Business ProfileforMy ECOM Club

BBB files indicate that this business has a pattern of complaints concerning misrepresentation of services and billing issues.

In August 2019, BBB contacted the business requesting information as to why the business believes the customers are filing the complaints, and what actions the business has taken to help eliminate the causes of complaints.

As of today's date BBB has not received a response from the business.

11/19/19 Business states/ Please be informed that My Ecom Club has closed and is no longer in business, and its employees have been dismissed. A small handful are still on board to wrap things up through the end of the year.


Thank you,
Erin Carter
Director of Customer Service My Ecom Club

The following describes a government action that has been resolved by either a settlement or a decision by a court or administrative agency. If the matter is being appealed, it will be noted below.

On March 3, 2020, the Federal Trade Commission filed a complaint for permanent injunction and other relief (Case No. 6:20-cv-00371-CEM-GJK) with Middle District of Florida, Orlando Division against Michael A. Giannulis, a/k/a Mike Antoni, individually and as an officer, member and/or manager of BPO USA LLC, Pixx Media LLC, MyEcomClub Events LLC, and Mike Antoni LLC; Michael R. Williams, individually and as an officer, member and/or manager of BPO USA LLC, Pixx Media LLC, MyEcomClub Events LLC; BPO USA LLC, also d/b/a MY ECOM CLUB, formerly d/b/a MY INTERNET EDUCATION, formerly d/b/a DIGITAL EDUCATION SYSTEMS, a Florida limited liability company; PIXX MEDIA LLC, also d/b/a YOU GET PAID, a Florida limited liability company; MIKE ANTONI LLC, a Florida limited liability company; and MYECOMCLUB EVENTS LLC, a Florida limited liability company.

Defendant Michael A. Giannulis also known as Mike Antoni ("Giannulis") is the Chief Executive Officer and registered owner of BPO USA LLC, Pixx Media LLC, MyEcomClub Events, and Mike Antoni LLC. At all times material to this complaint, acting alone or in concert with others, Giannulis has formulated, directed, controlled, had the authority to control, or participated in the acts and practices set forth in this complaint. Giannulis resides in this district and, in connection with the matters alleged herein, transacts or has transacted business in this District and throughout the United States.

Defendant Michael R. Williams ("Williams") is the Chief Operating Officer and registered owner of BPO USA LLC, Pixx Media LLC, and MyEcomClub Events. At all times material to this complaint, acting alone or in concert with others, Williams formulated, directed, controlled, had the authority to control, or participated in the acts and practices set forth in this complaint. Williams resides in Utah, but in connection with the matters alleged herein, transacts or has transacted business in this District and throughout the United States.

Defendant BPO USA, LLC ("BPO") is a Florida limited liability company formed in October 2014. BPO's registered business address is 3152 Little Road, Suite 114, Trinity, Florida 34655, which is a UPS store mailbox. On or about November 29, 2016, BPO registered the trade name "Digital Education Systems" with the Florida Secretary of State; this trade name registration was canceled on or about April 24, 2018. On or about May 23, 2017, BPO registered the trade name "My Internet Education" with the Florida Secretary of State; this registration was canceled on or about April 17, 2018. On or about May 23, 2017, BPO registered the trade name "My Ecom Club" with the Florida Secretary of State, which remains active. BPO transacts or has transacted business in connection with the alleged herein in this District and throughout the United States.

Defendant Pixx Media LLC ("Pixx") is a Florida limited liability company formed in August 2015. Pixx transacts or has transacted business in connection with the matters alleged herein in this District and throughout the United States. Pixx's registered business address is also located at 3152 Little Road, Suite 114, Trinity, Florida 34655. On or about May 15, 2017, Pixx registered the trade name "You Get Paid" with the Florida Secretary of State, which remains active.

Defendant Mike Antoni LLC ("MALLC") is a Florida limited liability company with its registered place of business in Odessa, Florida. MALLC transacts or has transacted business in connection with the matters alleged herein in this District and throughout the United States. Individual defendant Michael A. Giannulis ("Giannulis") is the registered agent and general manager of MALLC, which he formed in 2007. On or about October 27, 2016, MALLC registered the trade name "My Ecom Club" with the Florida Secretary of State; this trade name registration was canceled on or about April 24, 2018.

Defendant MyEcomClub Events LLC ("MEC Events") is a Florida limited liability company formed by Giannulis and Williams in August 2017. MEC Events transacts or has transacted business in connection with the matters alleged herein in this District and throughout the United States. MEC Events' registered place of business is 3152 Little Road, Suite 110, New Port Richey, Florida 34655, a mailbox in the same UPS store as BPO and Pixx.

Defendants BPO, Pixx, MALLC and MEC Events (collectively, "Corporate Defendants") have operated as a common enterprise while engaging in the unlawful acts and practices alleged below. Corporate Defendants conducted the business practices described below through an interrelated network of companies that have common business purpose, business functions, business locations and employees; have commingled funds, and are all owned or controlled by Giannulis and Williams, and others acting at their behest. The Corporate Defendants have routinely moved money among their various business accounts to satisfy obligations and pay business expenses. Because the Corporate Defendants have operated as a common enterprise, each of them is jointly and severally liable for the acts and practices alleged herein against the common enterprise.
Specifically, BPO, Pixx and MEC Events are co-owned and managed by Giannulis and Williams and operate as a seamless unit to promote and sell the business opportunities alleged in this Complaint. MALLC operates as a shell for Giannulis and has no separate business functions apart from promoting Defendants' business opportunities and processing payments from consumers.
Charges

Defendants have operated a series of fraudulent business coaching schemes in order to peddle sham investment opportunities and bilk over $30 million from consumers.


Starting in 2013, Defendants deployed their team of sales agents--purporting to be business "coaches"--to sell worthless membership packages from a company called "My Online Business Education" or "MOBE." Defendants falsely claimed that their coaches would teach consumers how to start and grow their internet business and that the MOBE membership packages, costing anywhere from $2,500 to $30,000, would enable consumers to make substantial income online quickly and easily. Defendants collaborated with the principals of the MOBE scheme and received millions of dollars as reward for proliferating MOBE's deception and bringing consumer victims into its fold. In early June 2018, the FTC filed a lawsuit and obtained a temporary restraining order to halt the MOBE enterprise.
In the same year that MOBE was shut down, Defendants launched their own line of business "training" packages under the name "My Ecom Club." Through My Ecom Club, Defendants purported to supply consumers with e-commerce stores and a series of related coaching programs, costing between $2,000 and $40,000. Defendants claimed that My Ecom Club's purported training programs would enable consumers to generate substantial income through their online stores. Defendants used the same team of coaches and sales scheme as they used for MOBE, replete with similarly false or unsubstantiated earnings claims, to bilk millions of dollars more from consumers in just under two years. With My Ecom Club, Defendants were able to reap all of the ill-gotten proceeds from their coaching operation without sharing the proceeds with MOBE.

Individual Defendants Giannulis and Williams have formulated, directed, controlled, had the authority to control, or participated in the acts and practices of the Corporate Defendants that constitute the common enterprise. As CEO of the common enterprise, Giannulis directs and oversees Defendants' advertising and marketing strategy, including devising and editing sales scripts and videos. As CFO, Williams oversees the financial and business operations of the enterprise, such as hiring sales agents, disputing refunds or chargebacks and obtaining merchant accounts and other means to consumer payments.

Defendants use online advertisements, videos on websites, social media platforms such as Facebook and Instagram, and live events to target prospective buyers for their business opportunities, including MOBE and My Ecom Club.

Once consumers join, Defendants run consumers through their step-by-step "training" system and assign business "coaches" who falsely claim that consumers will make substantial income online once they pay tens of thousands of dollars for additional coaching programs and, in the case of My Ecom Club, customized drop-shipping stores built on Shopify.

Unbeknownst to consumers, these "coaches" are essentially sales agents paid on commission for selling Defendants' overpriced coaching products, and the step-by-step process is a ruse designed to separate consumers from their money.
In just over eight years, Defendants caused more than $30 million in harm using this scheme to deceive consumers. As a result of Defendants' deception, many consumers have lost their retirement funds or life savings, lost their homes, and ended up with insurmountable credit card debt.

When consumers lacked funds to pay for the expensive MOBE memberships, Defendants pressed consumers to put the purchase on credit cards and open new credit lines if necessary. Defendants referred these consumers to third parties, such as Seed Consulting LLC, who Defendants claimed were business loan consultants or credit advisors that will assist consumers to obtain credit cards for their MOBE membership purchases.

Unbeknownst to consumers, Defendants received referral fees from these third-party "consultants," who in turn collected their service fees from Defendants' customers. Defendants claimed that consumers would be able to pay off their credit card debt with the eventual profits they would generate from MOBE.

In just over six years, Defendants received over $23 million in commissions from MOBE using this sales process.
Defendants devised fake testimonials or product reviews to generate publicity for their "training system." When Defendants re-branded the name of their coaching operation from "The Automatic Edge" to "Digital Education Systems," the BPO Defendants also published testimonials from purportedly satisfied customers. The BPO Defendants' internal records show that these reviews were drafted by the BPO Defendants and did not originate from actual consumers of Digital Education Systems.

When Defendants re-branded their system to "My Internet Education" in 2017, they published a press release that deceptively claimed that Digital Education Systems had formed a new "partnership with a like-minded company ... to bring the best available online training for small businesses to their students and members." The press release did not disclose the fact that My Internet Education was a continuation of Digital Education Systems and that they had the same owners and managers, coaches, ad campaigns, and "training" videos.


In or around late 2017, Defendants created and launched their own line of purported business coaching packages under the brand "My Ecom Club." Similar to MOBE, My Ecom Club offered a "done-for-you" money-making system--in the form of "optimized" drop-shipping stores set up on Shopify's e-commerce platform--and coaching from Defendants' "coaches" that would purportedly teach consumers how to make substantial income through the operation of their own e-commerce stores.

My Ecom Club offered five or six different product packages, starting with the entry level "Done-For-You E-Commerce Store" ($1997), where purchasers would purportedly receive their first two Shopify stores and additional e-commerce "training." If consumers purchased entry-level package with two stores, Defendants offered and sold "upgrade packages" with similar price points to MOBE's memberships, such as the "Lemonade Stand" ($4,997), "Small Box" ($9,997), "Mom & Pop Shop" ($14,997), "Big Box Store" ($29,997), and "The Mall" ($39,997).

Unbeknownst to consumers, Shopify offered e-commerce stores to the general public for monthly payments of $29 (for 2 staff accounts), $79 (for 5 staff accounts), or $299 (for 15 staff accounts). Shopify also offered "training" courses on managing e-commerce stores at no additional cost to its users.
In order to sell My Ecom Club's expensive offerings, Defendants used the same coaches and step-by-step sales process they used to sell the MOBE memberships.

Defendants claimed that once consumers registered with My Ecom Club, Defendants would provide five hours of free "walk-through instructions on the strategies and tools for learning to build an e-commerce store and become a player in the trillion dollar eCommerce business."

Once consumers joined My Ecom Club, they were directed to work with My Ecom Club "coaches" who would purportedly guide each consumer through Defendants' step-by-step course on e-commerce, which would include a "Strategy Session" step (around Step 6) and a "Business Plan" step (around Step 15 or later) for the consumer's prospective e-commerce business. As with MOBE, Defendants' coaches were paid commissions from their sales of the upgrade packages.

Like Defendants' sale of MOBE, My Ecom Club's business "training" steps consisted of the consumer watching pre-recorded videos, communicating to Defendants' coaches their personal income goals and available finances, and attending webinars led by My Ecom Club's paid spokesman, where he displayed screens that purportedly showed his drop-shipping stores generating revenues in real time.

After watching the videos and progressing through the introductory steps, consumers were prompted to schedule a "Strategy Session" when they reached Step 6.

Defendants devised the script for My Ecom Club's "Strategy Session" step to induce consumers to buy the entry level product offering, which mirrored the process for selling MOBE memberships. Defendants claimed that with this purchase, consumers would receive two custom built stores that were tested to reach higher sales conversions than stores built using Shopify's generic template.

After a consumer purchased the entry-level package, Defendants offered to develop a personalized "business plan" based on the consumer's financial situation. This was a ploy to induce consumers to purchase one or more of the upgrade packages.
After the strategy session, Defendants directed consumers to view a prerecorded video from their sales agent who claimed: I'm gonna be working with on My Ecom Club. Now, I know that you're ready to start making money and I'm ready for you to start making money as well.... Over the next couple of weeks, I'm going to be developing a business plan for you to really take your business way up into the stratosphere, to get you making the money you came here to make, and living the life you came here to live.... If I'm going to be an effective business coach for you and help you develop a business plan that is specific to you, I've got to know where you're at financially.

Defendants often used high-pressure sales tactics to induce purchasers to buy upgrade packages even before consumers received the My Ecom Club stores that Defendants promised with purchase of the entry-level package. For example, Defendants represented that the prices of the upgrade packages (costing between $4,997 and $39,997) were timelimited offers and that consumers would need to pay 40% more if they failed to purchase one or more of these upgrade packages within 10 days of their "Business Plan" session.

Throughout My Ecom Club's step-by-step process, Defendants' coaches conveyed the false impression that consumers would make more money if they had more ecommerce stores and received more "training" from My Ecom Club.

Defendants further claimed that My Ecom Club would reveal to consumers what products or product niches would maximize profit for their stores, which Defendants referred to as "profitable niches." After consumers spent thousands of dollars on one of the upgrade packages, Defendants provided them a "profitable niche" list that contained over 200 product categories or themes, such as "animal jewelry," "artificial flowers," "breast cancer," "drone," "military goods," and "reusable shopping bags."

Defendants' coaches told consumers that after six months to a year, consumers would be able to resell their My Ecom Club stores on third-party websites such as flippa.com or bizbuysell.com for about twenty times each store's monthly net revenue.

As they had with the purchase of MOBE memberships, Defendants' coaches referred My Ecom Club members to outside "credit advisors," like Seed Consulting LLC, which proceeded to "guide" consumers by filling out applications to obtain credit cards and submitting requests to raise borrowing limits on existing credit cards.

Defendants also invited consumers to attend Defendants' live seminars, where the members would listen to and receive tips from My Ecom Club's "six or seven-figure mentors."

Many consumers who purchased My Ecom Club's packages did not make money through their e-commerce stores, or even recoup their investments.
Contrary to the claims in their marketing materials and sales calls, Defendants claimed in another disclaimer buried in post-purchase agreements: "MyEcomClub makes no representations or guarantees as to the amount of income ... amount of traffic to the Purchaser's website or interest generated ... (or) increase in Purchaser sales...."
Defendants often conveyed the misleading impression to consumers that My Ecom Club's product packages were refundable within 30 days. Contrary to these representations, when consumers requested their money back, Defendants refused to issue the refunds or ignored these requests in the first instance.

In those instances where Defendants ultimately issued refunds, consumers had escalated their refund disputes by lodging a complaint with the BBB or threatening to hire a lawyer or refer the matter to a law enforcement agency. Defendants also issued refunds after consumers initiated a chargeback request with the credit card networks, which if left unaddressed, could trigger the credit card networks' fraud monitoring oversight of Defendants' merchant accounts.

Through the operation of the My Ecom Club scheme between 2018 and 2019, Defendants bilked more than $8 million from consumers.

Count I - Misrepresentations Regarding Earnings
In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of Defendants' products and MOBE memberships, Defendants have represented, directly or indirectly, expressly or by implication, that purchasers of those products or services would earn or were likely to earn substantial income.
Defendants' representations set forth in Paragraph 144 of this Complaint are false, misleading, or were not substantiated at the time the representations were made.
Therefore, Defendants' representations set forth in Paragraph 144 of this Complaint constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count II - Unfairly Injuring Consumers Through Credit Card Laundering
In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of Defendants' products and MOBE memberships, Defendants have engaged in credit card laundering by: (a) falsely representing, directly or through agents acting on their behalf and for their benefit, that the shell companies listed as the applicants on the merchant applications were the true merchants who were applying for merchant accounts; and/or (b) falsely representing, directly or through agents acting on their behalf and for their benefit, that the individual signors listed as the principal owners on the merchant applications were the bona fide principal owners applying for merchant accounts.
Defendants' actions caused or were likely to cause substantial injury to consumers that was not reasonably avoidable by consumers themselves and that is not outweighed by countervailing benefits to consumers or competition.
Therefore, Defendants' acts or practices, as described in Paragraph 147 above, constitute unfair acts or practices in violation of Section 5 of the FTC Act §§ 45(a) and (n).



ORDERS

I. BAN ON SALE OR MARKETING OF BUSINESS COACHING PROGRAMS AND MONEY-MAKING METHODS IT IS ORDERED that Settling Defendants are permanently restrained and enjoined from:
A. Creating, advertising, marketing, promoting, offering for sale, or selling, or assisting others in creating, advertising, marketing, promoting, offering for sale, or selling any Business Coaching Program or any Money-Making Method; and
B. Holding, directly or through a third-person, any ownership or other financial interest in any business entity that is creating, advertising, marketing, promoting, offering for sale, or selling, or that assists others in creating, advertising, marketing, promoting, offering for sale, or selling any Business Coaching Program, any Money-Making Method, or any product to assist in the creation or development of a Business Coaching Program or a Money-Making Method.

II. PROHIBITIONS RELATED TO MERCHANT ACCOUNTS
IT IS FURTHER ORDERED that Settling Defendants are permanently restrained and enjoined from:
A. Credit Card Laundering;
B. Making, or assisting others in making, directly or by implication, any false or misleading statement in order to obtain Payment Processing services;
C. Failing to disclose to an Acquiring Bank or other Financial Institution, service provider, payment processor, independent sales organization, or other entity that enables a Person to accept payments of any kind any material information related to a Merchant Account including, but not limited to, the identity of any owner, manager, director, or officer of the applicant for or holder of a Merchant Account, and any connection between an owner, manager, director, or officer of the applicant for or holder of a Merchant Account and any third person who has been or is placed in a Merchant Account monitoring program, had a Merchant Account terminated by a payment processor or a Financial Institution, or has been fined or otherwise disciplined in connection with a Merchant Account by a payment processor or a Financial Institution; and
D. Engaging in any tactics to circumvent fraud and risk monitoring programs established by any Financial Institution, Acquiring Bank, or the operators of any payment system, including, but not limited to, tactics such as balancing or distributing sales transactions among multiple Merchant Accounts or merchant billing descriptors; splitting a single sales transaction into multiple smaller transactions; or using a shell company to apply for a Merchant Account.

III. PROHIBITION AGAINST MISREPRESENTATIONS IT IS FURTHER ORDERED that Settling Defendants, their officers, agents, employees, and attorneys, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, in connection with the advertising, marketing, promoting, or offering for sale of any goods or services, are permanently restrained and enjoined from misrepresenting or assisting others in misrepresenting, expressly or by implication:
A. That consumers who purchase any goods or services will earn or are likely to earn substantial income;
B. Any other fact material to consumers concerning any good or service, such as: the total costs; any refund policy; any material restrictions, limitations, or conditions; or any material aspect of its performance, efficacy, nature, or central characteristics.

IV. MONETARY JUDGMENT AND PARTIAL SUSPENSION
A. Judgment in the amount of Thirty One Million Six Hundred Thousand Dollars ($31,600,000) is entered in favor of the Commission against the Settling Defendants, jointly and severally, as equitable monetary relief.
B. In partial satisfaction of the monetary judgment:
1. Settling Defendants are ordered to pay to the Commission Seven Hundred Sixty Thousand Dollars ($760,000), which, as Settling Defendants stipulate, their undersigned counsel holds in escrow for no purpose other than payment to the Commission. Such payment must be made within 7 days of entry of this Order by electronic fund transfer in accordance with instructions previously provided by a representative of the Commission;
2. Within ten (10) days of entry of this Order, the Settling Defendants shall surrender or assign to the Liquidating Receiver all control, title, dominion and interest to and deliver to the Liquidating Receiver or his designated agent possession of the following property items and property rights identified in Attachment A to this Order. The Liquidating Receiver shall, as soon as practicable, commence the sale of the unliquidated assets identified above and surrendered or assigned pursuant to this Order using a commercially reasonable procedure. The Liquidating Receiver shall hold the surrendered or assigned assets, and the proceeds from the sale of the unliquidated assets, for future transfer to the Commission in accordance with further instructions from the Court.
C. Settling Defendants shall cooperate fully with the Commission and the Liquidating Receiver and take such steps as the Commission or the Liquidating Receiver may require, including delivering and providing access to the assets, executing any documents and providing any information, documents and signatures the Commission or the Liquidating Receiver may deem necessary, to effectuate the assignment, transfer, sale and liquidation of the assets or properties referenced in Subsection B above.
D. Upon delivery of all payments to the Commission and of all the assets to the Liquidating Receiver specified in Subsection B above, the remainder of the judgment against Settling Defendants is suspended, subject to Subsections E thru L below.
E. The Commission's agreement to the suspension of part of the judgment is expressly premised upon the truthfulness, accuracy, and completeness of Settling Defendants' sworn financial statements and related Documents (collectively, "Financial Representations") submitted to the Commission, namely:
1. The sworn amended Financial Statement of Individual Defendant Giannulis, executed on October 17, 2019, including attachments;
2. The sworn amended Financial Statement of Individual Defendant Williams, executed on October 18, 2019, including attachments;
3. The amended Financial Statement of Corporate Defendant BPO USA LLC, signed by Williams on October 15, 2019, including attachments dated October 18, 2019;
4. The amended Financial Statement of Corporate Defendant Pixx Media LLC, signed by Giannulis on October 17, 2019, including attachments dated October 18, 2019;
5. The Financial Statement of Corporate Defendant MyEcomClub Events LLC, signed by Williams on November 26, 2019;
6. The amended Financial Statement of Corporate Defendant Mike Antoni LLC, signed by Giannulis on October 17, 2019, including attachments dated October 18, 2019;
7. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via letter dated September 13, 2019 with subject line: "Responses to Questions and Additional Document Requests from FTC";
8. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via FTP file transfer on September 13, 2019 at 5:16pm EDT transmitting 35 secure files;
9. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via letter dated September 26, 2019 with subject line: "Responses to FTC's Monetary Demand and Counteroffer for Settlement";
10. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via letter dated September 27, 2019 with subject line: "Responses to FTC's Monetary Demand and Counteroffer for Settlement";
11. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via email on September 27, 2019 at 10:13 am EDT;
12. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via email on September 26, 2019 at 12:42 pm EDT, including attached PDF file entitled "BPO Settlement Asset schedule from FTC";
13. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via email on September 27, 2019 at 10:13 am EDT;
14. The supplement to Settlement Defendants' financial disclosures sent by Settling Defendants' counsel to FTC counsel via email on October 7, 2019 at 12:02 pm EDT, including 9 attached files;
15. The supplement to Settlement Defendants' financial disclosures sent by Settling Defendants' counsel to FTC counsel via email on October 14, 2019 at 8:20 pm EDT, including 5 attached files;
16. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via FTP file transfer on October 14, 2019 at 8:21 pm EDT transmitting 31 secure files;
17. The supplement to Settlement Defendants' financial disclosures sent by Settling Defendants' counsel to FTC counsel via email on October 18, 2019 at 11:46 pm EDT, including one attached PDF file entitled "2019.10.18 Letter to S. Kim and B. Davidson re Financial Statements,pdf," one attached excel file entitled "Debt and Asset Spreadsheet 10.18.2019.xlsx," and one zip file;
18. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via FTP file transfer on October 21, 2019 at 11:07 pm EDT transmitting 65 secure files;
19. The supplement to Settlement Defendants' financial disclosures sent by Settling Defendants' counsel to FTC counsel via letter dated October 28, 2019 entitled "47887274-v1-Response to Request for Supp Financial Data.pdf";
20. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via FTP file transfer on October 28, 2019 at 9:41 am EDT transmitting 46 secure files;
21. The supplement to Settling Defendants' financial disclosures sent by Settling Defendants' counsel to FTC counsel via letter dated November 27, 2019 entitled "48121622-v1-2019.11.27 - Letter to S. Kim and B. Davidson update re financials - revised date.pdf";
22. The supplement to Settling Defendants' financial disclosures submitted by Settling Defendants' counsel to FTC counsel via FTP file transfer on November 27, 2019 at 11:43 am EDT transmitting 203 secure files;
23. The declaration of Michael A. Giannulis, dated December 17, 2019, as to the completeness of disclosures regarding assets held by entities affiliated with BPO Corporate Defendants; and
24. The declaration of Michael R. Williams, dated December 16, 2019, as to the completeness of disclosures regarding assets held by entities affiliated with BPO Corporate Defendants.
F. The suspension of the judgment will be lifted as to any Settling Defendant if, upon motion by the Commission, the Court finds that Settling Defendant failed to disclose any material asset, materially misstated the value of any asset, or made any other material misstatement or omission in the financial representations identified above. G. If the suspension of the judgment is lifted, the judgment becomes immediately due as to that Settling Defendant in the amount specified in Subsection A above (which the parties stipulate only for purposes of this Section represents the unjust enrichment alleged in the Complaint), less any payments previously made pursuant to this Section, plus interest computed from the date of entry of this Order.

ADDITIONAL MONETARY PROVISIONS IT IS FURTHER ORDERED that:
A. Settling Defendants relinquish dominion and all legal and equitable right, title, and interest in all assets transferred pursuant to this Order and may not seek the return of any assets.
B. The facts alleged in the Complaint will be taken as true, without further proof, in any subsequent civil litigation by or on behalf of the Commission, including in a proceeding to enforce its rights to any payment or monetary judgment pursuant to this Order, such as a nondischargeability complaint in any bankruptcy case.
C. The facts alleged in the Complaint establish all elements necessary to sustain an action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes.
D. Settling Defendants acknowledge that their Taxpayer Identification Numbers (Social Security Numbers or Employer Identification Numbers) may be used for collecting and reporting on any delinquent amount arising out of this Order, in accordance with 31 U.S.C. § 7701.
E. All money paid to the Commission pursuant to this Order may be deposited into a fund administered by the Commission or its designee to be used for equitable relief, including consumer redress and any attendant expenses for the administration of any redress fund. If a representative of the Commission decides that direct redress to consumers is wholly or partially impracticable or money remains after redress is completed, the Commission may apply any remaining money for such other equitable relief (including consumer information remedies) as it determines to be reasonably related to Settling Defendants' practices alleged in the Complaint. Any money not used for such equitable relief is to be deposited to the U.S. Treasury as disgorgement. Settling Defendants have no right to challenge any actions the Commission or its representatives may take pursuant to this Subsection.

For more information you may visit Federal Trade Commission https://www.ftc.gov or by phone 202-326-3115.