The case was one of more than 80 filed nationwide by the FTC, the U.S. Justice Department, and business opportunity regulators in 20 state securities divisions and attorneys general offices. The complaint against Nibblers and Kiernan alleged that they failed to give investors a required document containing substantiation for the earnings claims they made. The consent order also contains various reporting provisions that would assist the FTC in monitoring compliance. The Commission vote to authorize filing was 5-0. This consent order is for settlement purposes only and does not constitute an admission by the defendant of a law violation.
Consent orders have the force of law when signed by the judge.