Federal Trade Commission v. Good EBusiness, LLC et al

Filing 46

ORDER FOR PERMANENT INJUNCTION AND FINAL JUDGMENT AS TO DEFENDANTS TOBIAS AND KOMAL WEST 44 by Judge Otis D. Wright, II,Judgment in the amount of $2,329,456.00) is entered in favor of the Commission against Stipulating Defendants Komal West, T obias West, jointly and severally. Stipulating Defendants Tobias West and Komal West relinquish dominion and all legal and equitable right, title, and interest in favor of the FTC in all funds of Defendants Good EBusiness, LLC, Select Student Loan He lp, LLC, and SelectDocument Preparation, Inc., and Relief Defendant Beverly Hills Tax Group, LLC,remaining after payment of the fees authorized by the Court to the court-appointed receiver, Tom McNamara. (SEE DOCUMENT FOR SPECIFICS AND OTHER COMPLIANCE REQUIREMENTS ). (lc)

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DAVID C. SHONKA
Acting General Counsel
CHARLES A. HARWOOD
Regional Director
ELEANOR DURHAM MD Bar
Email: [e-mail]
Federal Trade Commission
915 2nd Ave., Suite 2896, Seattle, WA 98174
[phone] (Durham)
[phone] (fax)
STACY PROCTER, CA Bar # 221078
Email: [e-mail]
10877 Wilshire Blvd., Suite 700, Los Angeles, CA 90024
[phone] (Procter); [phone] (fax)
Attorneys for Plaintiff Federal Trade Commission
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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FEDERAL TRADE COMMISSION,
Plaintiff,
vs.
GOOD EBUSINESS, LLC, also d/b/a
AAP Firm; Student Loan Help Direct;
Select Student Loan; SELECT
STUDENT LOAN HELP, LLC;
SELECT DOCUMENT
PREPARATION, INC.; TOBIAS
WEST aka Tobey West, Toby West,
and Eric West; and KOMAL WEST,
Defendants, and
BEVERLY HILLS TAX GROUP,
LLC ,
Relief Defendant.

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LACV-16-1048-(ODW( JPRx)

ORDER FOR PERMANENT
INJUNCTION AND FINAL
JUDGMENT AS TO DEFENDANTS
TOBIAS AND KOMAL WEST

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Plaintiff, Federal Trade Commission (“Commission” or “FTC”), filed its

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Complaint for Permanent Injunction and Other Equitable Relief, subsequently

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amended as First Amended Complaint for Permanent Injunction and Other

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Equitable Relief (“Complaint”), pursuant to Section 13(b) of the Federal Trade

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Commission Act (“FTC Act”),15 U.S.C. § 53(b). The Commission and

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Defendants TOBIAS WEST aka Toby West, Tobey West, and Eric West, and

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KOMAL WEST (“Stipulating Defendants”) stipulate to entry of this Permanent

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Injunction and Final Judgment (“Order”) to resolve all matters in dispute in this

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action between them as follows:
FINDINGS OF FACT

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1.

This Court has jurisdiction over this matter.

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2.

The Complaint charges that Stipulating Defendants participated in deceptive

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acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), and

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the Mortgage Assistance Relief Services (“MARS Rule/Regulation O”), 12 C.F.R.

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§ 1015, and the Telemarketing Sales Rule, 16 C.F.R. § 310, in connection with the

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advertising, marketing, promotion, offering for sale, or sale of mortgage assistance

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relief services and student debt relief services.

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3.

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Complaint, except as specifically stated in this Order. Only for purposes of this

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action, Stipulating Defendants admit the facts necessary to establish jurisdiction.

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4.

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Access to Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this action

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through the date of this Order, and agree to bear their own costs and attorney fees.

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5.

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otherwise challenge or contest the validity of this Order.

Stipulating Defendants neither admit nor deny any of the allegations in the

Stipulating Defendants waive any claim that they may have under the Equal

Stipulating Defendants and the Commission waive all rights to appeal or
DEFINITIONS

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A.

“Assisting others” includes: (1) performing customer service functions,

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including receiving or responding to consumer complaints; (2) formulating or

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providing, or arranging for the formulation or provision of, any advertising or

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marketing material, including any telephone sales script, direct mail solicitation, or

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the design, text, or use of images of any Internet website, email, or other electronic

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communication; (3) formulating or providing, or arranging for the formulation or

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provision of, any marketing support material or service, including web or Internet

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Protocol addresses or domain name registration for any Internet websites, affiliate

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marketing services, or media placement services; (4) providing names of, or

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assisting in the generation of, potential customers; (5) performing marketing,

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billing, or payment services of any kind; or (6) acting or serving as an owner,

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officer, director, manager, or principal of any entity.

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B.

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program represented, expressly or by implication, to: (1) provide any consumer,

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arrange for any consumer to receive, or assist any consumer in receiving, a loan or

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other extension of credit; (2) provide any consumer, arrange for any consumer to

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receive, or assist any consumer in receiving, credit, debit, or stored value cards; (3)

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improve, repair, or arrange to improve or repair, any consumer’s credit record,

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credit history, or credit rating; or (4) provide advice or assistance to improve any

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consumer’s credit record, credit history, or credit rating.

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C.

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including a corporation, partnership, proprietorship, association, cooperative, or

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any other group or combination acting as an entity.

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D.

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“Financial product or service” means any product, service, plan, or

“Person” means a natural person, organization, or other legal entity,

“Secured or unsecured debt relief product or service” means:
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With respect to any mortgage, loan, debt, or obligation between a

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person and one or more secured or unsecured creditors or debt collectors, any

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product, service, plan, or program represented, expressly or by implication, to: (a)

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stop, prevent, or postpone any mortgage or deed of foreclosure sale for a person’s

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dwelling, any other sale of collateral, any repossession of a person’s dwelling or

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other collateral, or otherwise save a person’s dwelling or other collateral from
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foreclosure or repossession; (b) negotiate, obtain, or arrange a modification, or

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renegotiate, settle, or in any way alter any terms of the mortgage, loan, debt, or

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obligation, including a reduction in the amount of interest, principal balance,

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monthly payments, or fees owed by a person to a secured or unsecured creditor or

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debt collector; (c) obtain any forbearance or modification in the timing of

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payments from any secured or unsecured holder or servicer of any mortgage, loan,

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debt, or obligation; (d) negotiate, obtain, or arrange any extension of the period of

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time within which a person may (i) cure his or her default on the mortgage, loan,

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debt, or obligation, (ii) reinstate his or her mortgage, loan, debt, or obligation, (iii)

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redeem a dwelling or other collateral, or (iv) exercise any right to reinstate the

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mortgage, loan, debt, or obligation or redeem a dwelling or other collateral; (e)

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obtain any waiver of an acceleration clause or balloon payment contained in any

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promissory note or contract secured by any dwelling or other collateral; or (f)

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negotiate, obtain, or arrange (i) a short sale of a dwelling or other collateral, (ii) a

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deed-in-lieu of foreclosure, or (iii) any other disposition of a mortgage, loan, debt,

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or obligation other than a sale to a third party that is not the secured or unsecured

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loan holder. The foregoing shall include any manner of claimed assistance,

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including auditing or examining a person’s application for the mortgage, loan,

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debt, or obligation.
2.

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With respect to any loan, debt, or obligation between a person and one

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or more unsecured creditors or debt collectors, any product, service, plan, or

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program represented, expressly or by implication, to: (a) repay one or more

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unsecured loans, debts, or obligations; or (b) combine unsecured loans, debts, or

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obligations into one or more new loans, debts, or obligations.

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E.

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and Eric West, and Komal West.

“Stipulating Defendants” means Tobias West aka Tobey West, Toby West,

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ORDER

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I.

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AND SERVICES

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BAN ON SECURED AND UNSECURED DEBT RELIEF PRODUCTS
IT IS ORDERED that Stipulating Defendants are permanently restrained

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and enjoined from advertising, marketing, promoting, offering for sale, or selling,

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or assisting others in the advertising, marketing, promoting, offering for sale, or

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selling, of any secured or unsecured debt relief product or service.

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II.

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TO FINANCIAL PRODUCTS AND SERVICES

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PROHIBITION AGAINST MISREPRESENTATIONS RELATING
IT IS FURTHER ORDERED that Stipulating Defendants, and their

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officers, agents, employees, and attorneys, and all other persons or entities in

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active concert or participation with any of them, who receive actual notice of this

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Order, whether acting directly or indirectly, in connection with the advertising,

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marketing, promoting, offering for sale, or selling of any financial product or

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service, are permanently restrained and enjoined from misrepresenting, or assisting

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others in misrepresenting, expressly or by implication:

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A.

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including:

the terms or rates that are available for any loan or other extension of credit,

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closing costs or other fees;

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2.

the payment schedule, monthly payment amount(s), any balloon

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payment, or other payment terms;
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the interest rate(s), annual percentage rate(s), or finance charge(s), or

whether they are fixed or adjustable;
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the loan amount, credit amount, draw amount, or outstanding balance;

the loan term, draw period, or maturity; or any other term of credit;
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the amount of cash to be disbursed to the borrower out of the

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proceeds, or the amount of cash to be disbursed on behalf of the borrower to any

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third parties;

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whether any specified minimum payment amount covers both interest

and principal, or whether the credit has or can result in negative amortization; or

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that the credit does not have a prepayment penalty or whether

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subsequent refinancing may trigger a prepayment penalty and/or other fees;

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B.

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history, credit rating, or ability to obtain credit, including that a consumer’s credit

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record, credit history, credit rating, or ability to obtain credit can be improved by

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permanently removing current, accurate negative information from the consumer’s

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credit record or history;

the ability to improve or otherwise affect a consumer’s credit record, credit

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C.

that a consumer will receive legal representation; or

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D.

any other fact material to consumers concerning any financial product or

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service, such as: the total costs; any material restrictions, limitations, or conditions;

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or any material aspect of its performance, efficacy, nature, or central

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characteristics.

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III.

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TO ANY PRODUCTS OR SERVICES

PROHIBITION AGAINST MISREPRESENTATIONS RELATING
IT IS FURTHER ORDERED that Stipulating Defendants, and their

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officers, agents, employees, and attorneys, and all other persons in active concert

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or participation with any of them, who receive actual notice of this Order, whether

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acting directly or indirectly, in connection with advertising, marketing, promoting,

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offering for sale, or selling of any product, service, plan, or program, are hereby

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permanently restrained and enjoined from misrepresenting, or assisting others in

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misrepresenting, expressly or by implication:

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A.

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exchange, or repurchase policy, including the likelihood of a consumer obtaining a

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full or partial refund, or the circumstances in which a full or partial refund will be

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granted to the consumer;

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B.

any material aspect of the nature or terms of any refund, cancellation,

that any person is affiliated with, endorsed or approved by, or otherwise

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connected to any other person; government entity; public, non-profit, or other non-

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commercial program; or any other program;

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C.

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product, service, plan, or program;

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D.

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consumer;

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E.

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product, service, plan, or program;

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F.

the nature, expertise, position, or job title of any person who provides any
the person who will provide any product, service, plan, or program to any
that any person providing a testimonial has purchased, received, or used the
that the experience represented in a testimonial of the product, service, plan,

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or program represents the person’s actual experience resulting from the use of the

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product, service, plan, or program under the circumstances depicted in the

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advertisement; or

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as: the total costs; any material restrictions, limitations, or conditions; or any

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material aspect of its performance, efficacy, nature, or central characteristics.

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IV.

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any other fact material to consumers concerning any good or service, such

PROHIBITION AGAINST UNSUBSTANTIATED CLAIMS
IT IS FURTHER ORDERED that Stipulating Defendants, and their

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officers, agents, employees, and attorneys, and all other persons in active concert

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or participation with any of them, who receive actual notice of this Order, whether

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acting directly or indirectly, in connection with the sale of any product or service,

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are permanently restrained and enjoined from making any representation or

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assisting others in making any representation, expressly or by implication, about

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the benefits, performance, or efficacy of any product or service, unless the

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representation is non-misleading, and, at the time such representation is made,

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Stipulating Defendants possess and rely upon competent and reliable evidence that

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is sufficient in quality and quantity based on standards generally accepted in the

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relevant fields, when considered in light of the entire body of relevant and reliable

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evidence, to substantiate that the representation is true.

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V.

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MONETARY JUDGMENT AND PARTIAL SUSPENSION
IT IS FURTHER ORDERED that:

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A.

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four hundred fifty-six dollars ($2,329,456.00) is entered in favor of the

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Commission against Stipulating Defendants, jointly and severally, as equitable

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monetary relief.

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B.

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and all legal and equitable right, title, and interest in favor of the FTC in all funds

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of Defendants Good EBusiness, LLC, Select Student Loan Help, LLC, and Select

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Document Preparation, Inc., and Relief Defendant Beverly Hills Tax Group, LLC,

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remaining after payment of the fees authorized by the Court to the court-appointed

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receiver, Tom McNamara. Such payment, if any, shall be made by the holder of

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the funds by electronic fund transfer in accordance with instructions provided to

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the holder of the funds by a representative of the Commission. The remainder of

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the judgment is suspended upon payment of any such remaining funds to the FTC,

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or if no such funds remain, upon entry of this Order, subject to the Subsections

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below.

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C.

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expressly premised upon the truthfulness, accuracy, and completeness of

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Stipulating Defendants’ sworn financial statements dated March 1, 2016, and

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related documents (collectively, “financial representations”) submitted to the

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Commission.

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D.

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Defendant if, upon motion by the Commission, the Court finds that Stipulating

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Defendant failed to disclose any material asset, materially misstated the value of

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any asset, or made any other material misstatement or omission in the financial

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representations identified above.

Judgment in the amount of two million three hundred twenty-nine thousand

Stipulating Defendants Tobias West and Komal West relinquish dominion

The Commission’s agreement to the suspension of part of the judgment is

The suspension of the judgment will be lifted as to any Stipulating

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E.

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immediately due in the amount specified in Subsection A above (which the parties

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stipulate only for purposes of this Section) which represents the consumer injury

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alleged in the Complaint, less any payment previously made pursuant to this

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Section, plus interest computed from the date of entry of this Order.

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VI.

OTHER MONETARY PROVISIONS

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A.

Stipulating Defendants relinquish dominion and all legal and equitable right,

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title, and interest in all assets transferred pursuant to this Order and may not seek

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the return of any assets.

If the suspension of the judgment is lifted, the judgment becomes

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B.

The facts alleged in the Complaint will be taken as true, without further

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proof, in any subsequent civil litigation by or on behalf of the Commission,

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including in a proceeding to enforce its rights to any payment or money judgment

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pursuant to this Order, such as a nondischargeablity complaint in any bankruptcy

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case.

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C.

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an action by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy

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Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect

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for such purposes.

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D.

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Numbers and Social Security Numbers, which Stipulating Defendants previously

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submitted to the Commission, may be used for collecting and reporting on any

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delinquent amount arising out of this Order, in accordance with 31 U.S.C. § 7701.

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E.

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into a fund administered by the Commission or its designee to be used for

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equitable relief, including consumer redress and any attendant expenses for the

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administration of any redress fund. If a representative of the Commission decides

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that direct redress to consumers is wholly or partially impracticable or money

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remains after redress is completed, the Commission may apply any remaining

The facts alleged in the Complaint establish all elements necessary to sustain

Stipulating Defendants acknowledge that the Taxpayer Identification

All money paid to the Commission pursuant to this Order may be deposited

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money for such other equitable relief (including consumer information remedies)

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as it determines to be reasonably related to Stipulating Defendants’ practices

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alleged in the Complaint. Any money not used for such equitable relief is to be

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deposited to the U.S. Treasury as disgorgement. Stipulating Defendants have no

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right to challenge any actions the Commission or its representative may take

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pursuant to this Subsection.

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F.

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aka Tobey West, Toby West, and Eric West, and Komal West, pursuant to the

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Preliminary Injunction entered in this action is lifted.

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Upon entry of this Order, the freeze on the personal assets of Tobias West

VII. CUSTOMER INFORMATION
IT IS FURTHER ORDERED that Stipulating Defendants and their

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officers, agents, employees, and attorneys, and those persons or entities in active

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concert or participation with them who receive actual notice of this Order by

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personal service or otherwise, whether acting directly or through any corporation,

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subsidiary, division, or other device, are hereby permanently restrained and

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enjoined from directly or indirectly:

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A.

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name, address, telephone number, email address, social security number, other

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identifying information, or any data that enables access to a customer’s account

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(including a credit card, bank account, or other financial account), that any

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Stipulating Defendant obtained prior to entry of this Order; and

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B.

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custody, or control within thirty (30) days after receipt of written direction to do so

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from a representative of the Commission.

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disclosing, using, or benefitting from customer information, including the

failing to destroy such customer information in all forms in their possession,

Provided, however, that customer information need not be disposed of,

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and may be disclosed, to the extent requested by a government agency or required

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by law, regulation, or court order.

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VIII. ORDER ACKNOWLEDGMENTS

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IT IS FURTHER ORDERED that Stipulating Defendants obtain

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acknowledgments of receipt of this Order:

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A.

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must submit to the Commission an acknowledgment of receipt of this Order sworn

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under penalty of perjury.

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B.

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business that such Stipulating Defendants, individually or collectively with any

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other Defendant, is the majority owner or controls directly or indirectly, must

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deliver a copy of this Order to: (1) all principals, officers, directors, and LLC

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managers and members; (2) all employees, agents, and representatives who

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participate in conduct related to the subject matter of this Order; and (3) any

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business entity resulting from any change in structure as set forth in the Section

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titled Compliance Reporting. Delivery must occur within seven (7) days of entry

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of this Order for current personnel. For all others, delivery must occur before they

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assume their responsibilities.

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C.

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copy of this Order, that Stipulating Defendant must obtain, within thirty (30) days,

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a signed and dated acknowledgment of receipt of this Order.

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IX.

Each Stipulating Defendant, within seven (7) days of entry of this Order,

For five (5) years after entry of this Order, Stipulating Defendants, for any

From each individual or entity to which a Stipulating Defendant delivered a

COMPLIANCE REPORTING
IT IS FURTHER ORDERED that Stipulating Defendants make timely

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submissions to the Commission:

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A.

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compliance report, sworn under penalty of perjury. Stipulating Defendants must:

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One year after entry of this Order, each Stipulating Defendant must submit a
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identify the primary physical, postal, and email address and telephone

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number, as designated points of contact, which representatives of the Commission

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may use to communicate with Stipulating Defendants;

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2.

identify all of Stipulating Defendants’ businesses by all of their

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names, telephone numbers, and physical, postal, email, and Internet addresses;

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describe the activities of each business, including the goods and

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services offered, the means of advertising, marketing, and sales, and the

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involvement of any other Stipulating Defendant;

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4.

describe in detail whether and how Stipulating Defendants are in

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compliance with each Section of this Order; (e) provide a list of all domain names

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held or registered by any Stipulating Defendant; and
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provide a copy of each Order Acknowledgment obtained pursuant to

this Order, unless previously submitted to the Commission.

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B.

For ten (10) years after entry of this Order, each Stipulating Defendant must

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submit a compliance notice, sworn under penalty of perjury, within fourteen (14)

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days of any change in the following:

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any designated point of contact; or

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2.

the structure of any entity that Stipulating Defendants have any

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ownership interest in or control directly or indirectly that may affect compliance

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obligations arising under this Order, including: creation, merger, sale, or

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dissolution of the entity or any subsidiary, parent, or affiliate that engages in any

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acts or practices subject to this Order; and

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C.

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filing of any bankruptcy petition, insolvency proceeding, or similar proceeding by

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or against such Stipulating Defendant within fourteen (14) days of its filing.

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D.

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penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746,

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such as by concluding: “I declare under penalty of perjury under the laws of the

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United States of America that the foregoing is true and correct. Executed on:

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_____” and supplying the date, signatory’s full name, title (if applicable), and

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signature.

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E.

Each Stipulating Defendant must submit to the Commission notice of the

Any submission to the Commission required by this Order to be sworn under

Unless otherwise directed by a Commission representative in writing, all

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submissions to the Commission pursuant to this Order must be emailed to

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[e-mail] or sent by overnight courier (not the U.S. Postal Service) to:

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Associate Director for Enforcement, Bureau of Consumer Protection, Federal

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Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The

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subject line must begin: FTC v. Good EBusiness, LLC, et al., X160029.

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X.

RECORDKEEPING

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IT IS FURTHER ORDERED that Stipulating Defendants must create

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certain records for ten (10) years after entry of the Order, and retain each such

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record for five (5) years. Specifically, for any business for which such Stipulating

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Defendant, individually or collectively, is a majority owner or controls directly or

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indirectly, must create and retain the following records:

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A.

accounting records showing the revenues from all goods or services sold;

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B.

personnel records showing, for each person providing services, whether as

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an employee or otherwise, that person’s: name; addresses; telephone numbers; job

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title or position; dates of service; and (if applicable) the reason for termination;

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C.

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directly or indirectly, such as through a third party, and any response;

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D.

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this Order, including all submissions to the Commission; and

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E.

a copy of each unique advertisement or other marketing material.

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XI.

COMPLIANCE MONITORING

records of all consumer complaints and refund requests, whether received
all records necessary to demonstrate full compliance with each provision of

IT IS FURTHER ORDERED that, for the purpose of monitoring

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Stipulating Defendants’ compliance with this Order, including the financial

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attestations upon which all or part of the judgment was suspended and any failure

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to transfer any assets as required by this Order:

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A.

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representative of the Commission, each Stipulating Defendant must: submit

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additional compliance reports or other requested information, which must be sworn

Within fourteen (14) days of receipt of a written request from a

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under penalty of perjury; appear for depositions; and produce documents for

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inspection and copying. The Commission is also authorized to obtain discovery,

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without further leave of court, using any of the procedures prescribed by Federal

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Rules of Civil Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 36,

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45, and 69.

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B.

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communicate directly with each Stipulating Defendant. Stipulating Defendants

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must permit representatives of the Commission to interview any employee or other

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person affiliated with any Stipulating Defendant who has agreed to such an

For matters concerning this Order, the Commission is authorized to

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interview. The person interviewed may have counsel present.

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C.

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its representatives as consumers, suppliers, or other individuals or entities, to

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Stipulating Defendants or any individual or entity affiliated with Stipulating

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Defendants, without the necessity of identification or prior notice. Nothing in this

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Order limits the Commission’s lawful use of compulsory process, pursuant to

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Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1.

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XII. ENTRY OF JUDGMENT

The Commission may use all other lawful means, including posing, through

IT IS FURTHER ORDERED that there is no just reason for delay of entry

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of this judgment, and that, pursuant to Federal Rule of Civil Procedure 54(b), the

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Clerk immediately shall enter this Order as a final judgment as to Stipulating

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Defendants.

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XIII. RETENTION OF JURISDICTION
IT IS FURTHER ORDERED that this Court retains jurisdiction of this
matter for purposes of construction, modification, and enforcement of this Order.

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DATED: May 13, 2016

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Hon. Otis D. Wright

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UNITED STATES DISTRICT JUDGE

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