,;1_.,..._....,_ ____ .,, __ _.._. .... , ..... -

Case 8:23-cv-01575 Document 1-1 Filed 07/14/23 Page 5 of 5 PageID 27 

4 
_ _ __ __ 

---------------- ------------

JS 44 (Rev 04/21) Case 8:23-cv-01575 D~th\r~Sft'¥:~3 Page 1 of 2 PagelD 28 

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service ofpleadings or other papers as required by law, except as 

provided by local rules ofcourt. This form, approved by the Judicial Conference ofthe United States in September 1974, is required for the use ofthe Clerk ofCourt for the 

purpose ofinitiating the civil docket sheet. (SEE INSTRUCTIONS ONNEXT PAGE OF THIS FORM) 

I. (a) PLAINTIFFS DEFENDANTS 

United States of America Yodel Technologies, LLC; Robert W. Pulsipher 

(b} County ofResidence ofFirst Listed Plaintiff County ofResidence ofFirst Listed Defendant ~P~in~e=lla=s________ (EXCEPTIN US. PLAINTIFFCASES) (IN US PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USETHE LOCATION OF 

THE TRACT OF LAND INVOLVED 

(C} Attorneys Attorneys (IfKnown) (Firm Name, Address, and Telephone Number) 

Zachary Cowan, US DOJ Consumer Protection Branch, 

450 5th St. NW, Washington, DC 20002, 202-353-7728. 

II. BASIS OF JURISDICTION (Placean "X " inOneBoxOnly) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X"inOneBoxforPlaintiff 

(For Diversity Cases Only) and One Box/or Defendant) 

~ I US Government 0 3 Federal Question PTF DEF PTF DEF 

Plaintiff (US. Government Not a Party) Citizen ofThis State D I D Incorporated orPrincipal Place D 4 D 4 

ofBusiness InThis State 

0 2 US Government 0 4 Diversity Citizen ofAnother State D 2 D 2 Incorporated and Principal Place D 5 D 5 

Defendant (Indicate Citftenship ofParties in Item III) ofBusiness InAnother State 

Citizen or Subject ofa D 3 D 3 ForeignNation D 6 0 6 

Foreign Country 

IV. NATURE OF SUIT(Placean "X"inOneBoxOnly) Click here for: Nature ofSuit Code Descri tions. 

CONTRACT TORTS FORIIUURE./PENALTY BANKRUPTCY OTHER STATUTES r- PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure O 422 Appeal 28 USC 158 375 False Claims Act 

120Marine 3 10 Airplane 0 365 Personal Injury - ofProperty21 USC 881 0 423 Withdrawal 376 Qui Tarn (31 USC 

130 Miller Act 3 15 Airplane Product Product Liability 690 Other 28 USC 157 3729(a)) 

140 Negotiable Instrument Liability 0 367 Health Care/ INTELLECTUAL 400 State Reapportionment 

D 150 Recovery ofOverpayment 320 Assault, Libel & Pharmaceutical 1=-P_R_O_P_ER_ TY_ _RI_G_BT_S_-t-l 410 Antitrust 

& Enforcement ofJudgment Slander Personal Injury 0 820 Copyrights 430 Banlcs and Banking B151 Medicare Act 330 Federal Employers Product Liability D 830 Patent 450 Commerce ' 

152 Recovery ofDefaulted Liability D 368 Asbestos Personal D 835 Patent - Abbreviated 460 Deportation 

Student Loans 340Marine Injury Product New Drug Application 470 Racketeer Influenced and 

(Excludes Veterans) 345MarineProduct Liability 1------,,..,.,,,=,------1,D 840 Trademark Corrupt Organizations D 153 Recovery ofOverpayment Liability PERSONAL PROPERTY i,,,,,,-=-:-:,-=--:-!-LAB ..,...., O="R ,.__,,....,_--IID 880 Defend Trade Secrets 480 Consumer Credit 

ofVeteran's Benefits 350 Motor Vehicle B370 OtherFraud 710 FairLabor Standards Act of20J6 (15 USC 1681 or 1692) D 160 Stockholders' Suits 355 Motor Vehicle 371 Truth in Lending Act 1----,,=-:,,,.,.,,..,,,.===,---t~ 485 Telephone Consumer D 190 OtherContract Product Liability D 380 Other Personal 720 Labor/Management SOCIAL SECURITY ProtectionAct B195 Contract Product Liability 360 Other Personal Property Damage Relations ~ 861 HlA (1395ft) 490 Cable/Sat TV 

196 Franchise Injury D 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/ 

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange 

Medical Malpractice Leave Act 864 SSID Title XVI X 890 Other Statutory Actions 

REAL PROPERTY --1-...,.,...;;,,..;,;;;~,.;.;;,;~.,.,_-i--,;;.~;..;.;;-=.;;.;;.;;;.;.;;,;.;.;;.;,.;~~ CMLRIGHTS PRISONER PETITIONS 790 Other Labor Litigation D 865 RSI (405(g)) 891 Agricultural Acts 

2 10 Land Condemnation 

D 220 Foreclosure §230 Rent Lease & Ejectment 

240 Torts to Land 

245 Tort Product Liability

D 290 All Other Real Property 

440 Other Civil Rights Babe.is 01rpus: 791 Employee Retirement 893 Environmental Matters 

441 Voting Income Security Act 1---FED--E-RAL--T-AX SUITS 895 Freedom ofInformation 

442 Employment 

463 Alien Detainee 

510 Motions to Vacate D 870 Taxes (US Plaintiff Act 

443 Housing/ Sentence or Defendant) 896 Arbitration 

Accommodations 530 General D 871 IRS-Third Party 899 Administrative Procedure 

445 Amer w/Disabilities - 535 Death Penalty 1----11\=IMI=G"'RA ,...,.,TI= o,... N,----1 26 USC 7609 Act/Review or Appeal of 

Employment Other: 462 Naturalization Application Agency Decision 

446 Amer w/Disabilities - 540 Mandanrus & Other 465 Other hnmigration 950 Constitutionality of 

Other 550 Civil Rights Actions State Statutes 

448 Education 555 Prison Condition 

560 Civil Detainee -

Conditions of 

Confinement 

V. ORIGIN (Placean "X"inOneBoxOnly) 

~ I Original D2 Removed from Remanded from D 4 Reinstated or D 5 Transferred from D 6 Multidistrict D 8 Mu!tidistrict 

Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -

(specify) Transfer Direct File 

Cite the U.S. Civil Statute under which you are filing (Do 110/ citej11risdictio11al staf11/es 1111/ess diversiM : 

FTC Act, 15 U.S.C. § 45, et seq., and Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. § 6105, et seq. VI. CAUSE OF ACTION 1-----------------------------------­ Briefdescription ofcause: The United States seeKs monetary civil penalties, permanent injunc ion, and other relief for alleged violations of the FTC Act and TSR 

VII. REQUESTED IN 0 CHECK IF THIS IS A CLASS ACTION DEMAl'ID S CHECK YES only ifdemanded in complaint: 

COMPLAINT: UNDERRULE23, F.R.Cv.P. JURY DEMAND: Yes O No 

VIII. RELATED CASE(S) IF ANY (See instroctions): 

JUDGE DOCKETNUMBER 

DATE SIGNATURE OF ATTORNEY OF RECORD 

7/1 4/2023 Isl Zachary L. Cowan 

FOR OFnCE USE ONLY 

RECEIPT# AMOUNT APPLYING IFP JUDGE MAG JUDGE 
JS 44 Reverse (Rev 04/21) Case 8:23-cv-01575 Document 1-2 Filed 07/14/23 Page 2 of 2 PageID 29 

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44 

Authority For Civil Cover Sheet 

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as 

required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is 

required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of 

Court for each civil complaint filed. The attorney filing a case should complete the form as follows: 

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use 

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then 

the official, giving both name and title.

 (b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the 

time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land 

condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) 

(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting 

in this section "(see attachment)". 

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X" 

in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below. 

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here. 

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. 

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment 

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes 

precedence, and box 1 or 2 should be marked. 

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the 

citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity 

cases.) 

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this 

section for each principal party. 

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code 

that is most applicable. Click here for: Nature of Suit Code Descriptions. 

V. Origin. Place an "X" in one of the seven boxes. 

Original Proceedings. (1) Cases which originate in the United States district courts. 

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. 

Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing 

date. 

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date. 

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or 

multidistrict litigation transfers.

Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. 

Section 1407. 

Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket. 

PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to 

changes in statute. 

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional 

statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service. 

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P. 

Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction. 

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded. 

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket 

numbers and the corresponding judge names for such cases. 

Date and Attorney Signature. Date and sign the civil cover sheet.