IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

KEVIN TRUDEAU, 

 Defendant. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Case No. 03-C-3904 

Hon. Robert W. Gettleman 

FEDERAL TRADE COMMISSION’S RESPONSE TO TRUDEAU’S MOTION TO 

TRAVEL 

Defendant Kevin Trudeau has moved for permission to leave the Northern District of 

Illinois to attend a Global Information Network (“GIN”) event in Boston, MA from May 22 to 

28, 2023. ECF No. 1031. As the FTC has emphasized—and the Court concluded in 2013—

resuming Trudeau’s coercive incarceration is the only way to ensure he complies fully with the 

Court’s 2010 Order to Pay, ECF No. 372. Given that the proposed travel is more than three 

months away, and a considerable time after the March 8-9 proceedings, the FTC asks the Court 

to defer ruling on Trudeau’s request at least until those proceedings conclude. Although there is 

already a sufficient basis to resume coercive incarceration, deferring the decision on Trudeau’s 

travel motion will afford the Court an opportunity to consider additional evidence at the hearing 

that may affect the Court’s decision. 

Furthermore, additional criminal proceedings may complicate Trudeau’s ability to 

travel.1

 Among other things, criminal consequences may stem from Trudeau’s contemptuous 

1

 This response applies only to the instant motion to travel to Boston, MA in the civil matter and does not alter the 

FTC’s position with respect to the Motion for Permission to Travel Internationally, filed in United States v. Trudeau, 

No. 10-cr-886 (N.D. Ill.). 

Case: 1:03-cv-03904 Document #: 1041 Filed: 02/17/23 Page 1 of 3 PageID #:21874
failure to appear in the civil case. Specifically, that contempt likely violated Trudeau’s “Special 

Conditions of Supervision,” including the conditions requiring Trudeau to “cooperate in the 

collection of civil judgments issued against him” and to “abide by all court orders filed in any 

civil lawsuits in which he is named.” United States v. Trudeau, No. 10-cr-886 (N.D. Ill.) 

(Document # 173 at 5). Consequently, the Court should defer ruling on the Motion to Travel, 

given the pendency of these issues. 

 Finally, to the extent the Court ultimately permits Trudeau’s travel, the Court should 

make clear that, pursuant to the Court’s Order To Pay, Trudeau must document his earnings from 

the seminar and turn them over to the FTC immediately. Notably, Trudeau suggests turning over 

only 40% of his salary and bonuses to the FTC, including only 40% of what he may earn at the 

GIN event. ECF No. 1031 at 2. However, the Court ordered Trudeau to pay $37,616,161 

“forthwith” (ECF No. 372), and endorsing any lesser arrangement impermissibly modifies that 

order. See Fed. R. Civ. P. 60(b).

Dated: February 17, 2023 Respectfully Submitted, 

/s/ ___________________ 

Jonathan Cohen (jcohen2@ftc.gov) 

Crystal D. Ostrum (costrum@ftc.gov) 

Iris Micklavzina (imicklavzina@ftc.gov) (pro 

hac pending) 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. CC-9105 

Washington, DC 20580 

Phone: 202-326-2551 (Cohen); -3405 

(Ostrum); -2996 (Micklavzina)

 

Case: 1:03-cv-03904 Document #: 1041 Filed: 02/17/23 Page 2 of 3 PageID #:21875
CERTIFICATE OF SERVICE 

I, Crystal Ostrum, hereby certify that on February 17, 2023, I caused to be 

served true copies of the foregoing by electronic means, by filing such documents through the 

Court’s Electronic Case Filing System, which will send notification of such filing to: 

Kimball Richard Anderson 

kanderson@winston.com 

Giel Stein 

gstein@clarkhill.com 

Nicole Prefontaine 

nprefontaine@clarkhill.com 

Jonathan Lippner 

jlippner@clarkhill.com 

/s/ Crystal Ostrum 

Crystal Ostrum (costrum@ftc.gov) 

Attorney for Plaintiff 

Federal Trade Commission 

Case: 1:03-cv-03904 Document #: 1041 Filed: 02/17/23 Page 3 of 3 PageID #:21876