IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FEDERAL TRADE COMMISSION, ) 

 ) 

 Plaintiff, ) 

 ) 

vs. ) Case No. 03 C 3904

 ) 

KEVIN TRUDEAU, ) 

 ) 

 Defendant. ) 

MEMORANDUM OPINION AND ORDER

MATTHEW F. KENNELLY, District Judge:

The Federal Trade Commission filed this lawsuit against Kevin Trudeau over 

twenty-one years ago, in 2003, alleging deceptive practices.1 It was not the first time 

the FTC had sued Trudeau. In 1998, the FTC sued Trudeau for deceptive practices and 

false advertising in connection with a number of products he promoted through 

infomercials. FTC v. Trudeau, No. 98 C 168 (N.D. Ill.). Trudeau settled that case and 

paid $500,000 to compensate the products' purchasers. He also agreed to an injunction 

that included, among other things, a provision barring him from making representations 

about the benefits or performance of any product without "competent and reliable 

evidence" of his claims. 

The present lawsuit involved similar conduct and included a claim that Trudeau 

had violated the injunction in the earlier case. A consent order was entered in 

1 This summary of the history of the litigation is taken from previous court rulings in the 

present case, including by the Seventh Circuit, and from a joint status report filed by 

Trudeau and the government in his criminal case in July 2023.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 1 of 41 PageID #:43898
2

September 2004. It ordered Trudeau to pay $2 million for consumer redress and 

prohibited him from advertising any products in infomercials. But it allowed Trudeau to 

participate in infomercials for publications, including his own publications, so long as the 

publication did not refer to any other product he was marketing. The order provided, 

however, that infomercials for a book could not misrepresent the book's contents. 

In 2007, Trudeau appeared in infomercials promoting his book The Weight Loss 

Cure "They" Don't Want You To Know About. The FTC sued, contending that the 

infomercials misrepresented the contents of the book and thus ran afoul of the 2004 

consent order. The revenues from sales of the book amounted to about $37 million 

from infomercial sales and $9 million from retail sales. Judge Robert Gettleman, to 

whom the case was assigned, found that Trudeau had made misleading statements and 

found him in contempt. See FTC v. Trudeau, 567 F. Supp. 2d 1016 (N.D. Ill. 2007). 

Litigation ensued over the appropriate remedy. This is summarized in a later decision 

by the Seventh Circuit. See FTC v. Trudeau, 579 F.3d 754, 761-62 (7th Cir. 2009). The 

bottom line is that Judge Gettleman initially ordered Trudeau to pay the FTC about $5.1 

million to disgorge some of the royalties he had received from sales of Weight Loss 

Cures. Judge Gettleman's order also banned Trudeau from doing any infomercials for a 

three-year period. See FTC v. Trudeau, 572 F. Supp. 2d 919, 925-26 (N.D. Ill. 2008). 

Several months later, however, Judge Gettleman increased the monetary award to 

$37.6 million, "representing a reasonable approximation of the loss consumers suffered 

as a result of [Trudeau's] deceptive infomercials." Order of Nov. 4, 2008 (dkt. 219).

Trudeau appealed. The Seventh Circuit overruled his challenges to Judge 

Gettleman's contempt finding but remanded for a better explanation of the $37.6 million 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 2 of 41 PageID #:43899
3

monetary award. Trudeau, 579 F.3d at 768, 769-75. The court also vacated the threeyear infomercial ban, concluding that it was an inappropriate remedy for civil contempt 

because it did not give Trudeau an opportunity to purge the contempt. Id. at 776-79. 

In 2010, on remand, Judge Gettleman found that "given Trudeau's history of 

contemptuous conduct, the fact that his misrepresentations were so widely 

disseminated, and the fact that disgorgement of ill-gotten-gains would be wholly 

ineffectual, . . . a sanction based on consumer loss is the only appropriate remedy." 

FTC v. Trudeau, 708 F. Supp. 2d 711, 715 (N.D. Ill. 2010) (dkt. 355). Judge Gettleman 

further explained that the $37,616,161 sanction represented "the cost of the book 

purchases through the '800' telephone number displayed during the deceptive 

infomercial . . ., along with shipping and handling costs, less returns to consumers." Id. 

at 717. The order provided that "[a]ny funds remaining after such reimbursement to 

consumers, less taxable costs and other costs of disbursement approved by the court, 

shall be returned to Trudeau . . . ." Id. at 729. Judge Gettleman also modified the 

injunction he had previously imposed, prohibiting Trudeau from misrepresenting the 

benefits, performance or efficacy of any product, program, or service in any infomercial"; 

reinstating certain compliance reporting requirements originally imposed in 2004; and 

requiring Trudeau to post a $2 million performance bond, as security for any failure to 

pay a judgment resulting from a violation of the injunction's terms, before he could 

produce or air any infomercials. Id. at 724.

On appeal, the Seventh Circuit affirmed Judge Gettleman's order in its entirety. 

FTC v. Trudeau, 662 F.3d 947 (7th Cir. 2011). In particular, the court found that the 

$37.6 million figure "correctly measures the loss" and indeed was "conservative." Id. at 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 3 of 41 PageID #:43900
4

950. 

In September 2013, Judge Gettleman found that Trudeau had concealed assets 

to avoid paying the contempt judgment, and he ordered coercive incarceration to 

compel full disclosure. Judge Gettleman suspended this order in March 2014 to allow 

Trudeau to begin serving a sentence for criminal contempt, discussed in the next 

paragraph.

Earlier, in April 2010, after he imposed the original civil contempt sanction, Judge 

Gettleman entered an order directing Trudeau to show cause why he should not be held 

in criminal contempt of court for the same conduct that had led to the civil contempt

finding. The U.S. Attorney's Office agreed to prosecute the case, and the criminal 

matter was transferred to Judge Ronald Guzman. A jury convicted Trudeau in 2013, 

and Judge Guzman imposed a below-Guidelines sentence of ten years imprisonment. 

As indicated in the previous paragraph, Judge Gettleman suspended his civil coercive 

incarceration of Trudeau in March 2014 so that he could serve the sentence for criminal 

contempt. On appeal from the criminal contempt conviction, the Seventh Circuit 

affirmed. United States v. Trudeau, 812 F.3d 578 (7th Cir. 2016).

Trudeau was released from prison in or about January 2022 and began to serve 

a term of supervised release, which is under the supervision of another judge in this 

district. 

Back to the present case. In 2013, at the suggestion of Trudeau, Judge 

Gettleman appointed a receiver. By 2015, the receiver had collected from Trudeau a 

little over $15 million to be applied toward the $37.6 million contempt judgment. The 

Court will discuss the disposition of the $15 million and other payments by Trudeau later 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 4 of 41 PageID #:43901
5

in this decision.

After Trudeau was released from prison in 2022, proceedings in the present case 

resumed. The FTC contended that Trudeau had hidden assets and was impeding 

collection of the civil contempt judgment. It sought further coercive incarceration. 

Trudeau contended that he was not hiding assets. In June 2023, after discovery and an 

extended evidentiary hearing, Judge Gettleman found that Trudeau had paid about $2.6 

million toward the judgment during 2023, most of which had come from donations by 

members of his fan club, the Kevin Trudeau Fan Club (KTFC). Judge Gettleman also 

stated that:

[The] evidence presented at the hearings demonstrates that Trudeau 

remains in contempt of the judgment order, and would justify any 

appropriate remedy, including coercive incarceration, that the court might 

impose to bring about the desired result of full payment of the judgment. 

Nevertheless, in the exercise of the court’s discretion to fashion such a 

remedy, it must consider the probable effectiveness of any sanction. In 

the instant case, coercive incarceration at this time would appear to be 

counterproductive, because Trudeau has demonstrated that he has the 

ability to earn substantial compensation and receive gifts from donors that 

could be used to pay the balance of the outstanding judgment (which is in 

excess of $17 million). That ability would be significantly diminished, if not 

eliminated, were Trudeau to resume coercive incarceration at this time.

Order of June 6, 2023 (dkt. 1146) at 2-3. Judge Gettleman ordered Trudeau to (among 

other things):

• Pay the FTC seventy-five percent of all monies received from GIN Unite, 

Inc. or its affiliates, less income taxes;

• Pay the FTC one hundred percent of all monies he received from any 

other source, less income taxes;

• Submit bimonthly verified statements of all monies received and 

expenses and disbursements by him and KTFC, "along with the status of any 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 5 of 41 PageID #:43902
6

business relationship he has entered into or intends to enter into"; and

• Before agreeing to any business relationship, submit his intended 

activities to the FTC for approval, followed by good faith consultation, after 

which either party could move the Court for determination.

Id. at 3-4. The same order stated that "Trudeau is prohibited from acting through 

nominees." Id. at 4.

A later order by Judge Gettleman made some slight modifications to the June 6, 

2023 order, including the details of the reporting requirements, and it (among other 

things):

• Authorized KTFC to "retain funds to cover its reasonable operating 

expenses, which Trudeau shall itemize in his Reports. Any funds net of such 

expenses and those amounts paid to Trudeau will be paid to the FTC directly by 

the KFTC or paid to Trudeau so that he can pay them to the FTC net of all taxes 

at the time of his bi-monthly Reports"; 

• Precluded Trudeau from "the practice of tithing until further order of this 

court"; and

• Authorized Trudeau to establish "a new legal defense fund separate from 

KTFC," with "the sole purpose" to collect contributions "to pay Trudeau's legal 

fees and costs and to remit such contributions to Trudeau's counsel," with a bimonthly requirement to report on the fund's income and expenses.

Order of June 16, 2023 (dkt. 1151) at 1-2 (emphasis added).

On August 3, 2023, Judge Gettleman entered an order, on Trudeau's motion for 

approval of business relationships (dkt. 1154), that among other things provided the 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 6 of 41 PageID #:43903
7

following:

• Trudeau was authorized to enter into an agreement with FortyFPS Films 

and sell certain books;

• Any future books "cannot promote the sale of any branded or 

trademarked products, programs or services pursuant to the consent order 

entered in September 2004";

• Trudeau was required to pay any tax refunds to the FTC in partial 

satisfaction of the judgment;

• "The $2 million infomercial bond shall stay in place. Should Trudeau 

seek relief from this requirement, he must submit all proposed infomercials to 

the FTC and the court for approval, as he has agreed to do."

• All funds received from investment income are assets subject to payment 

on the judgment;

• Trudeau "remains prohibited from entering into any personal 

endorsement agreements for Natural Cures.com"; and

• Trudeau "may enter into an endorsement agreement for World's Best 

Nutritionals and Organics, Inc., but must submit any commercial activities in 

which he intends to participate to the FTC for approval. Lacking such approval 

he may bring the matter to the attention of the court for the court's approval."

Order of Aug. 3, 2023 (dkt. 1185) at 1-2.

In late September 2023, the case was reassigned to the undersigned judge after 

Judge Gettleman recused himself. Since that time, the parties' filings have been 

voluminous enough to fill a small pickup truck. There are, depending on how one 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 7 of 41 PageID #:43904
8

counts, close to a couple dozen contested matters before the Court, including 

objections by the FTC to various aspects of Trudeau's bimonthly reports. As the filings 

multiplied, the Court saw the contested matters as facets of a single whole, thus 

making it inadvisable to rule on each point separately. Rather, the Court determined, it 

made sense to rule on all the contested issues together. Unfortunately, the Court has 

taken far longer than it hoped to rule on the disputed matters. This is in no small part 

because there are no simple solutions on many of the disputed points. And as time 

has passed, more disputes have arisen, making the task more difficult. The Court has 

endeavored in this order to address everything, though as will be seen several items 

will require further action.

Stepping back a bit and looking at the big picture, the current state of affairs is 

not good. No one is satisfied. The FTC continues to believe that Trudeau is hiding 

assets and otherwise evading payment of the coercive sanction; it has repeatedly 

asked the Court to reimpose coercive incarceration. The FTC is also quite dissatisfied 

with the provision of Judge Gettleman's June 2023 order that requires Trudeau to 

submit new business relationships to the FTC for preapproval. Though the FTC did not 

seek reconsideration of the order at the time and did not appeal following the order's 

entry, it contends that this provision is a legally inappropriate imposition upon the 

agency. Instead the FTC wants the Court to appoint a monitor, to be paid for from 

funds collected from Trudeau, to vet his proposed business ventures and his finances. 

Alternatively, it asks the Court to eliminate the preapproval requirement.

Trudeau, too, is dissatisfied with the current state of affairs. He has sought 

approval for a number of new ventures and contends the FTC is stonewalling him. He 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 8 of 41 PageID #:43905
9

wants to be able to travel internationally to pursue moneymaking ventures, which he 

has been precluded from doing since 2013. He wants to be able to pay accountants 

from the legal defense fund and wants his related entities to be able to pay legal 

expenses from their retained earnings. And Trudeau contends that the FTC's litigation 

conduct has inappropriately imposed undue burdens on him and has unfairly cast him in 

a bad light. 

The Court does not find the current state of affairs to be satisfactory either:

• Even though well over $17 million has been collected from Trudeau in 

various ways, only about $5.4 million has actually been distributed to consumers. 

And the flow of funds from Trudeau to the FTC for payment of the judgment 

seems to have slowed to a relative trickle at this point.

• Everyone seems to be making out pretty well, except for the consumers 

harmed by Trudeau's misconduct. The receiver and fund distribution 

administrator appointed by the FTC have been paid quite handsomely (more on 

this below). A very significant amount of money has been raised by Trudeau for 

legal defense and has been paid to his lawyers. And Trudeau himself appears to 

be doing quite well for someone facing a $37.6 million contempt judgment. Half 

the rent on his home is being paid by certain of his business entities that have 

been accumulating money without any payments from those amounts to the 

FTC. Many of the furnishings purchased for the "home office" and thus 

essentially for the benefit of Trudeau appear to be high-end items that, at least on 

the surface, appear to go beyond any reasonably legitimate needs for a basic 

home business office. That aside, Trudeau has been spending an almost 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 9 of 41 PageID #:43906
10

absurdly large amount of the entities' money on cigars (supposedly giveaways

used for promotional purposes). And then there is the $6,600 set of golf clubs 

purchased by the businesses for Trudeau. That may not be a Rolls-Royce-level 

set of clubs, but it's close to a Bentley.2 And all of this has happened even as 

Trudeau has, over time, paid dwindling amounts to the FTC on the judgment. 

• The current setup imposes a significant burden on everyone, including the 

Court. The best examples of this are the bimonthly reports by Trudeau and the 

resulting objections and replies, as well as the business relationship preapproval 

process. 

• That preapproval process has not worked in an optimal fashion. It was 

presumably Judge Gettleman's intention that the process would result in 

agreement on some proposed relationships and some winnowing of others via 

modification or voluntary withdrawal. But that has not happened. With a 

relatively modest exception or two, nothing has actually gotten approved. This 

may be for good and valid reasons, but the bottom-line consequence at this point 

is essentially that no money from new business activities has gone to pay the 

judgment. And all of the disputes have been put on the plate of the Court, which 

is ill-equipped to make an advance determination of the propriety of Trudeau's 

proposed business ventures.

2 Assuming that Trudeau complies with the Rules of Golf, which allow a player to carry 

no more than 14 clubs, see Rules of Golf 4.1(b), 

https://www.usga.org/content/usga/home-page/rules/rules-2019/players-edition/rule4.html (last visited Sept. 10, 2024), this means that the price of each club was, on 

average, $470. The Court can attest that, absent gold plating, that's quite a lot, even for 

"custom fit" clubs. 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 10 of 41 PageID #:43907
11

• Distribution to consumers of the amounts collected from Trudeau on the 

judgment has also been less than optimal, to put it mildly. Over $15 million was 

collected from Trudeau by the receiver; this does not count amounts paid in 

2023-24 from Trudeau's earnings in those years. Of the $15 million, the receiver 

was paid $6.8 million (about forty-six percent of the total), and the administrator

the FTC retained to make distributions to consumers was paid just short of $2.5 

million (about seventeen percent). Only about $5.4 million—just thirty-six percent 

of the amount collected—went to consumers, most of whom got about $9 each.3 

To a disinterested observer, that seems rather paltry. 

As the Court has indicated, there are no obvious solutions to these problems. In 

fact, it's not clear there are any real solutions. Everything that is in place and that has 

been proposed has its downside.

With this rather dim and pessimistic introduction, the Court addresses what it 

believes are all of the parties' disputes.

A. Periodic financial reports by Trudeau

The Court begins with what it considers to be the most cumbersome set of 

disputes: resolution of issues arising from the bimonthly financial reports filed by 

Trudeau pursuant to Judge Gettleman's June 2023 order. The protocol is: Trudeau files 

a verified report; the FTC generally files a response, including objections; and Trudeau 

replies to any objections.

1. November 2023 report (covering August-September 2023)

3 Some got less—about $5—because they did not cash the second check. Around 

550,000 consumers did not cash even the first check and thus were not sent a second 

one.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 11 of 41 PageID #:43908
12

The FTC's response to Trudeau's November 2023 report is at docket 1243; 

Trudeau's reply is at docket 1250. The major points are as follows.

a. The FTC notes that per the report, Trudeau saved and put away about 

$56,000 between January and June 2023 without notifying the Court. The FTC 

characterizes this as a slush fund and suggests it is inappropriate. But as Trudeau 

correctly points out, this money was made in the period before entry of the June 6, 2023 

order and thus was not subject to that order's restrictions. Trudeau's access to this 

significant pot of money is a factor appropriately considered in assessing his

compliance with the judgment as well as how to proceed moving forward, but it is not a 

basis for imposition of any sort of a sanction or penalty.

b. The FTC notes that during the reporting period, Trudeau received about 

$143,000 in net personal income and paid about $122,000 to the FTC on the judgment. 

This left $21,000 that he kept. The FTC notes that Trudeau spent only about half of the 

$21,000. Again, however, the order permits Trudeau to keep 25 percent of the income 

paid to him by GIN Unite, and that's what the $21,000 represents. There is no provision 

in the current order requiring him to turn over the unspent amounts. Again, this may be 

a factor appropriately considered in any further action the Court may take, but there is 

no provision in the June 6 order that requires Trudeau to pay this money over.

c. The FTC notes that per the report, KTFC brought in around $243,000 

during the reporting period and spent around $145,000, leaving about $98,000. Of that, 

Trudeau appears to have spent about $65,000 for legal bills, leaving $32,000 on the 

table. Trudeau's company Trudeau Consulting Training and Coaching (TCTC or 

Trudeau Consulting) brought in around $480,000 and spent around $257,000, leaving 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 12 of 41 PageID #:43909
13

approximately $223,000. The FTC argues that the leftover money all should have to be 

paid on the contempt judgment and that these entities should not be permitted to 

accumulate reserves.

In response, Trudeau says that the June 6 order only requires Trudeau himself to 

pay over a percentage of his income from GIN Unite and that "[n]o order requires any of 

Trudeau's businesses to pay redress directly to the FTC, nor does any order specify 

how often these businesses must pay Trudeau so that he can forward those payments

to the FTC." Dkt. 1250 at 4. That may be correct at this point for Trudeau Consulting, 

but it's flat wrong with respect to KTFC: Judge Gettleman's June 2023 order, though 

allowing KTFC to retain funds to cover reasonable operating expenses, specifically 

required KTFC to pay over to the FTC, or Trudeau to send to the FTC, "any funds net of 

those expenses." And regarding Trudeau Consulting, there is no order permitting it to 

retain funds for reasonable operating expenses: it was up to Trudeau to ask for that, 

and he hasn't. The Court intends to rectify this and will discuss the point a bit later in 

this order.

More broadly, Trudeau argues that Judge Gettleman permitted the businesses to 

retain funds to cover reasonable operating expenses. He contends that if these entities 

were required to, in effect, empty their accounts every two months as the FTC seems to 

contend, the businesses would not be able to meet expenses and thus would have to 

cease operating. The Court will return to these points later in this order but notes, 

again, that there appears to be no order at this point allowing Trudeau Consulting to 

retain funds for operating expenses, let alone setting the terms upon which it may do 

that.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 13 of 41 PageID #:43910
14

d. In the same vein, the FTC notes that from June 6 through October 8, 

2023, Trudeau's businesses KTFC and Trudeau Consulting took in a total of about $1.5 

million (KTFC about $440,000; Trudeau Consulting about $994,000) but paid only 

$92,000 to Trudeau. The FTC says that at least some of what the business are paying 

out for "business expenses" also personally benefit Trudeau, e.g., payment of half his 

rent and payment of his phone bills. Again, the Court will return to these points below.

There are also disputes about particular expenses, but the Court does not regard 

it as a wise use of its time to litigate these on an micro (item-by-item) basis.

e. The FTC contends that Trudeau's report reflects that he is pursuing 

unapproved business activities: (1) a naturalcures.com celebrity endorsement 

agreement for which he has not sought approval; (2) a new entity called World's Best 

Nutritionals & Organics to sell supplements (the FTC notes that Judge Gettleman 

allowed Trudeau to pursue this business generally, subject to approval for specific 

activities, but says that Trudeau has sought no such approvals as of the report date); (3) 

a reference to unapproved activities by Trudeau Consulting; (4) $10,000 in unexplained 

"affiliate income"; (e) supposedly inappropriate health-related claims being made by 

KTFC; and (f) a potential podcast.

Trudeau has the better of these points, at least as of time of the November 2023 

report and the ensuing briefing. The report appears to identify only one current activity 

as of the date of the report, a seminar that the FTC appears to have approved. 

Everything else was, at that point, on the if-come and did not involve any current 

business activity as of the date of the report. On the "health claims" point, the Court 

agrees that the FTC's objection includes no evidence that Trudeau was running afoul of 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 14 of 41 PageID #:43911
15

the injunction or any other order. As for the $10,000 payment by KTFC, Trudeau 

explains this reimbursed a GIN Unite employee for a fee he paid for a Trudeau seminar 

even though he worked the seminar as a staff member. That explanation appears 

adequate to the Court.

f. The FTC's submission ends with a request to the Court to: (1) modify the 

provision of the order allowing Trudeau to keep 25 percent of his income from GIN; (2) 

require documentation of any expense paid by another person or entity that benefits 

Trudeau; (3) clarify the appropriate amounts set aside by Trudeau for estimated taxes; 

and (4) preclude the Trudeau legal defense fund from paying accountants and experts. 

The tax withholding issue was fixed, at least prospectively, in 2023 after Trudeau 

retained a new accountant. The accountants/experts issue is the subject of a separate 

motion, addressed below. The other two points will be addressed later in this decision 

as part of a broader discussion.

Trudeau, in his reply, complains about the time and effort needed to address the 

FTC's objections, which he says were largely lacking in merit. He asks the Court to 

impose a good faith consultation requirement as a precondition to assertion of an 

objection to a financial report. The Court will address this later in this order.

2. December 2023 report (covering October-November 2023)

The FTC's response to Trudeau's December 2023 report is at docket 1255; 

Trudeau's reply is at docket 1267. The major points are as follows.

a. Regarding the businesses' retention of funds for future operating 

expenses, the FTC points out that Judge Gettleman's June 6, 2023 order allowed KTFC 

to do this, but not other businesses (for example, Trudeau Consulting). The FTC 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 15 of 41 PageID #:43912
16

acknowledged that it agreed at the time not to oppose such a request, but it notes that 

this did not relieve Trudeau from asking for a modification of the Court's order—which 

he never did. The FTC says that now, based on its view of the track record in this 

regard, it would oppose a "retention of funds" modification for Trudeau Consulting 

unless significant restrictions are imposed—but it does not say what sorts of restrictions 

it proposes.

Trudeau does not respond to this point in any meaningful way. The FTC is 

correct that Trudeau Consulting does not have an order allowing it to retain funds for 

operating expenses. It might make sense to enable this, but it was and is incumbent 

upon Trudeau to make the request. Due to the absence of any order allowing it, the 

Court hereby bars Trudeau Consulting from retaining funds on a month-to-month basis 

pending the granting of a motion by Trudeau to modify the Court's prior orders 

accordingly, and in the interim the Court bars Trudeau Consulting from disposing of or 

dissipating any funds or other assets pending further order of court. Given this

(presumably temporary) bar, it is in Trudeau's interest to get any such motion on file as 

promptly as possible. The Court will set a prompt hearing once Trudeau files the 

motion.

b. The FTC notes in its objections to the December 2023 report that the 

report does not contain any separate accounting for the Trudeau legal defense fund 

authorized by Judge Gettleman; rather it just appears as a line item on KTFC's income 

statement. The FTC points out that the order required this account to be held 

separately. In his response, Trudeau has established to the Court's satisfaction that 

there is in fact a separate account for the legal defense fund. It also appears that as of 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 16 of 41 PageID #:43913
17

the date of the report, any payouts from the fund had gone to the two law firms 

representing Trudeau, Clark Hill and Winston & Strawn. Trudeau agreed in his reply, as 

requested by the FTC, to itemize the sources of legal defense fund contributions. The 

Court directs Trudeau to do this consistently going forward.

c. The FTC claimed in its response that Trudeau did not provide supporting 

bank statements; did not provide documentation for what appear to be "loans" from 

Trudeau to Trudeau Consulting, another amount owed by Trudeau Consulting, and an 

amount loaned to World's Best Nutritionals; and did not provide receipts for certain 

expenses questioned by the FTC. 

It does appear, as Trudeau says in his response, that bank statements were

turned over—but were converted to spreadsheets as provided in the Court's order—and 

that the so-called loans were in fact disclosed. As for receipts, Trudeau's response 

likewise appears sufficient regarding when, currently, those are and are not required. 

The Court is willing to entertain a request to modify the order in an appropriate way to 

require greater itemization and documentation for expenditures, at least significant 

ones.

d. The FTC says, in a similar vein, that the reports do not include sufficient 

detail on certain expenditures, for example, $54,000 spent on computers that is 

identified as a single line item with no supporting detail. Trudeau did not directly 

respond to this point. The Court directs Trudeau to provide, within ten days of this 

order, a supplement to the report, itemizing the amounts spent on computers identified 

in this particular report (specifically, listing all items purchased and the price for each—a 

copy of any receipts covering the purchases will suffice as the disclosure so long as it 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 17 of 41 PageID #:43914
18

itemizes what was purchased). The Court notes that the $54,000 amount seems 

relatively high, so it looks forward with interest to the supporting details. 

e. The FTC also says that the report does not include sufficient information 

on other current and anticipated business ventures, for example World's Best 

Nutritionals. This point is answered adequately in Trudeau's response. See dkt. 1267

at 9-10.

f. The FTC acknowledges that Trudeau has complied with the June 2023 

order's requirement to pay over 75 percent of his GIN income for consumer redress. It 

points out, however, that Trudeau has obtained benefits that far exceed the remaining 

25 percent, via items paid by the entities as business expenses that benefit Trudeau 

personally, including one or more suits, Uber rides to and from court, fancy dinners paid 

for by the entities, and so on. 

In reply, Trudeau says (as he did in an earlier response) that the June 2023 order 

does not require the businesses to pay the FTC and does not tell them how often they 

have to pay funds to Trudeau or in what amounts. (As the Court has noted, this is just 

plain wrong regarding KTFC.) He also repeats his point that if the businesses cannot 

retain funds for operating expenses, they will not be able to operate. 

All of this suggests that it would be appropriate to modify the June 2023 order to 

require the Trudeau-controlled entities to pay out all or a specified proportion of their 

retained earnings (net of reasonable business expenses) to Trudeau to pay to the FTC,

or directly to the FTC, for payment on the contempt judgment. The existence of 

relatively large amounts of retained funds is also a factor appropriately considered in 

connection with other motions filed by the parties, as discussed below. Separately, the 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 18 of 41 PageID #:43915
19

Court notes that the current arrangement in effect incentivizes Trudeau to characterize 

what otherwise might be considered personal expenses as business expenses to justify 

having the businesses pay them.

g. The FTC again contends that Trudeau appears to be pursuing a number 

of business ventures or ideas that it contends likely would violate the 2004 order. The 

Court's view of this is that the June 2023 order requires preapproval of business 

relationships, and any violation of law may be pursued may be pursued via a separate 

lawsuit or, perhaps, a request for a contempt finding in this case. None of what is 

identified here appears to the Court—at least on the short summary provided—to be 

ripe for that sort of consideration as of the date of this particular FTC filing.

3. February 21, 2024 report (covering December 8, 2023 to February 7, 

2024); April 19, 2024 report (covering February 8, 2024 to April 7, 2024)

These reports are found at docket 1277 and docket 1289. There does not 

appear to have been any direct response filed by the FTC.

4. June 21, 2024 report (covering April 8, 2024 to June 7, 2024)

The FTC's response is found at docket 1336; Trudeau's reply is found at docket 

1341. The major points are as follows.

a. The FTC points out that by this point in mid-2024, Trudeau is paying 

progressively less and less of his and his businesses' gross income to the FTC even 

though he and the businesses have about $1.2 million in cash on hand. The current 

pace, the FTC says, is on average only about $13,000 per month paid over to the FTC 

for consumer redress. 

Trudeau responds that "gross income" is not an appropriate figure to consider, as 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 19 of 41 PageID #:43916
20

the Court's order does not require payment of a percentage of that. He also contends 

that business revenue isn't the same as personal income. Trudeau says that over the 

four reporting periods including the one covered by this report, he paid to the FTC a 

total of about $320,000 of about $373,000 he was paid as personal income, which 

includes the required 75 percent of his pay from GIN. He again repeats his earlier point 

about the need for the businesses to retain funds for operating expenses. Also, 

Trudeau says in his reply that he is "treading water" to see if the Court grants his 

request to drop the $2 million infomercial bond requirement.

The figures suggest that it would be appropriate—as noted by the Court earlier—

to require all Trudeau-controlled businesses to pay to Trudeau to pay to the FTC, or to 

pay directly to the FTC, a specified portion of the funds received or retained by the 

businesses. As the Court has indicated, an order to this effect is already in place for 

KTFC, but not for TCTC or any other entity that Trudeau may establish. 

b. The FTC takes issue with a number of expenses identified by the 

businesses that it characterizes as frivolous, including $25,000 paid to cigar 

establishment; $1146 at a liquor store; $1214 at Capital Grille, a restaurant; $4500 at a 

"celebrity brain scan center"; various amounts paid by GIN, including for shipment of 

Trudeau's golf clubs; $22,000 paid to a person referred to as Trudeau's former romantic 

partner, classified as an office expense without further explanation; and $289 for an 

Uber ride to a court hearing in the present case.

Trudeau responds as follows. The cigars are branded with a Trudeau trademark 

and are handed out at his seminars supposedly to generate more business. The liquor 

store expense was for "business entertainment" purposes, and the restaurant expense 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 20 of 41 PageID #:43917
21

involved a dinner with purchasers of a Trudeau seminar. The $22,000 and $4,500, 

Trudeau says, were "legitimately incurred for research and testing purposes." Dkt. 1341 

at 6. The $22,000 was for four "Life Force Energy Tesla Devices," whatever that 

means, and the $4,500 was for a "brain scan" at a particular clinic. Trudeau says he 

incurred these expenses so he could write about the products in a forthcoming book 

and discuss them on YouTube shows. All of this has some surface appeal, but it 

illustrates a broader issue regarding the effectively unregulated expenditures (and nonexpenditures) of funds by the Trudeau-controlled entities. 

c. The last point raised by the FTC is one made earlier: there is no 

documentation regarding the purportedly separate legal defense fund account. Trudeau 

responds, as before, that the fund has no expenses other than paying the attorneys. 

But this does not excuse a failure to report. Trudeau is directed to provide an itemized 

accounting of all amounts received and paid by the legal defense fund to date. For 

receipts, the accounting is to include the date, amount, and remitter of each amount 

received. For disbursements, the accounting is to include the date, amount, and payee. 

A similar accounting must be included in all bimonthly reports going forward.4 

5. August 21, 2024 report

This report, found at docket 1342, was recently filed, so there is no response by 

the FTC as of the date this section of the present order was written.

6. Summary

In summary:

4 For periods already past, it appears that this retrospective accounting now may have 

been provided as a result of the objections and briefing. If so, Trudeau may simply reproduce it to the FTC.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 21 of 41 PageID #:43918
22

• There is an open issue regarding TCTC's unregulated retention of funds given 

the absence of a court order allowing and governing this. The Court has 

imposed a bar on spending, dissipation of assets, etc. by TCTC pending entry of 

such an order. Trudeau has the burden of filing an appropriate motion in this 

regard and should do so promptly.

• There is an open issue regarding how much Trudeau's businesses should be 

able to retain and hold for business expenses, and when and in what amounts 

retained funds must be paid over to the FTC or to Trudeau for payment to the 

FTC. See also infra at 33. The parties are directed to engage in good faith 

discussion to attempt to agree on a proposal and are to submit a joint report to 

the Court with their proposal(s). The Court wishes to emphasize that it is quite 

serious in imposing the good faith requirement. If a party does not carry this out, 

it will effectively be forfeiting its place at the table: the Court is inclined, if the 

parties cannot reach agreement and submit separate proposals, to pick one or 

the other on the various points, along the lines of a baseball-type arbitration.

• Trudeau must make a supplemental disclosure regarding all receipts and 

disbursements by his legal defense fund, as spelled out above, and must do so 

in each bimonthly report going forward.

• There needs to be greater documentation and itemization of the entities' 

business expenses, as least above a particular threshold. The Court directs the 

parties to confer in good faith and make a proposal on this as well.

• Going forward, any objections or disputes by the FTC filed with the Court 

regarding a Trudeau bimonthly report must first be communicated to Trudeau's 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 22 of 41 PageID #:43919
23

counsel, no later than seven days before the due date for the FTC's response to 

the report. Upon such communication, both sides must engage in prompt, good 

faith discussions to resolve the dispute in advance of the FTC's filing deadline. 

Any disputes that survive this process and thus are included in a filing by the 

FTC in response to a bimonthly report will require an in-person evidentiary 

hearing before the Court. To the extent the Court's schedule permits, the hearing

will be held within seven days after the due date for Trudeau's response to the 

objections.

B. Resumption of coercive incarceration of Trudeau

The next issue to be addressed is the FTC's proposal to resume coercive 

incarceration of Trudeau. Adopting this approach presumably would provide some level 

of moral satisfaction, at least for the FTC. But there is no basis in the record to believe 

that it would accomplish anything with respect to compliance with the contempt 

judgment. After conducting extensive hearings in 2023, Judge Gettleman was not 

persuaded that reimposition of incarceration would lead to any further assets being 

surfaced or faster payment (or payment at all) of the contempt judgment. And 

incarceration would have a significant downside: to the extent Trudeau is able to 

generate any income to pay for consumer redress, incarcerating him would bring that to 

a screeching halt. 

The FTC also contends that the bimonthly financial reports show that Trudeau is, 

in essence, turning somersaults to make sure that incoming funds end up going for 

anything other than consumer redress, and in significant part for his direct or indirect 

personal benefit. But to the extent that's so, the better solution is a more direct one: 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 23 of 41 PageID #:43920
24

revise the current scheme to prevent, minimize, or penalize inappropriate distributions 

and payments, regulate what may be retained for ongoing operating expenses, and 

require distributions by the Trudeau-controlled entities to him, or to the FTC, to pay 

down the judgment. That is what the Court contemplates, as indicated by its directions 

in the previous section of this order.

For these reasons, the Court, like Judge Gettleman in his June 2023 order, 

declines to impose further coercive incarceration at this time.5

C. Imposition of a monitorship

The next issue involves the FTC's alternative proposal for a monitorship. See 

dkt. 1251. Specifically, the FTC asks the Court to appoint a monitor to oversee 

Trudeau's finances and business activities and provide semiannual reports to the Court. 

Imposition of a monitorship would relieve the FTC—and, possibly, the Court—of 

at least some of the burden of assessing new ventures proposed by Trudeau. But this 

would come at a high price. A monitor would have to first become immersed in the 

history of the litigation and Trudeau's past and current business ventures, and then 

would have to engage in extensive analysis—analysis the FTC itself characterizes as 

cumbersome, see dkt. 1251 at 13—before recommending approval or disapproval of 

any particular venture. And any thumbs-up or thumbs-down presumably would be 

subject to briefing by the parties and determination by the Court. The Court has learned 

quite well from its brief tenure presiding over this case that there appears to be no 

dispute too small to avoid being disputed at length, and typically with both sides' 

5 To be clear, this most emphatically does not mean that this is being taken off the table 

indefinitely.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 24 of 41 PageID #:43921
25

attorneys' adjective and adverb generators turned on and set to high. There's not much 

hope—at least, the Court doesn't have much hope—that establishing a monitorship 

would avoid this. 

Perhaps more importantly, imposition of a monitorship inevitably would lead to an 

additional financial drain on any income Trudeau might be able to garner. As indicated, 

one of the tasks the FTC proposes to assign to the monitor is the responsibility for 

overseeing the finances and transactions of Trudeau and his related entities. In this 

regard, the FTC's proposed order would allow the monitor to retain other professionals,

and it's reasonable to believe that the monitor would do so, in particular an 

accountant—who would also have to be paid. The FTC asks that the monitorship be 

paid for by Trudeau himself. But that money would have to come from somewhere. 

And any money available to Trudeau that goes to pay for a monitor is by definition 

unavailable for payment on the judgment and thus unavailable for consumer redress. In 

the Court's view, the amount that a monitorship would divert for fees and expenses is 

likely to be significant: that's been the experience with the FTC-approved trustee and 

redress administrator, who collectively were paid the lion's share—sixty-four percent—of 

the initial $15 million recovered from Trudeau, leaving a relatively modest amount for 

the consumers who were victims of Trudeau's scheme. 

The potential advantages of a monitorship would be twofold. As indicated, it 

would remove from the FTC the burden of pre-approval review for Trudeau's business 

activities, and depending on how things work out, it might also lighten the load on the 

Court in that regard. Second, a monitorship theoretically might relieve some of the 

burden imposed upon the FTC, defense counsel, Trudeau's accountants, and the Court 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 25 of 41 PageID #:43922
26

in connection with the review of Trudeau's finances. 

In the Court's view, however, the second of these two potential benefits is likely a 

mirage. Given the level of contention in the case, the likelihood that the FTC would no 

longer feel the need to object or otherwise weigh in on Trudeau's financial reports, even 

if they were being vetted first by a monitor, is a pipedream. And the history of the

Trudeau-related litigation going back to 1998 suggests that Trudeau would feel no 

compunctions about pushing the limits of what he may permissibly do, and the FTC 

likewise would feel no compunctions about strenuously objecting to a significant part of 

his financial activities.

The same is true of pre-approval of business relationships. Someone likely 

would be objecting to the monitor's recommendations on such proposals, either Trudeau 

or the FTC. And thus there still would be, and would have to be, briefing, argument, and 

hearings. 

In short, appointment of a monitor, in the Court's view, would unreasonably drain 

further the funds available for payment on the judgment, with no reasonably equivalent 

corresponding benefit. The Court therefore denies the FTC's motion (dkt. 1251), 

without prejudice to renewed consideration if circumstances change materially.

D. Motion for approval of business activities (dkt. 1284)

Trudeau has moved the Court to approve the following business activities: (1) a 

contract with Groove Digital, LLC and its sister companies to market and sell their online 

marketing software; (2) promotion of the previously-approved "money processes" 

seminar offered by Trudeau through his company TCTC, including use of a particular 

marketing brochure; and (3) purchase of the website naturalcures.com.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 26 of 41 PageID #:43923
27

As accurately summarized by the FTC in its response, there are two relevant 

sets of restrictions that apply to Trudeau's business activities—in addition to prohibitions 

imposed by statutory, regulatory, and common law. First, under the 2004 consent order, 

Trudeau is enjoined "from making or assisting others in making, expressly or by 

implication . . . any representation about the benefits, performance or efficacy of any 

product, program or service unless the representation is true and non-misleading." Dkt. 

56 at 10-11. Second, under the 2010 order, Trudeau is enjoined from making 

representations of any sort in any infomercial aired or played on any television or radio 

media (including the Internet), and from "making, or assisting others in making, 

expressly or by implication," any representation about the "health benefit" of any 

"product, program or service" or that any "product, program, or service can cure, treat, 

or prevent any disease." Dkt. 372 at 1-4. These prohibitions have a carve-out—an 

exception—for truthful, non-misleading representations on television or radio media in 

connection with books, newsletters, and informational publications, if Trudeau satisfies 

five elements: the publication does not reference, directly or indirectly, any branded or 

trademarked product, program or service that Trudeau promotes; the publication is not 

directly or indirectly an advertisement for any product, program or service, regardless of 

who promotes it; the publication is not promoted directly or indirectly in conjunction with 

any other product, program or service that is related to the content of the publication; 

Trudeau cannot misrepresent the publication's contents; and he cannot misrepresent 

the benefits, performance, or efficacy of any product, program, or service the publication 

references. Id.

Those are the relevant prohibitions, and they have been around in this case for a 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 27 of 41 PageID #:43924
28

long time. The pre-approval requirement is much more recent; it is contained in Judge 

Gettleman's June 6, 2023 order. That order states, in relevant part:

Before agreeing to any business relationship, including those referred to in 

Trudeau’s corrected motion to alter the judgment (Doc. 1119), Trudeau 

must submit his intended activities to the FTC for approval. Trudeau is 

prohibited from acting through nominees. If the parties, after good faith 

consultation, cannot reach agreement on any such plan, either party may 

file an appropriate motion with the court for determination.

Dkt. 1146 at 4.

The FTC objects to Trudeau's motion. The FTC principally says that the Court 

should eliminate the pre-approval requirement, which it characterizes as "unlawful" in 

terms of what it imposes upon the agency. The Court will return to that proposal in a 

moment. Alternatively, the FTC says that any business relationships should be 

evaluated by its proposed monitor, to whom the Court should defer. The Court has, 

however, overruled the FTC's motion to establish a monitorship.

Regarding Groove Digital, the FTC says that it questions the authenticity of the 

letter from Groove's CEO proposing the deal; Trudeau has not disclosed whether he 

has any connections with Groove; Groove has not responded to inquiries by the FTC, 

so it can't tell what exactly Trudeau would be doing; and the proposed agreement is not 

with Trudeau himself but rather with TCTC, leaving up in the air whether the 

arrangement would generate anything for consumer redress, which is payable by 

Trudeau at this point.

The Court approves the proposed arrangement between Trudeau and Groove 

Digital, but this approval is conditioned upon establishment and approval of terms 

acceptable to the Court that will ensure that revenues obtained by TCTC or any other 

Trudeau-related entity on this deal, or at least a significant portion of them, will go for

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 28 of 41 PageID #:43925
29

payment on the contempt judgment in the present case. Trudeau may not proceed until 

this is in place and approved.

And the Court wishes to make crystal clear what should be obvious: it is 

approving only the establishment of a relationship between Trudeau and/or his entities 

and Groove Digital; not any particular activities, statements, representations, or 

marketing that might be undertaken pursuant to that relationship. The Court has not 

been asked to do so, nor would it do so if asked: the Court is not going to do anything 

that could be viewed as an advance imprimatur of whatever Trudeau or others end up 

doing pursuant to a given business relationship. The June 2023 order requires advance 

approval of relationships, not particular statements, representations, or marketing 

campaigns. In this regard, Trudeau remains subject to the prohibitions and 

requirements imposed by the Court's orders in this case, as well as any applicable 

statutory, regulatory, and common law prohibitions and requirements.

Next is the proposed promotion of "money processes" seminars to be conducted 

via TCTC. In response, the FTC says that "Trudeau does not need the FTC's 

preapproval to run the 'Money Processes' ad (though the FTC reserves the right to 

pursue enforcement activity should he elect to use the ad)." Dkt. 1307 at 20. The FTC 

is right; the June 2023 order requires preapproval for business relationships, not 

particular communications. Thus the Court will not address the proposal for advance 

approval of the ad copy. Trudeau is on his own on that one and remains fully subject to 

the restrictions imposed in this case and, of course, by the law.

The last business relationship for which Trudeau seeks preapproval via this 

motion is the purchase of the website naturalcures.com. The FTC's first objection is 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 29 of 41 PageID #:43926
30

that "Trudeau has not committed to anything and, consequently, there is nothing to 

review." Id. at 25. The FTC also objects that it is highly likely that Trudeau will use the 

website to engage in fraud and misrepresentation. Id. The latter objection is 

hypothetical at this point and thus is not a basis to disapprove the website acquisition. 

The FTC's first objection, however, has a more solid foundation. Trudeau's motion does 

not tell the Court anything firm regarding the purchase price—just that it has to be 

negotiated and will be "no more than $1 million." Just as importantly, the motion says 

nothing about who (Trudeau? TCTC? some other entity?) will own the website and how 

revenues it generates will be distributed—including for payment on the judgment. 

These are necessary components for the Court to consider in determining whether to 

approve any "business relationship" in the way contemplated by the June 2023 order. 

The Court therefore denies this aspect of Trudeau's motion, without prejudice.

The Court notes that Trudeau has suggested at various points in his submissions 

that the FTC should not be heard later to object to some or all of his activities on 

different grounds or, perhaps, on bases that it had the opportunity to assert earlier but 

bypassed. That's an easy one: it's wrong. Trudeau's argument is not supported by any 

conceivably applicable legal authority. To be clear, the FTC is not estopped from 

anything with regard to Trudeau's businesses and activities, nor is the Court. Regarding 

the FTC, it retains its authority to bring appropriate proceedings to enforce the law and 

the consent orders and other orders entered in this case, as well as to refer matters to 

other regulatory and enforcement agencies. 

The Court returns, finally, to the FTC's request to eliminate the preapproval 

process. The FTC argues that this provision is "unlawful." The Court need not 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 30 of 41 PageID #:43927
31

determine that point. But it wishes to point out to the FTC that if the legality of this 

aspect of Judge Gettleman's June 2023 order was a serious question, one would have 

expected an immediate motion to reconsider or an appeal. The FTC did neither. 

But that aside, the FTC preapproval requirement, in practice, does not appear to 

be serving any useful purpose. Judge Gettleman's expectation and hope presumably 

was that the requirement would result in some winnowing of proposals by Trudeau and 

agreed-upon approval of other proposals. That, however, is not the way it has worked 

out. The FTC preapproval requirement has been counterproductive, or at least 

unproductive. The Court eliminates this requirement, effective on September 20, 2024.

This does not relieve Trudeau from the obligation to report in his bimonthly 

reports regarding "the status of any business relationship he has entered into or intends 

to enter into," as required by Judge Gettleman's June 6, 2023 order. Dkt. 1145 at 4. 

Indeed, as discussed below, the Court intends to assess whether this this requirement 

needs to be made more robust in light of the elimination of the FTC preapproval 

requirement.

Looking a bit further down the road, the Court would prefer to also eliminate the 

requirement for court preapproval of Trudeau's business relationships. The Court is illequipped to evaluate proposed business relationships in advance; courts have no 

particular expertise in this regard. Trudeau's business activities are already regulated 

by previous orders in this case and by statutory, regulatory, and common law. If he 

engages in unlawful or otherwise prohibited activity, contempt proceedings can be 

initiated, and/or the FTC can commence a new lawsuit. That should be sufficient. 

Another problem with preapproval by the Court of a business relationship is that it sets 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 31 of 41 PageID #:43928
32

up a risk that the Court will be seen, or portrayed, as having placed its imprimatur upon

whatever follows in that business relationship.

The Court will not, however, eliminate the court-preapproval requirement without 

first considering and initiating preventative measures. As discussed earlier, Trudeau is

currently required to remit to the FTC only a specified percentage of his GIN Unite 

income, any other income he receives personally, and whatever is left in KTFC after 

reasonable business expenses. There's nothing in place in this regard for TCTC, which 

has taken in significant revenues, let alone for any other entity or venture Trudeau may 

establish in the future. Without a mechanism governing when, how, or in what amounts 

any such funds have to be distributed to Trudeau or remitted, in whole or in part, to the 

FTC, this amounts to a significant loophole. The Court intends to close the loophole. 

Among other things, the Court does not intend to allow a situation in which Trudeau 

starts up a business venture, puts it in a corporate or entity name, it makes money, and 

then Trudeau does not apply those revenues to the judgment and says (as he is 

currently saying regarding TCTC) that there's no mechanism requiring the revenues, or 

any part of them, to be paid to him or to the FTC.6 Rather, the current process will need 

to be modified to establish how monies generated for any entities controlled by or 

affiliated with Trudeau will be contributed to the FTC on the judgment and/or distributed 

to Trudeau for that purpose.

6 Under the current regime, for example, Court approval of the naturalcures.com 

purchase would enable Trudeau to buy the website and then cause its revenues to be 

directed to TCTC, which could then pay for golf outings, cigar events, Trudeau's 

business dinners, travel to and from supposed work-related activities, phone bills, or 

whatever—without any of it going to the FTC for payment of the contempt judgment. 

That's inappropriate given the large balance remaining due on the judgment.

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 32 of 41 PageID #:43929
33

For this reason, as discussed earlier, the Court directs the parties to promptly 

confer and attempt, diligently and in good faith, to reach an agreement regarding 

disposition of revenues received by Trudeau's controlled, affiliated, and related entities, 

including KTFC, TCTC, and any that may be established in the future. See supra at 23. 

These entities should be permitted to retain a reasonable amount of money (preferable, 

in specified amounts or percentages) in anticipation of reasonable and legitimate 

business expenses, as estimated in advance and subsequently documented; they 

should be able to pay their employees reasonable but not excessive wages; and they 

should be able to pay their trade creditors in a timely fashion. But the Court will not 

permit them to be used to accumulate funds that, in turn, are used in significant part to 

pay expenses that Trudeau would otherwise pay himself or to support a high-end 

lifestyle for him, while the contempt judgment just sits there unpaid. The Court wishes 

to emphasize its direction to both sides to address this point diligently and in good faith 

to attempt to reach an agreement. As the Court has indicated, any party that does not 

do that will in effect be forfeiting its seat at the table.

While discussing this topic, the parties are also directed to review the current 

orders (in particular the June 6, 2023 order) regarding whether they include a 

sufficiently robust reporting requirement regarding Trudeau's ongoing business 

activities, particularly in light of the elimination of the FTC preapproval requirement and 

the future elimination of the requirement for Court preapproval. They are to discuss 

possible changes, consistent with the Court's direction, diligently and in good faith as 

well. The Court does not intend for the elimination of the preapproval requirement(s) to 

create an informational vacuum regarding Trudeau's day-to-day and longer-term 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 33 of 41 PageID #:43930
34

business activities, at least so long as the contempt judgment remains unpaid.

E. The $2 million infomercial bond requirement

Trudeau asks the Court to eliminate the requirement, found in the 2010 order, to 

post a $2 million performance bond, effectively as security against future consumer 

harm from infomercials that Trudeau may disseminate. The Court notes that this

requirement also has the effect of requiring Trudeau to have some skin in the game if 

and when he chooses to create infomercials: he can't do it scot-free.

At this point, Trudeau has not sufficiently made the case even for reducing the 

amount of the performance bond, let alone eliminating it. And this is where the fact that 

the ongoing accumulation of funds by the Trudeau-controlled entities without any 

distribution to the FTC or to Trudeau to pay to the FTC—which, at least for TCTC, the 

Court's orders do not specifically preclude—comes back to bite. The infomercial bond 

is, and should be, an expense of Trudeau and his businesses. He has accumulated 

significant funds in his business entities, and he has not made the case that he is 

financially incapable of putting up the bond. The Court would entertain a focused, and 

properly supported, motion to reduce the bond. But the Court denies Trudeau's request 

to eliminate the bond requirement altogether.

The Court notes, in this regard, that Trudeau has suggested—actually he has 

affirmatively said—that if the Court doesn't see this one his way, he will simply "retire," 

presumably retreat to his home, and thus generate no more money for consumer 

redress. See, e.g., Dkt. 1311 at 7; Dkt. 1238 at 5. The Court feels constrained to say 

that it does not appreciate this threat (which is exactly what it is). But that aside, it's not 

quite that easy. Trudeau is under an obligation to make diligent efforts to comply with 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 34 of 41 PageID #:43931
35

the Court's orders, including the order requiring payment to the FTC. See Order of June 

6, 2023 (dkt. 1146) at 2 (citing Goluba v. Sch. Dist. of Ripon, 45 F.3d 1035, 1037 (7th 

Cir. 1995)). If he instead decides, figuratively speaking, to sit in the corner and hold his 

breath until he turns blue, there is at least some risk that he will be in contempt. 

Trudeau would be well advised to keep that in mind as he decides how to conduct 

himself going forward.

F. International travel prohibition

Trudeau is currently prohibited from traveling internationally, via an order entered 

by Judge Gettleman in June 2013. See dkt. 700. Trudeau has moved the Court to lift 

this prohibition. See dkt. 1242, 1275. He says it is "counterproductive" because, 

among other things, it prevents him from conducting GIN Unite-related fundraising 

activities abroad, which is significant because, he says, over sixty percent of GIN's 

members are located outside the U.S. Trudeau argues that "[m]ember conferences are 

GIN Unite's lifeblood," id. at 2, and that the preclusion of international travel prevents 

him from taking advantage of such opportunities and any resulting income—seventyfive percent of which would go to the FTC. He says that "[s]imilar concerns apply to 

Trudeau's own business of [TCTC] and Trudeau's work for [KTFC]." Id.7

In response, the FTC points out that that the prohibition was imposed by Judge 

Gettleman in 2013 following "Trudeau's attempt to flee to his luxury home in 

Switzerland," dkt. 1252 at 1, and it contends the prohibition remains a viable and 

7 Trudeau also contends that the travel restriction "has no proper remaining role" 

because "there is nothing Trudeau can do to 'purge' himself of this restriction." Id. at 3. 

That's quite clearly wrong; paying off the remainder of the judgment would purge the

contempt, or at least this particular aspect of the contempt judgment. 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 35 of 41 PageID #:43932
36

appropriate exercise of the Court's equitable power to preserve its ability to compel 

repayment from Trudeau. See id. at 2 (citing Bank of Am., N.A. v. Veluchamy, 643 F.3d 

185, 187-90 (7th Cir. 2011)). The FTC also argues that allowing international travel 

would remove the threat of coercive incarceration and thus render the contempt 

monetary judgment ineffective. And, it argues, this would provide "another opportunity 

for Trudeau to spend extravagantly under the guise of his businesses' reasonable 

operating expenses." Id.

The key problem with Trudeau's motion is that (as the FTC pointed out in 

response) it did not identify any specific business opportunity that he lost, or any 

specifics about any particular opportunities he might have in the future. Without this, 

the motion basically came across as a request to approve an overseas vacation. For 

these reasons, the Court denies the motion (dkt. 1242) without prejudice.

The Court is willing to entertain specific, and fully supported, requests for 

international travel for specific, and real, opportunities along the lines of what Trudeau 

suggests. But to even get through the front door, the request will have to include, at a 

minimum, a detailed description of the proposed activities and itinerary and who else 

would be involved; a full budget (anticipated expenses and revenue, in detail); an 

explanation of what advance payments and commitments would be required and what 

they would cost; an undertaking regarding how and by whom expenses will be paid or 

advanced; an estimate of the amount that Trudeau and GIN Unite expect to realize; and 

a proposal for a binding commitment regarding when, how, and in what amounts any 

sums that are realized will be paid on the contempt judgment.

After briefing on the original motion was complete, Trudeau filed a "supplement" 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 36 of 41 PageID #:43933
37

that contained more information regarding his proposal. It does not appear that the 

Court set a schedule on this motion or that the FTC ever filed a response. The Court 

strikes the supplement (dkt. 1275) without prejudice to resubmission by Trudeau 

consistent with the requirements outlined by the Court in the previous paragraph. 

G. Accounting and expert expenses

Judge Gettleman's June 16, 2023 order permits Trudeau to raise funds for a 

"legal defense fund" separate from KFTC. The order states:

Trudeau may establish a new legal defense fund separate from KTFC. 

The sole purpose of the new legal defense fund will be to collect thirdparty contributions to pay Trudeau’s legal fees and costs and to remit such 

contributions to Trudeau’s counsel. One hundred percent (100%) of all 

contributions to the fund shall be applied toward Trudeau’s legal fees and 

costs, net of any reasonable expenses incurred to create and maintain the 

fund. Trudeau may solicit contributions to his legal defense fund, provided 

that any such solicitations expressly state that the sole purpose of any 

contributions to the fund are to pay Trudeau’s legal expenses and that 

such contributions are not in lieu of any payments that would otherwise be 

made to KTFC. Trudeau shall submit bi-monthly Reports detailing the 

income and expenses of the legal defense fund consistent with his other 

reporting requirements.

Dkt. 1151 ¶ 7. The parties dispute whether the phrase "legal fees and costs" allows 

Trudeau to pay accounting and expert fees. The Court concludes the order allows this, 

if (but only if) the accountant is retained by counsel and the particular fees charged are

directly related to the present lawsuit. An example would be preparation of the 

bimonthly financial reports that are required by court order. The June 16 order does not 

authorize use of the legal defense fund for the regular accounting expenses of

Trudeau's businesses, for making proposals to approve business opportunities, and so 

on. 

In addition, the Court wishes to make clear that the legal defense fund allowed by 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 37 of 41 PageID #:43934
38

the June 16 order must be a separate account from any other account held by KTFC, 

Trudeau, or any of his businesses. (It appears this has now been done, but there may 

previously been some confusion on this point.) And as previously discussed, the 

reporting must include an itemization of the contributions and contributors; and for any 

accounting or expert expenses that are paid, there must be a verification, including by 

counsel, that they are directly related to the present lawsuit. Expenditures will be 

subject to review by the Court for determination of compliance with applicable orders.

Trudeau has separately moved, more recently, to allow his businesses "to pay 

their outside legal and accounting litigation-related expenses." Dkt. 1312 at 1. The 

Court denies the motion, without prejudice to refiling. The request is not properly 

supported or anywhere close to it. There is no indication of the amounts involved; there 

is no proposal for any meaningful guardrails to determine what is "litigation-related"; and 

there is not a good explanation (actually, there is no explanation) of why this shouldn’t 

come from the already-permitted legal defense fund rather than as an expenditure that 

effectively reduces the business-related income available for payments on the contempt 

judgment. In addition, given the current state of affairs—in which Trudeau has 

accumulated significant funds in TCTC—granting Trudeau's proposal could enable him 

to (for example) take all the accumulated funds, pay them over to counsel, and then turn 

his pockets inside out and claim he can no longer afford to post the performance bond 

but should be allowed to plow ahead into new infomercials anyway. As the Court has 

indicated, all of the separate pieces discussed in the parties' respective requests and in 

this order are pieces of a single whole, and they should be dealt with as such rather 

than in a piecemeal way. 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 38 of 41 PageID #:43935
39

H. Effect of FDCPA

Trudeau has contended that the Federal Debt Collection Practices Act caps at 

twenty-five percent the amount that he may be ordered to pay on the judgment from his 

earnings. The Court ruled orally a number of months ago, at a status hearing held on 

December 13, 2023, that this cap is inoperative with regard to the $37.6 million 

contempt judgment. The Court indicated that it would make a written ruling later, but 

has reconsidered and does not see a need to do that, beyond the comments in this 

section. 

The FDCPA provides "the exclusive civil procedures for the United States to 

recover a judgment on a debt," 28 U.S.C. §3001(a)(1), but it "shall not be construed to 

supersede or modify . . . the authority of a court . . . to exercise the power of contempt 

under any Federal law." Id. § 3003(c)(8)(C). In this case we are not dealing with a 

preexisting debt, and we are not dealing with an ordinary civil judgment that the FTC is 

attempting to collect by garnishment or otherwise. Rather, we are dealing with a 

contempt order. The $37.6 million judgment was imposed as part of a civil contempt

order, and the collection mechanism ordered by Judge Gettleman is part and parcel of 

the civil contempt order. Thus collection is within the specific exception set out in 

section 3008(c)(8)(C) of the FDCPA.8 

The Court also notes that even if the FDCPA's limitations—including related 

limitations on garnishment—apply, Trudeau specifically agreed to pay over an amount 

8 CFTC v. Escobio, 946 F.3d 1242 (11th Cir. 2020), cited by Trudeau for the proposition 

that a party cannot be held in contempt for failure to pay a money judgment, simply 

does not govern here. In this case we do not have a preexisting money judgment that 

the Court is enforcing via contempt. Rather what is at issue is an order to pay imposed 

as a contempt sanction. See dkt. 372 at 13-14. 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 39 of 41 PageID #:43936
40

that exceeded the FDCPA's cap. He expressly offered to pay more than the twenty-five 

percent cap imposed by limitations on wage garnishment, and Judge Gettleman 

expressly took him up on that offer. Thus Trudeau affirmatively waived the limitations 

set out in the FDCPA even if they apply. And once Judge Gettleman entered the formal 

order regarding payment in June 2023, Trudeau could have appealed and/or sought 

reconsideration if he believed the order ran afoul of the FDCPA. He did not do so.

For these reasons, the Court overrules Trudeau's contention that the FDCPA cap 

applies and need not address the FTC's alternative contentions on this point.

I. Other issues

An issue was raised some months ago regarding what amount remains due and 

owing on the $37.6 million judgment. One of the specific questions is, is it $37.6 million 

less whatever the FTC has collected and Trudeau has paid? Or should the fact that 

some consumers did not cash their refund checks (and, for some, thus weren't sent a 

second refund check) be taken into account? There may be other related questions as 

well.

It is time to get this decided. The Court's order will require the parties to submit 

position papers on this point.

Conclusion

The Court: (1) overrules the FTC's request for coercive incarceration; (2) denies

the FTC's motion to impose a monitorship [1251]; (3) denies without prejudice Trudeau's 

motion to lift the international travel restriction [1242] and strikes without prejudice his 

supplemental motion on this point [1275]; (4) denies without prejudice Trudeau's motion 

to eliminate the $2 million infomercial performance bond requirement; and (5) denies 

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 40 of 41 PageID #:43937
41

without prejudice his motion to allow his businesses to pay legal and accounting 

expenses [1312]. The Court also directs the parties to confer in good faith on the 

various topics outlined in the body of this opinion and submit a joint status report on 

October 14, 2024. On that same date, the parties are to submit position papers 

regarding what amount remains due and owing on the contempt judgment. Finally, the

Court directs Trudeau to file, within ten days of today's date, a verified statement with 

details on the $54,000 computer expenditure as outlined in the body of this opinion.

Date: September 13, 2024

________________________________

MATTHEW F. KENNELLY

 United States District Judge

Case: 1:03-cv-03904 Document #: 1381 Filed: 09/13/24 Page 41 of 41 PageID #:43938