Federal Trade Commission v. Health Formulas, LLC et al

Filing 220

ORDER Granting #201 Stipulation for Permanent Injunction. Judgment in the amount of One Hundred Five Million Dollars ($105,000,000) is entered in favor of the Commission and against the Individual Defendants and Corporate Defendants, jointly and severally, as equitable monetary relief (see Order for details). Signed by Judge Richard F. Boulware, II on 2/22/2017. (Copies have been distributed pursuant to the NEF - SLD)

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DAVID C. SHONKA
Acting General Counsel
DANIELLE ESTRADA
[e-mail]
MELISSA DICKEY
[e-mail]
Federal Trade Commission
600 Pennsylvania Avenue, NW, CC-8528
Washington, DC 20580
202-326-2630 (Estrada)
202-326-2662 (Dickey)
202-326-3395 (Fax)

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BLAINE T. WELSH
[e-mail]
Assistant United States Attorney
Nevada Bar No. 4790
333 Las Vegas Blvd. South, Suite 5000
Las Vegas, NV 89101
702-388-6336
702-388-6787 (Fax)

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Attorneys for Plaintiff Federal Trade Commission

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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FEDERAL TRADE COMMISSION,

Civil Action No. 2:14-cv-01649-RFB-GWF

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Plaintiff,
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NOTICE OF FILING STIPULATED
FINAL ORDER FOR PERMANENT
INJUNCTION AS TO DEFENDANTS
JASON MILLER, DANELLE MILLER,
458 MEDIA LLC; ALPHA BRANDS,
LLC; BARREL ROLL, LLC; BLU
STELLA, LLC; BRILLIANT SKIN LLC;
BSC MARKETING, LLC; CHERRY
HILL MARKETING, LLC; CSA
VENTURES, LLC; DIET CONCEPTS,
LLC; DISCOUNT PROVISIONS L.L.C.;
DJD DISTRIBUTION, LLC; EXTAMAX,
LLC; F12 MEDIA LLC; FLEX
FORMULAS, LLC; GCB MARKETING

v.
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HEALTH FORMULAS, LLC, et al.,
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Defendants.
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LLC; HEALTH FORMULAS, LLC;
HEALTH PRODUCTS DIRECT LLC;
KMS MARKETING LLC; LONGHORN
MARKETING, LLC; LUMINOUS SKIN
LLC; MDCC, LLC; MEN’S HEALTH
FORMULAS, LLC; METABOLIC LABS,
LLC; METHOD DIRECT, LLC;
METHOD FILMS, INC.; MIRACLE
MALE, LLC; MORINGA MARKETING
LLC; NATURAL PRODUCTS DIRECT
LLC; NORTHBOUND MARKETING
LLC; NORTHERN HEALTH
PRODUCTS LLC; PURE AND
NATURAL HEALTH PRODUCTS LLC;
PURE AND SIMPLE HEALTH
PRODUCTS LLC; PURE VITAMINS,
LLC; RADIANT SKIN LLC;
SHIMMERING SKIN LLC; SKINNY 7
LLC; TINDY FILMS LLC; WEIGHT
LOSS DOJO, LLC; WELLNESS LABS,
LLC; WELLNESS PRODUCTS, LLC;
VIP SAVINGS, LLC; AND YACON
MARKETING LLC.

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Plaintiff, Federal Trade Commission respectfully submits for the Court’s review the attached

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Stipulated Permanent Injunction and Final Order against all the remaining defendants in the matter,

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Defendants Jason Miller; Danelle Miller; 458 Media LLC; Alpha Brands, LLC; Barrel Roll,

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LLC; Blu Stella, LLC; Brilliant Skin LLC; BSC Marketing, LLC; Cherry Hill Marketing, LLC;

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CSA Ventures, LLC; Diet Concepts, LLC; Discount Provisions L.L.C.; DJD Distribution, LLC;

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Extamax, LLC; F12 Media LLC; Flex Formulas, LLC; GCB Marketing LLC; Health Formulas,

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LLC; Health Products Direct LLC; KMS Marketing LLC; Longhorn Marketing, LLC; Luminous

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Skin LLC; MDCC, LLC; Men’s Health Formulas, LLC; Metabolic Labs, LLC; Method Direct,

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LLC; Method Films, Inc.; Miracle Male, LLC; Moringa Marketing LLC; Natural Products Direct

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LLC; Northbound Marketing LLC; Northern Health Products LLC; Pure and Natural Health

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Products LLC; Pure and Simple Health Products LLC; Pure Vitamins, LLC; Radiant Skin LLC;

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Shimmering Skin LLC; Skinny 7 LLC; Tindy Films LLC; Weight Loss Dojo, LLC; Wellness

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Labs, LLC; Wellness Products, LLC; VIP Savings, LLC; and Yacon Marketing LLC

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DATED: April 26, 2016

Respectfully submitted,

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/s/Danielle Estrada
DANIELLE ESTRADA
MELISSA L. DICKEY
Federal Trade Commission
600 Pennsylvania Avenue N.W.
Mail Stop CC-8528
Washington, D.C. 20580
[phone] (Estrada)
[phone] (Dickey)
[phone] (facsimile)
[e-mail]
[e-mail]

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Certificate of Service

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I hereby certify that on April 26, 2016, I electronically filed the foregoing document with

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the Clerk of the Court using CM/ECF, which will send a notice of electronic filing to all counsel

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of record.

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Date: April 26, 2016

/s/Danielle Estrada
DANIELLE ESTRADA

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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FEDERAL TRADE COMMISSION,

Case No. 2:14-cv-01649-RFB-GWF

Plaintiff,
v.

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JASON MILLER, individually and as an officer or
manager of Weight Loss Dojo, LLC, Health
Formulas, LLC, Method Direct, LLC, Pure
Vitamins, LLC, and MDCC, LLC; and
DANELLE MILLER, also known as Danelle Folta
and Danelle Kenealy, individually and as an
officer or manager of Method Direct, LLC,
Health Formulas, LLC, MDCC, LLC, Pure
Vitamins, LLC, and Weight Loss Dojo,
LLC,
458 MEDIA LLC, a limited liability company;

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ALPHA BRANDS, LLC, a limited liability
company;
BARREL ROLL, LLC, a limited liability company;
BLU STELLA, LLC, a limited liability company;

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BRILLIANT SKIN LLC, a limited liability
company;
BSC MARKETING, LLC, a limited liability
company;
CHERRY HILL MARKETING, LLC, a limited
liability company;

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CSA VENTURES, LLC, a limited liability
company;

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STIPULATED ORDER FOR
PERMANENT INJUNCTION AND
MONETARY JUDGMENT FOR
DEFENDANTS JASON MILLER,
DANELLE MILLER, 458 MEDIA LLC;
ALPHA BRANDS, LLC; BARREL
ROLL, LLC; BLU STELLA, LLC;
BRILLIANT SKIN LLC; BSC
MARKETING, LLC; CHERRY HILL
MARKETING, LLC; CSA VENTURES,
LLC; DIET CONCEPTS, LLC;
DISCOUNT PROVISIONS L.L.C.; DJD
DISTRIBUTION, LLC; EXTAMAX,
LLC; F12 MEDIA LLC; FLEX
FORMULAS, LLC; GCB MARKETING
LLC; HEALTH FORMULAS, LLC;
HEALTH PRODUCTS DIRECT LLC;
KMS MARKETING LLC; LONGHORN
MARKETING, LLC; LUMINOUS SKIN
LLC; MDCC, LLC; MEN’S HEALTH
FORMULAS, LLC; METABOLIC
LABS, LLC; METHOD DIRECT, LLC;
METHOD FILMS, INC.; MIRACLE
MALE, LLC; MORINGA MARKETING
LLC; NATURAL PRODUCTS DIRECT
LLC; NORTHBOUND MARKETING
LLC; NORTHERN HEALTH
PRODUCTS LLC; PURE AND
NATURAL HEALTH PRODUCTS LLC;
PURE AND SIMPLE HEALTH
PRODUCTS LLC; PURE VITAMINS,
LLC; RADIANT SKIN LLC;
SHIMMERING SKIN LLC; SKINNY 7
LLC; TINDY FILMS LLC; WEIGHT
LOSS DOJO, LLC; WELLNESS LABS,
LLC; WELLNESS PRODUCTS, LLC;
VIP SAVINGS, LLC; AND YACON
MARKETING LLC.

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DIET CONCEPTS, LLC, a limited liability
company;

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DISCOUNT PROVISIONS L.L.C., a limited
liability company;
DJD DISTRIBUTION, LLC, a limited liability
company;

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EXTAMAX, LLC, a limited liability company;

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F12 MEDIA LLC, a limited liability company;

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FLEX FORMULAS, LLC, a limited liability
company;

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GCB MARKETING LLC, a limited liability
company;

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HEALTH FORMULAS, LLC, a limited liability
company;
HEALTH PRODUCTS DIRECT LLC, a limited
liability company;
KMS MARKETING LLC, a limited liability
company;
LONGHORN MARKETING, LLC, a limited
liability company;

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LUMINOUS SKIN LLC, a limited liability
company;
MDCC, LLC, a limited liability company;
MEN’S HEALTH FORMULAS, LLC, a limited
liability company;
METABOLIC LABS, LLC, a limited liability
company;
METHOD DIRECT, LLC, a limited liability
company;
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METHOD FILMS, INC., a corporation;

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MIRACLE MALE, LLC, a limited liability
company;
MORINGA MARKETING LLC, a limited liability
company;
NATURAL PRODUCTS DIRECT LLC, a limited
liability company;

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NORTHBOUND MARKETING LLC, a limited
liability company;
NORTHERN HEALTH PRODUCTS LLC, a
limited liability company;
PURE AND NATURAL HEALTH PRODUCTS
LLC, a limited liability company;
PURE AND SIMPLE HEALTH PRODUCTS LLC,
a limited liability company;

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PURE VITAMINS, LLC, a limited liability
company;
RADIANT SKIN LLC, a limited liability company;

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SHIMMERING SKIN LLC, a limited liability
company;

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SKINNY 7 LLC, a limited liability company;

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TINDY FILMS LLC, a limited liability company;
WEIGHT LOSS DOJO, LLC, a limited liability
company;
WELLNESS LABS, LLC, a limited liability
company;
WELLNESS PRODUCTS, LLC, a limited liability
company;
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VIP SAVINGS, LLC, a limited liability company;
and
YACON MARKETING LLC, a limited liability
company.

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Defendants.

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Plaintiff, the Federal Trade Commission (“Commission” or “FTC”), filed its Complaint
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for Permanent Injunction and Other Equitable Relief, subsequently amended as Amended
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Complaint for Permanent Injunction and Other Equitable Relief (“Complaint”), for a permanent
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injunction and other equitable relief in this matter, pursuant to Sections 13(b) and 19 of the
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Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 53(b), 57b. The Commission and
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Defendants Jason Miller; Danelle Miller; 458 Media LLC; Alpha Brands, LLC; Barrel Roll,
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LLC; Blu Stella, LLC; Brilliant Skin LLC; BSC Marketing, LLC; Cherry Hill Marketing, LLC;
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CSA Ventures, LLC; Diet Concepts, LLC; Discount Provisions L.L.C.; DJD Distribution, LLC;
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Extamax, LLC; F12 Media LLC; Flex Formulas, LLC; GCB Marketing LLC; Health Formulas,
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LLC; Health Products Direct LLC; KMS Marketing LLC; Longhorn Marketing, LLC; Luminous
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Skin LLC; MDCC, LLC; Men’s Health Formulas, LLC; Metabolic Labs, LLC; Method Direct,
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LLC; Method Films, Inc.; Miracle Male, LLC; Moringa Marketing LLC; Natural Products Direct
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LLC; Northbound Marketing LLC; Northern Health Products LLC; Pure and Natural Health
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Products LLC; Pure and Simple Health Products LLC; Pure Vitamins, LLC; Radiant Skin LLC;
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Shimmering Skin LLC; Skinny 7 LLC; Tindy Films LLC; Weight Loss Dojo, LLC; Wellness
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Labs, LLC; Wellness Products, LLC; VIP Savings, LLC; and Yacon Marketing LLC stipulate to
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the entry of this Stipulated Order for Permanent Injunction and Monetary Judgment (“Order”) to
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resolve all matters in dispute in this action between them.
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THEREFORE, IT IS ORDERED as follows:
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FINDINGS

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1.

This Court has jurisdiction over this matter.

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2.

The Complaint charges that Defendants participated in deceptive acts or practices in

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violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) & 52; Section 907(a) of the

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Electronic Fund Transfer Act, 15 U.S.C. § 1693e(a); Section 4 of the Restore Online Shoppers’

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Confidence Act, 15 U.S.C. § 8403; Section 205.10(b) of Regulation E, 12 C.F.R. § 205.10(b);

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and the FTC’s Trade Regulation Rule entitled the Telemarketing Sales Rule (“TSR”), 16 C.F.R.

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Part 310, in connection with the deceptive labeling, advertising, marketing, promotion, offering

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for sale, or sale of Dietary Supplements, skin creams, and Upsell products.

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3.

Defendants neither admit nor deny any of the allegations in the Complaint, except as

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specifically stated in this Order. Only for purposes of this action, Defendants admit the facts

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necessary to establish jurisdiction.

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4.

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28 U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, and

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agree to bear their own costs and attorney fees. Defendants further waive and release any claims

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that they may have against the Commission, the Receiver, and their agents that relate to this

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action.

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5.

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contest the validity of this Order.

Defendants waive any claim that they may have under the Equal Access to Justice Act,

Defendants and the Commission waive all rights to appeal or otherwise challenge or

DEFINITIONS

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For the purpose of this Order, the following definitions apply:

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A.

“Acquirer” means a business organization, financial institution, or an agent of a business

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organization or financial institution that has authority from an organization that operates or

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licenses a credit card system (e.g., Visa, MasterCard, American Express, and Discover) to

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authorize Merchants to accept, transmit, or process payment by credit card through the credit

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card system for money, goods or services, or anything else of value.

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B.

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against the consumer’s credit card, debit card, bank account, phone bill, or other account, or

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otherwise attempting to collect money or other consideration.

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C.

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(i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of the

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following ways:

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1.

“Charge” includes causing billing information to be submitted for payment, including

“Clear(ly) and Conspicuous(ly)” means that a required disclosure is difficult to miss

In any communication that is solely visual or solely audible, the disclosure must

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be made through the same means through which the communication is presented. In any

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communication made through both visual and audible means, such as a television

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advertisement, the disclosure must be presented simultaneously in both the visual and

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audible portions of the communication even if the representation requiring the disclosure

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is made in only one means.

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2.

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and other characteristics, must stand out from any accompanying text or other visual

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elements so that it is easily noticed, read, and understood.

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3.

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delivered in a volume, speed, and cadence sufficient for ordinary consumers to easily

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hear and understand it.

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4.

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Internet or software, the disclosure must be unavoidable.

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5.

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panel.

A visual disclosure, by its size, contrast, location, the length of time it appears,

An audible disclosure, including by telephone or streaming video, must be

In any communication using an interactive electronic medium, such as the

On a product label, the disclosure must be presented on the principal display

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6.

The disclosure must use diction and syntax understandable to ordinary consumers

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and must appear in each language in which the representation that requires the disclosure

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appears.

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7.

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which it is received, including all electronic devices and face-to-face communications.

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8.

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anything else in the communication.

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9.

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children, the elderly, or the terminally ill, “ordinary consumers” includes reasonable

The disclosure must comply with these requirements in each medium through

The disclosure must not be contradicted or mitigated by, or inconsistent with,

When the representation or sales practice targets a specific audience, such as

members of that group.

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D.

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LLC; Blu Stella, LLC; Brilliant Skin LLC; BSC Marketing, LLC; Cherry Hill Marketing, LLC;

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CSA Ventures, LLC; Diet Concepts, LLC; Discount Provisions L.L.C.; DJD Distribution, LLC;

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Extamax, LLC; F12 Media LLC; Flex Formulas, LLC; GCB Marketing LLC; Health Formulas,

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LLC; Health Products Direct LLC; KMS Marketing LLC; Longhorn Marketing, LLC; Luminous

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Skin LLC; MDCC, LLC; Men’s Health Formulas, LLC; Metabolic Labs, LLC; Method Direct,

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LLC; Method Films, Inc.; Miracle Male, LLC; Moringa Marketing LLC; Natural Products Direct

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LLC; Northbound Marketing LLC; Northern Health Products LLC; Pure and Natural Health

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Products LLC; Pure and Simple Health Products LLC; Pure Vitamins, LLC; Radiant Skin LLC;

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Shimmering Skin LLC; Skinny 7 LLC; Tindy Films LLC; Weight Loss Dojo, LLC; Wellness

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Labs, LLC; Wellness Products, LLC; VIP Savings, LLC; and Yacon Marketing LLC, and their

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successors, assigns, affiliates, and subsidiaries.

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E.

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“Corporate Defendants” means 458 Media LLC; Alpha Brands, LLC; Barrel Roll,

“Credit Card Factoring” means:
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Presenting or depositing into, or causing or allowing another to present or deposit
into, the credit card system for payment, a Credit Card Sales Draft generated by a

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transaction that is not the result of a credit card transaction between the

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cardholder and any of the Defendants;
2.

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Employing, soliciting, or otherwise causing or allowing a Merchant, or an

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employee, representative, or agent of a Merchant, to present to or deposit into the

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credit card system for payment, a Credit Card Sales Draft generated by a

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transaction that is not the result of a credit card transaction between the

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cardholder and the Merchant; or
3.

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Obtaining access to the credit card system through the use of a business
relationship or an affiliation with a Merchant, when such access is not authorized

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by the Merchant Account agreement or the applicable credit card system.

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F.

“Credit Card Sales Draft” means any record or evidence of a credit card transaction.

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G.

“Defendants” means all of the Individual Defendants and the Corporate Defendants,

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individually, collectively, or in any combination.

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H.

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“Dietary Supplement” means:
1.

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any product labeled as a Dietary Supplement or otherwise represented as a
Dietary Supplement; or

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2.

any pill, tablet, capsule, powder, soft gel, gel cap, liquid, or other similar form

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containing one or more ingredients that are a vitamin, mineral, herb or other

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botanical, amino acid, probiotic, or other dietary substance for use by humans to

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supplement the diet by increasing the total dietary intake, or a concentrate,

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metabolite, constituent, extract, or combination of any ingredient described above,

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that is intended to be ingested, and is not represented to be used as a conventional

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Food or as a sole item of a meal or the diet.

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I.

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official Homoeopathic Pharmacopoeia of the United States, or official National Formulary, or

“Drug” means: (a) articles recognized in the official United States Pharmacopoeia,

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any supplement to any of them; (b) articles intended for use in the diagnosis, cure, mitigation,

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treatment, or prevention of disease in humans or other animals; (c) articles (other than Food)

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intended to affect the structure or any function of the body of humans or other animals; and

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(d) articles intended for use as a component of any article specified in (a), (b), or (c); but does

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not include devices or their components, parts, or accessories.

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J.

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(b) chewing gum; and (c) any article used for components of any such article.

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K.

“Individual Defendants” means Jason Miller and Danelle Miller.

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L.

“Merchant” means a Person who is authorized under a written contract with an Acquirer

“Food” means: (a) any article used for Food or drink for humans or other animals;

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to honor or accept credit cards, or to transmit or process for payment credit card Charges, for the

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purchase of goods or services.

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M.

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Merchant to honor or accept credit cards, or to transmit or process for payment credit card

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Charges, for the purchase of goods or services or a charitable contribution.

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N.

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or service, a provision under which the consumer’s silence or failure to take an affirmative action

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to reject a good or service or to cancel the agreement is interpreted by the seller or provider as

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acceptance or continuing acceptance of the offer or agreement.

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O.

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induce the purchase of goods or services or to solicit a charitable contribution.

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P.

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corporation, limited liability company, partnership, proprietorship, association, cooperative,

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government or governmental subdivision or agency, or any other group or combination acting as

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an entity.

“Merchant Account” means an account with an Acquirer that authorizes and allows a

“Negative Option Feature” means, in an offer or agreement to sell or provide any good

“Outbound Telephone Call” means a telephone call initiated by a Telemarketer to

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

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Q.

“Receiver” means Robb Evans & Associates LLC, the temporary receiver appointed in

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Section XIII of the Preliminary Injunction Order issued as to the Defendants [D.E. 149] and

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whose appointment is continued in Section XII of this Order and any deputy receivers that shall

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be named by the Receiver.

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R.

“Receivership Defendants” means all of the Corporate Defendants.

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S.

“Receivership Estate” means all assets of the Corporate Defendants, including but not

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limited to: (a) any assets of the Corporate Defendants currently in the possession of the Receiver,

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including but not limited to accounts identified in Appendix 6; (b) all the funds, property,

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premises, accounts, documents, mail, and all other assets of, or in the possession or under the

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control of the Corporate Defendants, wherever situated, the income and profits therefrom, all

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sums of money now or hereafter due or owing to the Corporate Defendants, and any other assets

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or property belonging or owed to the Corporate Defendants; (c) any assets of the Corporate

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Defendants held in asset protection trusts; (d) any reserve funds or other accounts associated with

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any payments processed on behalf of any Corporate Defendant, including but not limited to, such

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reserve funds held by a payment processor, credit card processor, or bank, and including but not

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limited to accounts identified in Appendices 1 through 3 and Appendices 7 through 12; and

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(e) all proceeds from the sale of such assets, except those assets the sale of which the Receiver

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determines will not add appreciably to the value of the estate.

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T.

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test has been published in a peer-reviewed journal, and such published report provides sufficient

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information about the test for experts in the relevant field to assess the reliability of the results.

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U.

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receives telephone calls to or from a customer or donor.

“Reliably Reported,” for a human clinical test or study (“test”), means a report of the

“Telemarketer” means any Person who, in connection with Telemarketing, initiates or

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V.

“Telemarketing” means any plan, program, or campaign which is conducted to induce

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the purchase of goods or services by use of one or more telephones, and which involves a

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telephone call, whether or not covered by the TSR.

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W.

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transaction during a single telephone call.

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X.

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packaged, distributed, advertised, promoted, offered for sale, or sold for the express or implied

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purpose of causing weight loss, maintaining weight loss, maintaining weight, or otherwise

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affecting weight gain or loss, whether individually or in any combination. For the purposes of

“Upsell” means a solicitation for the purchase of any good or service following an initial

“Weight Loss Product” means any product, service, or program manufactured, labeled,

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this Order only, “Weight Loss Product” does not mean or include an exercise program or

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exercise equipment.

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ORDER

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I.

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BAN ON NEGATIVE OPTION SALES

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IT IS ORDERED that Defendants are permanently restrained and enjoined from

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advertising, marketing, promoting, or offering for sale any good or service with a Negative

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Option Feature, whether directly or through an intermediary, including by consulting, planning,

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participating, facilitating or advising.

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II.

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BAN ON SALES OF WEIGHT LOSS PRODUCTS

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IT IS FURTHER ORDERED that Defendants are permanently restrained and enjoined

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from manufacturing, labeling, packaging, advertising, marketing, promotion, offering for sale,

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sale, or distribution, or assisting in the manufacturing, labeling, packaging, advertising,

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marketing, promotion, offering for sale, sale, or distribution of any Weight Loss Product.

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III.

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PROHIBITED BUSINESS ACTIVITIES

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IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, and

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employees, and all other Persons in active concert or participation with any of them, who receive

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actual notice of this Order, whether acting directly or indirectly, in connection with promoting or

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offering for sale any good or service are permanently restrained and enjoined from:

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A.

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assisting others in failing to disclose in a Clear and Conspicuous manner, expressly or by

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implication, all material terms and conditions of any offer, including:

Before a customer consents to pay for such good or service, failing to disclose, or

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1.

the total cost or price of the good or service;

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2.

the amount, timing, and manner of all fees, Charges or other amounts that a

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consumer will be Charged or billed, including but not limited to the date of the

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Charge and whether it will be a credit card or checking account Charge; and
3.

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the mechanism for consumers to stop a Charge.

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B.

Before a customer consents to pay for such good or service, failing to disclose, or

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assisting others in failing to disclose in a Clear and Conspicuous manner, expressly or by

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implication, all material terms and conditions of any refund and cancellation policy, including:

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1.

the specific steps and means by which such requests must be submitted;

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2.

the customer service telephone number or numbers that a customer must call to
cancel and return goods or services;

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3.

directed;

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the email address, web address, or street address to which such requests must be

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any mechanism that customers must use to return any goods or services, including

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any requirement for specific tracking methods or delivery confirmation for a

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package;

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5.

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if there is any policy of not making refunds or cancellations, including any

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requirement that a product will not be accepted for return or refund unless it is

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unopened and in re-sellable condition, a statement regarding this policy; and
6.

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the duration of Defendants’ refund and cancellation policy, including the date that
it begins to run.

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C.

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fact material to consumers concerning any good or service, such as:

8

Misrepresenting, or assisting others in misrepresenting, expressly or by implication, any

1.

obligation;

9
10

2.

that consumers can obtain a good or service for a minimal processing, service, or
administrative fee with no further obligation;

11
12

that a good or service is free, a bonus, a gift, a trial, without cost, or without

3.

that a purchase is “risk free,” or offered with a satisfaction guarantee, or with a
money-back guarantee;

13
14

4.

the total cost for any good or service;

15

5.

the timing or manner of any Charge or bill, including but not limited to the date of
the Charge and whether it will be a credit card or a checking account Charge;

16
17

6.

any material restrictions, limitations, or conditions to purchase, receive, or use
any good or service;

18
19

7.

that a transaction has been authorized by a consumer;

20

8.

any material aspect of the performance, efficacy, nature, or central characteristics

21
22
23

of a good or service; or
9.

any material aspect of the nature or terms of a refund, cancellation, exchange, or
repurchase policy for any good or service.

24
25

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1

IV.

2

PROHIBITED REPRESENTATIONS: OTHER HEALTH-RELATED CLAIMS

3

IT IS FURTHER ORDERED that Defendants, and Defendants’ officers, agents, and

4

employees, and all other Persons in active concert or participation with any of them, who receive

5

actual notice of this Order, whether acting directly or indirectly, in connection with the

6

manufacturing, labeling, packaging, advertising, marketing, promotion, offering for sale, sale, or

7

distribution of any Food, Drug, or Dietary Supplement, are permanently restrained and enjoined

8

from making, or assisting others in making, directly or by implication, any representation, other

9

than representations covered under Sections I and II of this Order, about the health benefits,

10

performance, or efficacy of such product, unless the representation is non-misleading, and, at the

11

time of making such representation, Defendants possess and rely upon competent and reliable

12

scientific evidence that is sufficient in quality and quantity based on standards generally accepted

13

by experts in the relevant disease, condition, or function to which the representation relates

14

(“qualified experts”), when considered in light of the entire body of relevant and reliable

15

scientific evidence, to substantiate that the representation is true.

16

For purposes of this Section of the Order, competent and reliable scientific evidence

17

means tests, analyses, research, or studies (1) that have been conducted and evaluated in an

18

objective manner by qualified experts; (2) that are generally accepted by qualified experts to

19

yield accurate and reliable results; and (3) that are randomized, double-blind, and placebo-

20

controlled human clinical testing of the Food, Dietary Supplement, or Drug, when qualified

21

experts would generally require such human clinical testing to substantiate that the representation

22

is true. In addition, when such tests or studies are human clinical tests or studies, all underlying

23

or supporting data and documents generally accepted by experts in the field as relevant to an

24

assessment of such testing as set forth in the Section of this Order entitled Preservation of

25

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1

Records Relating to Competent and Reliable Human Clinical Tests or Studies must be available

2

for inspection and production to the Commission.

3

V.

4
5

PRESERVATION OF RECORDS RELATING TO
COMPETENT AND RELIABLE HUMAN CLINICAL TESTS OR STUDIES

6

IT IS FURTHER ORDERED that, with regard to any human clinical test or study

7

(“test”) upon which Defendants rely to substantiate any claim covered by this Order, Defendants

8

shall secure and preserve all underlying or supporting data and documents generally accepted by

9

experts in the field as relevant to an assessment of the test, including:

10

A.

All protocols and protocol amendments, reports, articles, write-ups, or other accounts of

11

the results of the test, and drafts of such documents reviewed by the test sponsor or any other

12

Person not employed by the research entity;

13

B.

14

oral instructions, to participants; and participant compliance;

15

C.

16

not complete the test, and all communications with any participants relating to the test; all raw

17

data collected from participants enrolled in the test, including any participants who did not

18

complete the test; source documents for such data; any data dictionaries; and any case report

19

forms;

20

D.

21

any pretest analysis, intent-to-treat analysis, or between-group analysis performed on any test

22

data; and

23

E.

24

communications and contracts between any sponsor and the test’s researchers.

All documents referring or relating to recruitment; randomization; instructions, including

Documents sufficient to identify all test participants, including any participants who did

All documents referring or relating to any statistical analysis of any test data, including

All documents referring or relating to the sponsorship of the test, including all

25

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Provided, however, the preceding preservation requirement does not apply to a Reliably

1
2

Reported test, unless the test was conducted, controlled, or sponsored, in whole or in part by:

3

(1) any Defendant; (2) any Defendant’s officers, agents, representatives, or employees; (3) any

4

other Person or entity in active concert or participation with any Defendant; (4) any Person or

5

entity affiliated with or acting on behalf of any Defendant; (5) any supplier of any ingredient

6

contained in the product at issue to any of the foregoing or to the product’s manufacturer; or

7

(6) the supplier or manufacturer of such product.

8

For any test conducted, controlled, or sponsored, in whole or in part, by Defendants,

9

Defendants must establish and maintain reasonable procedures to protect the confidentiality,

10

security, and integrity of any personal information collected from or about participants. These

11

procedures must be documented in writing and must contain administrative, technical, and

12

physical safeguards appropriate to Corporate Defendants’ size and complexity, the nature and

13

scope of Defendants’ activities, and the sensitivity of the personal information collected from or

14

about the participants.

15

VI.

16

PROHIBITIONS AGAINST DECEPTIVE AND ABUSIVE
TELEMARKETING PRACTICES

17

IT IS FURTHER ORDERED that Defendants and Defendants’ officers, agents, and

18
19

employees, and all other Persons in active concert or participation with any of them, who receive

20

actual notice of this Order, whether acting directly or indirectly, in connection with

21

Telemarketing, are hereby permanently restrained and enjoined from engaging in, causing others

22

to engage in, or assisting other Persons to engage in, any of the following practices:

23

A.

24

that Person has previously stated that he or she does not wish to receive an Outbound Telephone

25

Call made by or on behalf of Defendants; or

initiating, or assisting others in initiating, any Outbound Telephone Call to a Person when

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1

B.

2

attached as Attachment A.

violating, or assisting others in violating, the TSR, 16 C.F.R. Part 310, a copy of which is

3

VII.

4

PROHIBITIONS RELATED TO MERCHANT ACCOUNTS

5

IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, and

6

employees, and all other Persons in active concert or participation with any of them, who receive

7

actual notice of this Order, whether acting directly or indirectly, in connection with a Merchant

8

Account, are permanently restrained and enjoined from Credit Card Factoring.

9

VIII.

10

MONETARY JUDGMENT AND PARTIAL SUSPENSION
IT IS FURTHER ORDERED that:

11
12

A.

13

in favor of the Commission and against the Individual Defendants and Corporate Defendants,

14

jointly and severally, as equitable monetary relief. Upon complete payment and transfer to the

15

Commission of all assets listed in Subsections VIII.B. and VIII.C. below, the remainder of the

16

judgment is suspended, subject to Subsection VIII.D-H, directly below.

17

B.

18

relinquish any dominion, and all legal and equitable right, title, control, or interest in the assets

19

listed below effective upon entry of this Order, and the following transfers of assets shall occur

20

within seven (7) days of entry of this Order:

21

Judgment in the amount of One Hundred Five Million Dollars ($105,000,000) is entered

In partial satisfaction of the monetary judgment set forth above, Defendants hereby

1.

Charles Schwab & Co., Inc. (“Charles Schwab”) shall liquidate all assets held in

22

the name of or for the benefit of any of the Individual Defendants, including but

23

not limited to the Charles Schwab accounts identified in Appendix 4 to this Order,

24

and then transfer to the Commission the net proceeds of the liquidated accounts;

25

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1

2.

Comerica Bank and/or Comerica Bank & Trust National Association

2

(“Comerica”) shall transfer to the Commission all assets held in the name of or for

3

the benefit of any of the Individual Defendants, including but not limited to the

4

Comerica accounts identified in Appendix 5 to this Order;

5

3.

John Hancock FREEDOM 529 and/or its distributor, John Hancock Distributors

6

LLC, which is an affiliate of John Hancock Funds LLC, the distributor of John

7

Hancock Investments (“John Hancock”) shall liquidate all assets held in the John

8

Hancock accounts for Danelle Miller 529 College Savings FBO [REDACTED]

9

and Danelle Miller 529 College Savings FBO [REDACTED], including but not

10

limited to John Hancock accounts ending in *2024 and *2028, and then transfer to

11

the Commission the net proceeds of the liquidated accounts;

12

4.

Pershing LLC (“Pershing”) shall liquidate all assets held in the name of or for the

13

benefit of any of the Individual Defendants, including but not limited to the

14

Pershing account ending in *3517 for SEP FBO Jason W. Miller, and then

15

transfer to the Commission the net proceeds of the liquidated accounts;

16

5.

Puerto Rico Sotheby’s International Realty (“Sotheby’s”) shall transfer to the

17

Commission all assets held in the name of or for the benefit of any of the

18

Defendants, including but not limited to the trust account ending in *8804;

19

6.

UBS Financial Services, Inc. (“UBS”) shall liquidate all assets held in the name

20

of or for the benefit of any of the Individual Defendants, including but not limited

21

to the UBS accounts identified in Appendix 13 to this Order, and then transfer to

22

the Commission the net proceeds of the liquidated accounts; and

23
24

7.

Defendants Jason Miller and Danelle Miller shall liquidate all Bitcoin assets held
in any www.coinbase.com accounts in the name of or for the benefit of any of the

25

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1

Individual Defendants, and then transfer to the Commission the net proceeds of

2

the liquidated accounts.

3

C.

4

legal and equitable right, title, control, or interest, in the following assets:

5

Effective upon entry of this Order, Defendants hereby relinquish any dominion, and all

1.

All funds held, controlled, or maintained by BankCard USA Merchant Services

6

(“BankCard USA”) since the inception of the Temporary Restraining Order [D.E.

7

12] associated with credit card or debit card Charges made on behalf of any

8

Corporate Defendants, including all funds in accounts held, controlled,

9

maintained, or opened by BankCard USA, including reserve funds, and including

10
11

the accounts identified in Appendix 1 to this Order;
2.

All funds held, controlled, or maintained by CashFlows since the inception of the

12

Temporary Restraining Order [D.E. 12] associated with credit card or debit card

13

Charges made on behalf of any Corporate Defendants, including all funds in

14

accounts held, controlled, maintained, or opened by CashFlows, including reserve

15

funds, and including the accounts identified in Appendix 2 to this Order;

16

3.

All funds held, controlled, or maintained by Chain Commerce Inc. (“Chain”)

17

since the inception of the Temporary Restraining Order [D.E. 12] associated with

18

credit card or debit card Charges made on behalf of any Corporate Defendants,

19

including all funds in accounts held, controlled, maintained, or opened by Chain,

20

including reserve funds, and including the accounts identified in Appendix 3 to

21

this Order;

22

4.

All funds in any accounts held by Comerica, in the name of or for the benefit of

23

any of the Corporate Defendants, including but not limited to the Comerica

24

accounts identified in Appendix 6 to this Order;

25

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1

5.

All funds held, controlled, or maintained by Cynergy Data LLC (“Cynergy”)

2

since the inception of the Temporary Restraining Order [D.E. 12] associated with

3

credit card or debit card Charges made on behalf of any Corporate Defendants,

4

including all funds in accounts held, controlled, maintained, or opened by

5

Cynergy, including reserve funds, and including but not limited to the accounts

6

identified in Appendix 7 to this Order;

7

6.

All funds held, controlled, or maintained by Electronic Merchant Systems, Inc.

8

(“EMS”) since the inception of the Temporary Restraining Order [D.E. 12]

9

associated with credit card or debit card Charges made on behalf of any Corporate

10

Defendants, including all funds in accounts held, controlled, maintained, or

11

opened by EMS, including reserve funds, and including but not limited to the

12

accounts identified in Appendix 8 to this Order;

13

7.

All funds held, controlled, or maintained by EVO Payments International LLC

14

(“EVO”) since the inception of the Temporary Restraining Order [D.E. 12]

15

associated with credit card or debit card Charges made on behalf of any Corporate

16

Defendants, including all funds in accounts held, controlled, maintained, or

17

opened by EVO, including reserve funds, and including but not limited to the

18

accounts identified in Appendix 9 to this Order;

19

8.

All funds held, controlled, or maintained by Humboldt Merchant Services

20

(“Humboldt”) since the inception of the Temporary Restraining Order [D.E. 12]

21

associated with credit card or debit card Charges made on behalf of any Corporate

22

Defendants, including all funds in accounts held, controlled, maintained, or

23

opened by Humboldt, including reserve funds, and including but not limited to the

24

accounts identified in Appendix 10 to this Order;

25

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1

9.

All funds held, controlled, or maintained by Merrick Bank (“Merrick Bank”)

2

since the inception of the Temporary Restraining Order [D.E. 12] associated with

3

credit card or debit card Charges made on behalf of any Corporate Defendants,

4

including all funds in accounts held, controlled, maintained, or opened by Merrick

5

Bank, including reserve funds, and including but not limited to the account ending

6

in *7526 for Defendant Wellness Product LLC, the account ending in *4153 for

7

Lifevtamins, the account ending in *4154 for Menshealth, the account ending in

8

*4155 for Spnutri, and the account ending in *4156 for Purevit;

9

10.

All funds held, controlled, or maintained by Meritus Payment Solutions, now

10

known as Paysafe Group, a subsidiary of Optimal Payments (“Meritus”), since the

11

inception of the Temporary Restraining Order [D.E. 12] associated with credit

12

card or debit card Charges made on behalf of any Corporate Defendants,

13

including all funds in accounts held, controlled, maintained, or opened by

14

Meritus, including reserve funds, and including but not limited to the accounts

15

identified in Appendix 11 to this Order;

16

11.

All funds held, controlled, or maintained by National Merchant Center (“NMC”)

17

since the inception of the Temporary Restraining Order [D.E. 12] associated with

18

credit card or debit card Charges made on behalf of any Corporate Defendants,

19

including all funds in accounts held, controlled, maintained, or opened by NMC,

20

including reserve funds, and including but not limited to the account ending in

21

*0001 for Defendant CSA Ventures LLC;

22

12.

All funds held, controlled, or maintained by Orion Payment Systems (“Orion”)

23

since the inception of the Temporary Restraining Order [D.E. 12] associated with

24

credit card or debit card Charges made on behalf of any Corporate Defendants,

25

including all funds in accounts held, controlled, maintained, or opened by Orion,

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1

including reserve funds, and including but not limited to the accounts identified in

2

Appendix 12 to this Order;
13.

3

All funds held, controlled, or maintained by Pace Payment Systems, Inc. (“Pace”)

4

since the inception of the Temporary Restraining Order [D.E. 12] associated with

5

credit card or debit card Charges made on behalf of any Corporate Defendants,

6

including all funds in accounts held, controlled, maintained, or opened by Pace,

7

including reserve funds, and including but not limited to the account ending in

8

*7881 for Defendant Diet Concepts LLC;
14.

9

All funds held, controlled, or maintained by Payment World (“Payment World”)

10

since the inception of the Temporary Restraining Order [D.E. 12] associated with

11

credit card or debit card Charges made on behalf of any Corporate Defendants,

12

including all funds in accounts held, controlled, maintained, or opened by

13

Payment World, including reserve funds, and including but not limited to the

14

accounts ending in *8001, *9001, and *0001 for Defendant BSC Marketing LLC,

15

and the accounts ending in *6001, *95001, and *85001 for Defendant Pure

16

Vitamin LLC;
15.

17

All funds held, controlled, or maintained by Select Bankcard since the inception

18

of the Temporary Restraining Order [D.E. 12] associated with credit card or debit

19

card Charges made on behalf of any Corporate Defendants, including all funds in

20

accounts held, controlled, maintained, or opened by Select Bankcard, including

21

reserve funds, and including but not limited to the account ending in *0164 for

22

Defendant Diet Concepts LLC;

23

D.

24

that all funds and accounts described in Subsection VIII.C. constitute a part of the Receivership

Notwithstanding the foregoing Subsection VIII.C., it is expressly agreed and understood

25

22 of 45

1

Estate, and the Receiver is expressly authorized and directed to take exclusive custody, control

2

and possession of all such funds and accounts pursuant to Section XII of this Order.

3

E.

4

written notice of this Order all documents necessary to effectuate the liquidation, where

5

appropriate, and the transfer of the assets identified in Subsections VIII.B. and VIII.C. above.

6

F.

7

premised upon the truthfulness, accuracy, and completeness of Defendants’ sworn financial

8

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

9

Commission, namely:

10

Individual Defendants shall execute, or cause to be executed, within three (3) days of

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

1.

the Financial Statement of Individual Defendant Jason Miller signed on October

11

21, 2014 and submitted on October 23, 2014, including the attachments submitted

12

on October 21, 2014, October 22, 2014, and October 23, 2014;

13

2.

14
15

the Financial Statement of Individual Defendant Jason Miller signed on July 9,
2015, including the attachments;

3.

16

the Financial Statement of Individual Defendant Jason Miller signed on October
8, 2015, including the attachments;

17

4.

the Declaration of Individual Defendant Jason Miller signed on October 16, 2015;

18

5.

the Financial Statement of Individual Defendant Danelle Miller signed on October

19

21, 2014 and submitted on October 23, 2014, including the attachments submitted

20

on October 21, 2014, October 22, 2014, and October 23, 2014;

21

6.

22
23
24

the Financial Statement of Individual Defendant Danelle Miller signed on July 9,
2015, including the attachments;

7.

the Financial Statement of Individual Defendant Danelle Miller signed on October
8, 2015, including the attachments;

25

23 of 45

1

8.

2015;

2
3

the Declaration of Individual Defendant Danelle Miller signed on October 16,

9.

the Financial Statement of Corporate Defendant 458 Media LLC, signed and

4

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

5

April 22, 2015, including the attachments;

6

10.

the Financial Statement of Corporate Defendant Alpha Brands, LLC, signed and

7

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

8

April 22, 2015, including the attachments;

9

11.

the Financial Statement of Corporate Defendant Barrel Roll, LLC, signed and

10

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

11

February 12, 2016, including the attachments;

12

12.

the Financial Statement of Corporate Defendant Blu Stella, LLC, signed and

13

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

14

April 22, 2015, including the attachments;

15

13.

the Financial Statement of Corporate Defendant Brilliant Skin LLC, signed and

16

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

17

April 22, 2015, including the attachments;

18

14.

the Financial Statement of Corporate Defendant BSC Marketing, LLC, signed and

19

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

20

July 9, 2015, including the attachments;

21

15.

the Financial Statement of Corporate Defendant Cherry Hill Marketing, LLC,

22

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

23

submitted on April 22, 2015, including the attachments;

24
25

24 of 45

1

16.

the Financial Statement of Corporate Defendant CSA Ventures, LLC, signed and

2

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

3

April 22, 2015, including the attachments;

4

17.

the Financial Statement of Corporate Defendant Diet Concepts, LLC, signed and

5

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

6

July 9, 2015, including the attachments;

7

18.

the Financial Statement of Corporate Defendant Discount Provisions L.L.C.,

8

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

9

submitted on April 22, 2015, including the attachments;

10

19.

the Financial Statement of Corporate Defendant DJD Distribution, LLC, signed

11

by Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

12

October 21, 2014 and submitted on October 30, 2014, including the attachments;

13

20.

the Financial Statement of Corporate Defendant Extamax, LLC, signed and

14

initialed by Jason Miller, Managing Member, on June 22, 2015 and submitted on

15

February 12, 2016, including the attachments;

16

21.

the Financial Statement of Corporate Defendant F12 Media LLC, signed and

17

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

18

April 22, 2015, including the attachments;

19

22.

the Financial Statement of Corporate Defendant Flex Formulas, LLC, signed and

20

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

21

April 22, 2015, including the attachments;

22

23.

the Financial Statement of Corporate Defendant GCB Marketing LLC, signed and

23

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

24

April 22, 2015, including the attachments;

25

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1

24.

the Financial Statement of Corporate Defendant Health Formulas, LLC, signed by

2

Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

3

October 21, 2014 and submitted on October 30, 2014, including the attachments;

4

25.

the Financial Statement of Corporate Defendant Health Products Direct LLC,

5

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

6

submitted on July 9, 2015, including the attachments;

7

26.

the Financial Statement of Corporate Defendant KMS Marketing LLC, signed and

8

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

9

April 22, 2015, including the attachments;

10

27.

the Financial Statement of Corporate Defendant Longhorn Marketing, LLC,

11

signed by Jason Miller, Manager, and initialed by Jason Miller and Danelle

12

Miller, on October 21, 2014 and submitted on October 30, 2014, including the

13

attachments;

14

28.

the Financial Statement of Corporate Defendant Luminous Skin LLC, signed and

15

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

16

April 22, 2015, including the attachments;

17

29.

the Financial Statement of Corporate Defendant MDCC, LLC, signed by Jason

18

Miller, Manager, and initialed by Jason Miller and Danelle Miller, on October 21,

19

2014 and submitted on October 30, 2014, including the attachments;

20

30.

the Financial Statement of Corporate Defendant Men’s Health Formulas, LLC,

21

signed and initialed by Jason Miller, Managing Member, on June 22, 2015 and

22

submitted June 22, 2015, including the attachments;

23

31.

the Financial Statement of Corporate Defendant Metabolic Labs, LLC, signed and

24

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

25

April 22, 2015, including the attachments;

26 of 45

1

32.

the Financial Statement of Corporate Defendant Method Direct, LLC, signed by

2

Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

3

October 21, 2014 and submitted on October 30, 2014, including the attachments;

4

33.

the Financial Statement of Corporate Defendant Method Films, Inc., signed and

5

initialed by Jason Miller, Secretary, on April 15, 2015 and submitted on April 22,

6

2015, including the attachments;

7

34.

the Financial Statement of Corporate Defendant Miracle Male, LLC, signed and

8

initialed by Jason Miller, Managing Member, on April 4, 2015 submitted on April

9

22, 2015, including the attachments;

10

35.

the Financial Statement of Corporate Defendant Moringa Marketing LLC, signed

11

and initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted

12

on April 22, 2015, including the attachments;

13

36.

the Financial Statement of Corporate Defendant Natural Products Direct LLC,

14

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

15

submitted on April 22, 2015, including the attachments;

16

37.

the Financial Statement of Corporate Defendant Northbound Marketing LLC,

17

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

18

submitted on April 22, 2015, including the attachments;

19

38.

the Financial Statement of Corporate Defendant Northern Health Products LLC,

20

signed and initialed by Jason Miller, Managing Member, on April 4, 2015 and

21

submitted on April 22, 2015, including the attachments;

22

39.

the Financial Statement of Corporate Defendant Pure and Natural Health Products

23

LLC, signed and initialed by Jason Miller, Managing Member, on April 4, 2015

24

and submitted on April 22, 2015, including the attachments;

25

27 of 45

1

40.

the Financial Statement of Corporate Defendant Pure and Simple Health Products

2

LLC, signed and initialed by Jason Miller, Managing Member, on April 4, 2015

3

and submitted on April 22, 2015, including the attachments;

4

41.

the Financial Statement of Corporate Defendant Pure Vitamins, LLC, signed by

5

Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

6

October 21, 2014 and submitted on October 30, 2014, including the attachments;

7

42.

the Financial Statement of Corporate Defendant Radiant Skin LLC, signed and

8

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

9

April 22, 2015, including the attachments;

10

43.

the Financial Statement of Corporate Defendant Shimmering Skin LLC, signed

11

and initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted

12

on July 9, 2015, including the attachments;

13

44.

the Financial Statement of Corporate Defendant Skinny 7 LLC, signed and

14

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

15

April 22, 2015, including the attachments;

16

45.

the Financial Statement of Corporate Defendant Tindy Films LLC, signed and

17

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

18

April 22, 2015, including the attachments;

19

46.

the Financial Statement of Corporate Defendant VIP Savings, LLC, signed by

20

Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

21

October 21, 2014 and submitted on October 30, 2014, including the attachments;

22

47.

the Financial Statement of Corporate Defendant Weight Loss Dojo, LLC, signed

23

by Jason Miller, Manager, and initialed by Jason Miller and Danelle Miller, on

24

October 21, 2014 and submitted on October 30, 2014, including the attachments;

25

28 of 45

1

48.

the Financial Statement of Corporate Defendant Wellness Labs, LLC, signed and

2

initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted on

3

April 22, 2015, including the attachments;

4

49.

the Financial Statement of Corporate Defendant Wellness Products, LLC, signed

5

and initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted

6

on April 22, 2015, including the attachments;

7

50.

the Financial Statement of Corporate Defendant Yacon Marketing LLC, signed

8

and initialed by Jason Miller, Managing Member, on April 4, 2015 and submitted

9

on April 22, 2015, including the attachments;

10

51.

the additional documentation submitted by letter from Defendants’ counsel

11

Steven Eichorn to Commission counsel dated November 3, 2014, in support of

12

Defendants’ financial disclosures;

13

52.

the additional documentation submitted by email from Defendants’ counsel Sarah

14

Koch to Commission counsel dated May 1, 2015, concerning the sale of a car

15

owned by the Individual Defendants;

16

53.

the additional documentation submitted by email from Defendants’ counsel

17

Rachel Hirsch to Commission counsel dated May 4, 2015, concerning the sale of

18

a car owned by the Individual Defendants;

19

54.

the additional documentation submitted by email from Defendants’ counsel

20

Rachel Hirsch to Commission counsel dated June 22, 2015, concerning the

21

Individual Defendants’ personal assets and liabilities;

22

55.

the additional documentation submitted by email from Defendants’ counsel

23

William Rothbard to Commission counsel dated September 2, 2015, concerning

24

the Corporate Defendants’ assets and the Individual Defendants’ liabilities;

25

29 of 45

56.

1

the additional documentation submitted by email from Defendants’ counsel

2

William Rothbard to Commission counsel dated December 4, 2015, concerning

3

the Individual Defendants’ house and IRAs;
57.

4

the additional documentation submitted by email from Defendants’ counsel

5

William Rothbard to Commission counsel dated December 7, 2015, concerning

6

the Individual Defendants’ house;
58.

7

the additional documentation submitted by email from Defendants’ counsel

8

William Rothbard to Commission counsel dated December 17, 2015, concerning

9

the Individual Defendants’ house and IRAs;
59.

10

the additional documentation submitted by email from Defendants’ counsel

11

William Rothbard to Commission counsel dated December 21, 2015, concerning

12

the Individual Defendants’ tax liability; and
60.

13

the additional documentation submitted by email from Defendants’ counsel

14

William Rothbard to Commission counsel dated December 28, 2015, concerning

15

the Individual Defendants’ tax liability.

16

G.

17

Commission, the Court finds that Defendant failed to disclose any material asset, materially

18

misstated the value of any asset, or made any other material misstatement or omission in the

19

financial representations identified above.

20

H.

21

that Defendant in the amount specified in Subsection VIII.A. above (which the parties stipulate

22

only for purposes of this Section represents the consumer injury alleged in the Complaint), less

23

any payment previously made pursuant to this Section, plus interest computed from the date of

24

entry of this Order.

The suspension of the judgment will be lifted as to any Defendant if, upon motion by the

If the suspension of the judgment is lifted, the judgment becomes immediately due as to

25

30 of 45

1

IX.

2

ADDITIONAL MONETARY PROVISIONS
IT IS FURTHER ORDERED that:

3
4

A.

Defendants relinquish dominion and all legal and equitable right, title, and interest in all

5

assets transferred pursuant to this Order, including but not limited to the assets identified in

6

Subsections VIII.B. and VIII.C. above, and may not seek the return of any assets.

7

B.

8

intellectual property owned by the Corporate Defendants;

9

C.

Defendants relinquish dominion and all legal and equitable right, title, and interest in all

Defendants relinquish dominion and all legal and equitable right, title, and interest in all

10

successors, assigns, affiliates, and subsidiaries of the Corporate Defendants, including all entities

11

(domestic or foreign) holding payment processing accounts used by Defendants and their

12

successors, assigns, affiliates, and subsidiaries, and their assets, and may not seek the return of

13

any interest in those corporate entities or their assets. Further, Defendants will not raise any

14

objection to the transfer of any assets held by said entities, including any funds held in payment

15

processing reserve accounts.

16

D.

17

in the name of or for the benefit of any of the Corporate Defendants and all of the funds, assets,

18

and intellectual property identified and set forth in Subsections VIII.C., IX.B., and IX.C,

19

constitute a part of the Receivership Estate, and the Receiver is expressly authorized and directed

20

to take exclusive custody, control and possession of all such funds, assets, and intellectual

21

property pursuant to Section XII of this Order.

22

E.

23

subsequent civil litigation by or on behalf of the Commission to enforce its rights to any payment

24

or monetary judgment pursuant to this Order, such as a nondischargeability complaint in any

25

bankruptcy case.

Notwithstanding the foregoing, it is expressly agreed and understood that all assets held

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

31 of 45

1

F.

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

2

the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C.

3

§ 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes.

4

G.

5

Numbers or Employer Identification Numbers), which Defendants previously submitted to the

6

Commission, may be used for collecting and reporting on any delinquent amount arising out of

7

this Order, in accordance with 31 U.S.C. § 7701.

8

H.

9

administered by the Commission or its designee to be used for equitable relief, including

Defendants acknowledge that their Taxpayer Identification Numbers (Social Security

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

10

consumer redress and any attendant expenses for the administration of any redress fund. If a

11

representative of the Commission decides that direct redress to consumers is wholly or partially

12

impracticable or money remains after redress is completed, the Commission may apply any

13

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

14

determines to be reasonably related to Defendants’ practices alleged in the Complaint. Any

15

money not used for such equitable relief is to be deposited to the U.S. Treasury as disgorgement.

16

Defendants have no right to challenge any actions the Commission or its representatives may

17

take pursuant to this Subsection.

18

I.

19

Order as to Defendants [D.E.149], entered by this court on May 6, 2015, is modified to permit

20

the payments and transfers identified in the Monetary Judgment Section (Section VIII) of this

21

Order. Upon completion of those payments and transfers, the asset freeze is dissolved as to the

22

Individual Defendants.

The existing asset freeze of Defendants’ assets set forth in the Preliminary Judgment

23
24
25

32 of 45

1

X.

2

CUSTOMER INFORMATION
IT IS FURTHER ORDERED that Defendants, Defendants’ officers, agents, employees,

3
4

and attorneys, and all other Persons in active concert or participation with any of them, who

5

receive actual notice of this Order, are permanently restrained and enjoined from directly or

6

indirectly:

7

A.

8

administer consumer redress. Defendants represent that they have provided this redress

9

information to the Commission. If a representative of the Commission requests in writing any

failing to provide sufficient customer information to enable the Commission to efficiently

10

information related to redress, Defendants must provide it, in the form prescribed by the

11

Commission, within 14 days.

12

B.

13

telephone number, email address, social security number, other identifying information, or any

14

data that enables access to a customer’s account (including a credit card, bank account, or other

15

financial account), that any Defendant obtained prior to entry of this Order in connection with

16

the sale of Dietary Supplements, skin creams, or Upsell products; and

17

C.

18

control within 30 days after receipt of written direction to do so from a representative of the

19

Commission.

20

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

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

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

21

disclosed, to the extent requested by a government agency or required by law, regulation, or

22

court order.

23
24
25

33 of 45

1

XI.

2

COOPERATION

3

IT IS FURTHER ORDERED that the Corporate Defendants and Individual Defendants

4

must fully cooperate with representatives of the Commission in this case and in any investigation

5

related to or associated with the transactions or the occurrences that are the subject of the

6

Complaint. Such Defendants must provide truthful and complete information, evidence, and

7

testimony. Such Individual Defendants must appear and such Corporate Defendants must cause

8

Defendants’ officers, employees, representatives, or agents to appear for interviews, discovery,

9

hearings, trials, and any other proceedings that a Commission representative may reasonably

10

request upon 10 days written notice, or other reasonable notice, at such places and times as a

11

Commission representative may designate, without the service of a subpoena. Such Defendants

12

also must fully cooperate with representatives of the Receiver in this case.

13

XII.

14

RECEIVERSHIP

15

IT IS FURTHER ORDERED that Robb Evans & Associates LLC is hereby appointed

16

permanent Receiver for the Receivership Defendants for the purpose of taking the necessary

17

steps to wind down the businesses of the Receivership Defendants, liquidate assets, and pay any

18

net proceeds to the Commission to satisfy the monetary judgment in this Order. In carrying out

19

these duties, the Receiver shall be the agent of this Court, shall be accountable directly to this

20

Court, and is authorized and directed to:

21

A.

22

affairs of the Receivership Defendants.

23

B.

24

collect, marshal, and take custody, control, and possession of all the funds, property, premises,

25

accounts, documents, mail, and other assets of, or in the possession or under the control of the

Take any and all steps that the Receiver concludes are appropriate to wind down the

Continue to exercise full control over the Receivership Defendants and continue to

34 of 45

1

Receivership Defendants, wherever situated, the income and profits therefrom, and all sums of

2

money now or hereafter due or owing to the Receivership Defendants.

3

C.

4

Defendants.

5

D.

6

all other assets of the Receivership Defendants, cancel the Receivership Defendants’ contracts,

7

collect on amounts owed to the Receivership Defendants, and take such other steps as may be

8

necessary to wind-down the Receivership Defendants efficiently.

9

E.

Continue to have full control over the management and personnel of the Receivership

Take all steps necessary or advisable, including issuing subpoenas, to locate and liquidate

To the extent not already completed, the Receiver shall as soon as practicable after the

10

entry of this Order, take exclusive custody, control, and possession of all funds identified in

11

Subsection VIII.C.

12

F.

13

compromises by the Receiver concerning the Receivership Estate, before the settlement or

14

compromise is consummated. Within 20 days of this notice, the Commission shall have the

15

opportunity to object to any such settlement, by filing a motion with the Court.

16

G.

17

advisable for carrying out the directions of, or exercising the authority granted by, this Order.

18

The Receiver shall apply to the Court for prior approval of any payment of any debt or obligation

19

incurred by the Receivership Defendants prior to the date of entry of the temporary restraining

20

order in this action, except payments that the Receiver deems necessary or advisable to ensure

21

assets of the Receivership Defendants are not lost, stolen, or dissipated.

22

H.

23

necessary and advisable to preserve or recover the assets of the Receivership Defendants, or that

24

the Receiver deems necessary and advisable to carry out the Receiver’s mandate under this

25

Order, including actions challenging fraudulent or voidable transfers.

The Receiver shall give reasonable notice to the Commission of any settlements or

Make payments and disbursements from the Receivership Estate that are necessary or

Institute actions or proceedings in state, federal, or foreign courts as the Receiver deems

35 of 45

1

I.

Defend any or all actions or proceedings instituted against the Receivership Defendants,

2

as the Receiver deems necessary and advisable to preserve the assets of the Receivership

3

Defendants.

4

J.

5

Receiver.

6

K.

7

the Receivership Estate, and prevent unauthorized transfer, withdrawal, or misapplication of said

8

assets.

9

L.

Continue to maintain accurate records of all receipts and expenditures incurred as the

Perform all acts necessary or advisable to complete an accurate accounting of assets of

Continue to be entitled to reasonable compensation for the performance of the Receiver’s

10

duties pursuant to this Order, including duties performed by the Receiver’s agents, including

11

accountants and lawyers, and for the cost of actual out-of-pocket expenses incurred by them,

12

from the assets of the Receivership Defendants, at the hourly rate previously agreed to by the

13

Receiver and used as the bases for prior fee applications approved by the Court.

14

XIII.

15

RECEIVER’S FINAL REPORT AND DISBURSEMENT

16

IT IS FURTHER ORDERED that:

17

A.

18

serve on the parties a report (the “Final Report”) to the Court that details the steps taken to

19

dissolve the Receivership Estate. The Final Report must include an accounting of the

20

Receivership Estate’s finances and total assets and a description of what other actions, if any,

21

must be taken to wind down the Receivership.

22

B.

23

Receivership Defendants with a notice stating that any objections to paying any assets of the

24

Receivership Defendants to satisfy the Receiver’s costs and expenses and the monetary judgment

No later than 120 days from the date of the entry of this Order, the Receiver shall file and

The Receiver shall mail copies of the Final Report to all known creditors of the

25

36 of 45

1

set forth in this Order must be submitted to the Court and served by mail upon the Receiver and

2

the parties within thirty (30) days of the mailing of the Final Report.

3

C.

4

an application for payment of compensation and expenses associated with his performance of his

5

duties as Receiver.

6

D.

7

valid objection, will issue an order directing that the Receiver:

8

No later than fifteen (15) days after submission of the Final Report, the Receiver shall file

The Court will review the Final Report and any objections to the report and, absent a

1.

9

Pay the reasonable costs and expenses of administering the Receivership,
including compensation of the Receiver and the Receiver’s personnel authorized

10

by Section XII of this Order or other orders of this Court and the actual

11

out-of-pocket costs incurred by the Receiver in carrying out his duties;

12

2.

13

Pay all remaining funds to the Commission or its designated agent to reduce the
monetary judgment in Section VIII.

14

E.

15

reserve to cover additional fees and costs related to actions to be addressed in a supplemental

16

application. If the Receiver does not make a supplemental application for fees and expenses

17

within the specified period, or if funds remain in the reserve funds after the payment of fees and

18

expenses approved by the Court in response to such a supplemental application, all funds in the

19

reserve funds shall be immediately paid to the Commission or its designated agent.

20

F.

21

Defendants shall be assigned to the Commission for further collection efforts.

With Court approval, the Receiver may hold back funds for a specified period as a

Any and all uncollected judgments obtained for the benefit of the Receivership

22

XIV.

23

ORDER ACKNOWLEDGMENTS

24
25

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of
this Order:

37 of 45

1

A.

Each Defendant, within 7 days of entry of this Order, must submit to the Commission an

2

acknowledgment of receipt of this Order sworn under penalty of perjury.

3

B.

4

Defendant, individually or collectively with any other Defendants, is the majority owner or

5

controls directly or indirectly, and each Corporate Defendant must deliver a copy of this Order

6

to: (1) all principals, officers, directors, and LLC managers and members; (2) all employees,

7

agents, and representatives who participate in conduct related to the subject matter of the Order;

8

and (3) any business entity resulting from any change in structure as set forth in the Section titled

9

Compliance Reporting (Section XV). Delivery must occur within 7 days of entry of this Order

For 5 years after entry of this Order, each Individual Defendant for any business that such

10

for current personnel. For all others, delivery must occur before they assume their

11

responsibilities.

12

C.

13

Defendant must obtain, within 30 days, a signed and dated acknowledgment of receipt of this

14

Order.

From each individual or entity to which a Defendant delivered a copy of this Order, that

15

XV.

16

COMPLIANCE REPORTING
IT IS FURTHER ORDERED that Defendants make timely submissions to the

17
18

Commission:

19

A.

20

Defendant must submit a compliance report, sworn under penalty of perjury:

21

One year after entry of this Order, each Individual Defendant and each Corporate

1.

Each Defendant must: (a) identify the primary physical, postal, and email address

22

and telephone number, as designated points of contact, which representatives of

23

the Commission may use to communicate with Defendant; (b) identify all of that

24

Defendant’s businesses by all of their names, telephone numbers, and physical,

25

postal, email, and Internet addresses; (c) describe the activities of each business,

38 of 45

1

including the goods and services offered, the means of advertising, marketing, and

2

sales, and the involvement of any other Defendant (which Individual Defendants

3

must describe if they know or should know due to their own involvement);

4

(d) describe in detail whether and how that Defendant is in compliance with each

5

Section of this Order; and (e) provide a copy of each Order Acknowledgment

6

obtained pursuant to this Order, unless previously submitted to the Commission.
2.

7

Additionally, each Individual Defendant must: (a) identify all telephone numbers

8

and all physical, postal, email and Internet addresses, including all residences;

9

(b) identify all business activities, including any business for which such

10

Defendant performs services whether as an employee or otherwise and any entity

11

in which such Defendant has any ownership interest; and (c) describe in detail

12

such Defendant’s involvement in each such business, including title, role,

13

responsibilities, participation, authority, control, and any ownership.

14

B.

15

Defendant must submit a compliance notice, sworn under penalty of perjury, within 14 days of

16

any change in the following:

17

For 10 years after entry of this Order, each Individual Defendant and each Corporate

1.

Each Defendant must report any change in: (a) any designated point of contact;

18

or (b) the structure of any Corporate Defendant or any entity that Defendant has

19

any ownership interest in or controls directly or indirectly that may affect

20

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

21

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

22

any acts or practices subject to this Order.

23

2.

Additionally, each Individual Defendant must report any change in: (a) name,

24

including aliases or fictitious names, or residence address; or (b) title or role in

25

any business activity, including any business for which such Defendant performs

39 of 45

1

services whether as an employee or otherwise and any entity in which such

2

Defendant has any ownership interest, and identify the name, physical address,

3

and any Internet address of the business or entity.

4

C.

5

petition, insolvency proceeding, or similar proceeding by or against such Defendant within 14

6

days of its filing.

7

D.

8

perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by concluding:

9

“I declare under penalty of perjury under the laws of the United States of America that the

Each Defendant must submit to the Commission notice of the filing of any bankruptcy

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

10

foregoing is true and correct. Executed on: _____” and supplying the date, signatory’s full

11

name, title (if applicable), and signature.

12

E.

13

the Commission pursuant to this Order must be emailed to [e-mail] or sent by overnight

14

courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of

15

Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington,

16

DC 20580. The subject line must begin: FTC v. Jason Miller, X150015.

Unless otherwise directed by a Commission representative in writing, all submissions to

17

XVI.

18

RECORDKEEPING

19

IT IS FURTHER ORDERED that Defendants must create certain records for 10 years

20

after entry of the Order, and retain each such record for 5 years. Specifically, Corporate

21

Defendants and each Individual Defendant for any business that such Defendant, individually or

22

collectively with any other Defendants, is a majority owner or controls directly or indirectly,

23

must create and retain the following records:

24

A.

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

25

40 of 45

1

B.

Personnel records showing, for each Person providing services, whether as an employee

2

or otherwise, that Person’s: name; addresses; telephone numbers; job title or position; dates of

3

service; and (if applicable) the reason for termination;

4

C.

5

the Order, whether received directly or indirectly, such as through a third party, and any

6

response;

7

D.

8

including all submissions to the Commission; and

9

E.

Records of all consumer complaints and refund requests concerning the subject matter of

All records necessary to demonstrate full compliance with each provision of this Order,

A copy of each unique advertisement or other marketing material, and each contract with

10

suppliers, payment processors, advertisers or advertising agencies, affiliate marketing brokers,

11

and consumer list brokers.

12

XVII.

13

COMPLIANCE MONITORING
IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’

14
15

compliance with this Order, including the financial representations upon which part of the

16

judgment was suspended and any failure to transfer any assets as required by this Order:

17

A.

18

each Defendant must: submit additional compliance reports or other requested information,

19

which must be sworn under penalty of perjury; appear for depositions; and produce documents

20

for inspection and copying. The Commission is also authorized to obtain discovery, without

21

further leave of court, using any of the procedures prescribed by Federal Rules of Civil

22

Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 36, 45, and 69.

23

B.

24

with each Defendant. Defendants must permit representatives of the Commission to interview

Within 14 days of receipt of a written request from a representative of the Commission,

For matters concerning this Order, the Commission is authorized to communicate directly

25

41 of 45

1

any employee or other Person affiliated with any Defendant who has agreed to such an interview.

2

The Person interviewed may have counsel present.

3

C.

4

representatives as consumers, suppliers, or other individuals or entities, to Defendants or any

5

individual or entity affiliated with Defendants, without the necessity of identification or prior

6

notice. Nothing in this Order limits the Commission’s lawful use of compulsory process,

7

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

8

D.

9

agency must furnish consumer reports concerning Individual Defendants, pursuant to Section

10

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

Upon written request from a representative of the Commission, any consumer reporting

604(1) of the Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(1).

11

XVIII.

12

RETENTION OF JURISDICTION

13

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for

14

purposes of construction, modification, and enforcement of this Order.

15
16
17

The Court has reviewed the stipulated preliminary injunction and finds no evidence that it is
unfair, inadequate, or unreasonable. Therefore, IT IS ORDERED that [201] Stipulation for
Permanent Injunction is GRANTED.

18

Dated: February 22, 2017
19
20

______________________________________________
THE HONORABLE RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE

21
22
23
24
25

42 of 45

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

Attachment A

APPENDIX 1 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
BankCard USA Merchant Services Accounts
Financial Institution
or Merchant
Processor
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services

Account Name

DBA

Account Number

458 Media LLC

P N OXIDE

*2902

458 Media LLC

P NITRIC

*2894

BARREL ROLL
FILMS LLC
BARREL ROLL
FILMS LLC
BRILLIANT SKIN
LLC
BSC MARKETING
INC
BSC MARKETING
INC
BSC MARKETING
INC
BSC MARKETING
LLC
CAS VENTURES
LLC
CSA VENTURES
LLC
DIET CONCEPTS
LLC
GCB MARKETING
LLC
GCB MARKETING
LLC
GCB MARKETING
LLC
GCB MARKETING
LLC
HEALTH
FORMULAS LLC
HEALTH
PRODUCTS
DIRECT LLC

DVD
ENTERTAINMENT
LIFE VITAMINS

*5112

SKNCARE 8004710112

*8439

PURE GCB 800 413 9366

*6581

PURE GC 800 424 9142

*6599

PURE RK 800 396 5158

*6573

MAX VITAMINS 800499-9515
EXERCISE DVDS

*4982

EXERCISE DVDS

*4990

SKINNY8005938029

*4483

GCBDIET 8889122761

*8496

GARCINIA 8889241351

*8694

GAR 8888518616

*8892

MENST 8889192045

*9015

SP VITAMINS
8004249142
GREEN 8889122765

*5096

*5120

*2616

*8488

APPENDIX 1

Financial Institution
or Merchant
Processor
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services

Account Name

DBA

Account Number

HEALTH
PRODUCTS
DIRECT LLC
HEALTH
PRODUCTS
DIRECT LLC
HEALTH
PRODUCTS
DIRECT LLC
KMS
MARKETING LLC
KMS
MARKETING LLC
KMS
MARKETING LLC
KMS
MARKETING LLC
LONGHORN
MARKETING LLC
LUMINOUS SKIN
LLC
MENS HEALTH
FORMULAS LLC
METHOD DIRECT
LLC
MORINGA
MARKETING LLC
MORINGA
MARKETING LLC
MORINGA
MARKETING LLC
MORINGA
MARKETING LLC
NATURAL
PRODUCTS
DIRECT LLC
NATURAL
PRODUCTS
DIRECT LLC
NATURAL
PRODUCTS

SUPANT8889241372

*9106

T10 8889192044

*9098

WGTLOSS 8888518620

*9114

SIMPLE PURE
NUTRITION
DIRECT DVD

*2541

FORMULA T10 800 497
0709
BLACK BULL 800 496
6099
LIFE VITAMINS

*6516

SKNREPAIR
8004711126
MENS VITAMINS

*8421

DIRECT DVD

*5054

PURE 8888518617

*5035

LIFE VITA 8889241352

*9023

PUREGM 8889122762

*8504

FT10 8889192046

*8967

GCBC 8889122764

*8512

SUPERIOR 8889241354

*9064

FORMULA 8889192048

*9122

*4776

*6524
*4768

*5005

APPENDIX 1

Financial Institution
or Merchant
Processor
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services

Account Name

DIRECT LLC
NATURAL
PRODUCTS
DIRECT LLC
NORTHBOUND
MARKETING LLC
NORTHBOUND
MARKETING LLC
NORTHBOUND
MARKETING LLC
NORTHBOUND
MARKETING LLC
NORTHERN
HEALTH
PRODUCTS LLC
NORTHERN
HEALTH
PRODUCTS LLC
PURE AND
NATURAL
HEALTH PROD
PURE AND
NATURAL
HEALTH PROD
PURE AND
NATURAL
HEALTH PROD
PURE AND
NATURAL
HEALTH PROD
PURE AND
NATURAL
HEALTH PROD
PURE AND
SIMPLE HEALTH
PRODU
PURE AND
SIMPLE HEALTH
PRODU
PURE AND
SIMPLE HEALTH
PRODU

DBA

Account Number

GRN 8888518619

*9148

GCB 8889122759

*8470

MHF 8889192043

*8660

SUPER 8889241349

*8744

GC 8888288229

*8900

VELVET 8889241373

*9155

MUSCLE 8889192050

*8520

PURE GCB 800-409-8125 *6490

PURE VITA 800-3977127

*6508

GRNC8888255058

*6771

PUREFOCUS8003888771 *7340

PURE GC 800-422-3010

*6474

PUREGRN 800 396 9790

*6607

PURE GCB 800 440 0699

*6615

PURE GC 800 433 8173

*6623

APPENDIX 1

Financial Institution
or Merchant
Processor
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services

Account Name

DBA

Account Number

PURE AND
SIMPLE HEALTH
PRODU
PURE AND
SIMPLE HEALTH
PRODU
PURE VITAMINS
LLC
PURE VITAMINS
LLC
PURE VITAMINS
LLC
PURE VITAMINS
LLC
RADIANT SKIN
LLC
RADIANT SKIN
LLC
SHIMMERING
SKIN LLC
SHIMMERING
SKIN LLC
SKINNY 7 LLC

PUREGC8888264902

*6763

SKINNY8005938032

*7431

PURE VITAMINS

*2533

PURE GCB800 397 5811

*6656

PURE GCB 800 421 7221

*6664

PURE GC 800 426 1944

*6672

BRIGHT 8004711277

*8116

SKINRX 8004811766

*8124

BSKIN 8004756117

*8140

RSKIN 8004818099

*8132

HEALTH 8889122763

*8454

SKINNY 7 LLC

ANTLER 8889241353

*8975

SKINNY 7 LLC

WELLNSS 8888518618

*8819

SKINNY 7 LLC

FORMT10 8889192047

*8702

TINDY FILMS
LLC
TINDY FILMS
LLC
TINDY FILMS
LLC
WEIGHTLOSS
DOJO LLC
WEIGHTLOSS
DOJO LLC
WELLNESS
PRODUCTS LLC

DISCOUNT DVD

*5062

BLACK BULL 800 490
1828
FORMULA T10 800 499
9515
FITNESS DVD

*6649

WL DVD 800-390-9406

*5088

PEAK 800 409 7870

*6466

*6631
*5070

APPENDIX 1

Financial Institution
or Merchant
Processor
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services
BankCard USA
Merchant Services

Account Name

DBA

Account Number

WELLNESS
PRODUCTS LLC
YACON
MARKETING LLC
YACON
MARKETING LLC
YACON
MARKETING LLC
YACON
MARKETING LLC

PEAK NITRIC OXIDE
800 398 0056
GCAM 8888299002

*6482

T10 8889192049

*8678

GRN 8889122760

*8827

GRN8888268667

*9072

*8447

APPENDIX 1

APPENDIX 2 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
CashFlows Accounts
Financial
Institution or
Merchant
Processor
CashFlows
CashFlows

Account Name

Business ID

Card Acceptor ID

Aegean Marketing DID6 LTD
**8612
Alonzo Product Marketing BC1
**8302
LTD
Alphabet City Marketing DID9 LTD **8634

**2138
**1687

**8329
**8629
**8711
**8610
**8700
**8360

**1721
**2156
**2254
**2136
**2243
**1756

CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows

Amari Marketing DEK5 LTD
Amsterdam Direct SLM11 LTD
Angeleno Marketing SLM22
Athens Marketing SLM7 LTD
Autzen Marketing DEK16 Ltd
Barrington Products Direct SLM1
LTD
Beach Products SLM16
Bimini Marketing BC15 Ltd
Bowery Marketing BC13 LTD
Bridge Road Marketing SLM21
Broadway Marketing DEK11 LTD
Brooklyn Direct DID10 LTD
Canal Products DID8 LTD
Centerline Marketing BC16 Ltd
Central Park Products SLM9 LTD

**8709
**8678
**8641
**8712
**8620
**8635
**8638
**8677
**8627

**2252
**2219
**2169
**2255
**2147
**2162
**2165
**2218
**2154

CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows

Classic Product Marketing DEK19
Coastal Marketing BC17 Ltd
Commonwealth Marketing DID13
Compass Marketing BC18 Ltd
Coral Tree Marketing DEK22 Ltd
CSC Direct BC6 LTD
Direct Health SLM2 LTD
Direct Products BC5 LTD
Dover Health DID1 LTD
Downtown Direct SLM10 LTD
Downwind Marketing BC19 Ltd
Eastwind Marketing BC14 Ltd

**8697
**8696
**8719
**8676
**8695
**8606
**8361
**8308
**8309
**8628
**8686
**8706

**2240
**2239
**2262
**2217
**2238
**2132
**1757
**1693
**1694
**2155
**2229
**2249

CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows

**2161

APPENDIX 2

Financial
Institution or
Merchant
Processor
CashFlows

Account Name

Business ID

Card Acceptor ID

Eureka Product Marketing SLM20

**8714

**2257

CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows

Fairway Marketing BC20 LTD
Gaviota Direct BC8 LTD
GN Health DID2 LTD
Golden State Products DEK21 Ltd
Greenhill Health SLM5 LTD
Greenwich Products BC9 LTD
Health Products BC4 LTD
Highline Marketing DID11 LTD
Hollis Marketing DID16 Ltd
Holly Health DID3 LTD
Hollywood Health Products DID22
Hudson Marketing BC10 LTD
Ivan Products Direct DID5 LTD
Jackson Health DEK4 LTD
Jackson Marketing SLM17 Ltd
KOS Marketing DEK2 LTD
La Maida Marketing DEK18 Ltd
Lagoon Marketing DID7 LTD
Landmark Marketing BC21 Ltd
Lexington Direct DID12 LTD
Lief Marketing SLM3 LTD
LV Health Products DEK1 LTD
Madison Marketing DEK8 LTD
Masthead Marketing BC22 Ltd
Merrimack Marketing DID14 Ltd
Milban Direct SLM4 LTD
Mix Marketingn DID4 LTD
Moya Marketing SLM6 LTD
Mustang Marketing DID17 Ltd
Mythos Direct DEK7 LTD
Nolita Products Direct BC11 LTD
North Shore Marketing DID15 Ltd
Northeast Marketing DID21 LTD
Nutra Direct BC3 LTD
Oakland Marketing SLM19

**8693
**8608
**8310
**8702
**8364
**8623
**8307
**8636
**8707
**8312
**8717
**8626
**8319
**8327
**8704
**8322
**8685
**8613
**8692
**8637
**8362
**8321
**8648
**8691
**8713
**8363
**8313
**8609
**8708
**8615
**8649
**8718
**8716
**8306
**8715

**2236
**2134
**1695
**2245
**1760
**2150
**1692
**2163
**2250
**1697
**2260
**2153
**1706
**1716
**2247
**1711
**2228
**2139
**2235
**2164
**1758
**1708
**2182
**2234
**2256
**1759
**1699
**2135
**2251
**2141
**2183
**2261
**2259
**1691
**2258

APPENDIX 2

Financial
Institution or
Merchant
Processor
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows
CashFlows

Account Name

Business ID

Card Acceptor ID

Oregon Product Marketing DEK17
Ltd
Pac12 Marketing DEK14
Pacer Products SLM14 Ltd
Pacific Product Marketing SLM15
Ltd
Park Products Direct DEK10 LTD
Paros Direct SLM8 LTD
Pure Health BC2 LTD
PURE WELLNESS PRODUCTS
LTD
Purple Mountain Marketing DEK15
Ltd
Radar Marketing BC23 Ltd
Shaw Direct DEK3 LTD
Soho Marketing SLM13 LTD
Southland Products SLM23
Spring Street Marketing BC12 LTD
Sprinter Direct DEK9 LTD
Tribeca Marketing SLM12 LTD
Tundra Direct DEK6 LTD
Van Dyke Marketing DEK20
Ventura Direct BC7 LTD
West Coast Marketing DEK13 Ltd
Westside Direct DEK12 LTD

**8701

**2244

**8688
**8703
**8705

**2231
**2246
**2248

**8619
**8611
**8303
**8189

**2146
**2137
**1688
**1496

**8699

**2242

**8690
**8324
**8631
**8710
**8625
**8618
**8630
**8614
**8689
**8607
**8698
**8621

**2233
**1713
**2158
**2253
**2152
**2145
**2157
**2140
**2232
**2133
**2241
**2148

APPENDIX 2

APPENDIX 3 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Chain Commerce Inc. (“Chain”) Accounts
Financial
Institution or
Merchant
Processor
Chain
Chain

Account Name

Account Number

BSC Marketing/MFI Limited - FITDVD
BSC Marketing/MFI Limited – DIRECTDVD

*0977
*0978

Chain

BSC Marketing/MFI Limited – PNUTRI

*0976

APPENDIX 3

APPENDIX 4 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Charles Schwab & Co., Inc. Accounts

Financial Institution

Account Name

Account Number

Charles Schwab & Co.,
Inc.

Method Films Inc 401K Profit
Sharing, Jason Miller & Danele
Miller, Pension Trustees
Method Films Inc 401K Profit
Sharing, Jason Miller & Danele
Miller, Pension Trustees
Method Films, Inc. - Defined
Beneficiary Plan, Jason Miller &
Danelle Miller, Pension Trustees

XXXX-8001 (Schwab One
Pension Trust Master
Account)
XXXX-7826 (Schwab One
Pension Trust Master
Account)
XXXX-6954 (Schwab One
Pension Trust Master
Account)

Charles Schwab & Co.,
Inc.
Charles Schwab & Co.,
Inc.

APPENDIX 4

APPENDIX 5 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Comerica Bank and/or Comerica Bank & Trust National Association (“Comerica”)
Individual Accounts
Financial Institution
Comerica
Comerica
Comerica
Comerica

Account Name
DANELLE MILLER OR JASON MILLER
DANELLE MILLER OR JASON MILLER
DANELLE MILLER OR JASON MILLER
DANELLE MILLER OR JASON MILLER

Account Number
*2914
*6350
*7242
*1325

APPENDIX 5

APPENDIX 6 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Comerica Bank and/or Comerica Bank & Trust National Association (“Comerica”)
Corporate Accounts
Financial Institution
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Account Name
458 MEDIA LLC
458 MEDIA LLC
ALPHA BRANDS LLC
ALPHA BRANDS LLC
BARREL ROLL FILMS LLC ( %
CHAPNICK SMUKLER & CHAPNICK )
BRILLIANT SKIN LLC
BRILLIANT SKIN LLC
BRILLIANT SKIN LLC
BRILLIANT SKIN LLC
BSC MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)

Account Number
*2571
*3652
*0988
*0996
*3892

BSC MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
BSC MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
BSC MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
CHERRY HILL MARKETING LLC
CHERRY HILL MARKETING LLC
CHERRY HILL MARKETING LLC
CHERRY HILL MARKETING LLC
CHERRY HILL MARKETING LLC
CSA VENTURES LLC
CSA VENTURES LLC
CSA VENTURES LLC
CSA VENTURES LLC
CSA VENTURES LLC C/O CHAPNICK
SMUKLER & CHAPNICK
DIET CONCEPTS LLC
DIET CONCEPTS LLC
DIET CONCEPTS LLC
DIET CONCEPTS LLC
DIET CONCEPTS LLC

*8883

*9585
*1045
*1052
*0822
*8875

*8891
*8909
*2811
*2852
*2829
*2837
*2845
*8917
*8925
*8933
*8941
*3728
*8977
*9017
*9058
*1748
*1755

APPENDIX 6

Financial Institution
Comerica
Comerica
Comerica
Comerica

Comerica

Comerica
Comerica
Comerica
Comerica
Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Comerica

Comerica

Comerica

Account Name
DISCOUNT PROVISIONS LLC (%CSC)
DISCOUNT PROVISIONS LLC (%CSC)
DISCOUNT PROVISIONS LLC (%CSC)
DISCOUNT PROVISIONS LLC (C/O
CHAPNICK SMUKLER & CHAPNICK
INC)
DISCOUNT PROVISIONS LLC (C/O
CHAPNICK SMUKLER & CHAPNICK
INC)
DJD DISTRIBUTION LLC ( %
CHAPNICK SMUKLER & CHAPNICK )
EXTAMAX DIRECT MARKETING LLC
EXTAMAX DIRECT MARKETING LLC
EXTAMAX DIRECT MARKETING LLC
EXTAMAX DIRECT MARKETING LLC
DBA VITAMAN LABS (% CHAPNICK
SMUKLER & CHAPNICK)
EXTREME GIRLS VIDEO LLC
F12 MEDIA LLC
F12 MEDIA LLC
FLEX FORMULAS LLC POCKET (C/O
CSC)
FLEX FORMULAS LLC MANAGEMENT
(C/O CSC)
GCB MARKETING LLC
GCB MARKETING LLC
GCB MARKETING LLC
GCB MARKETING LLC
HEALTH FORMULAS LLC
MANAGEMENT ACCOUNT (%
CHAPNICK SMUKLER & CHAPNICK)
HEALTH FORMULAS LLC MERCHANT
ACCOUNT 1 ( % CHAPNICK SMUKLER
& CHAPNICK)
HEALTH FORMULAS LLC MERCHANT
ACCOUNT 3 (% CHAPNICK SMUKLER
& CHAPNICK)
HEALTH FORMULAS LLC RESERVE
(% CHAPNICK SMUKLER &
CHAPNICK)

Account Number
*7797
*7805
*4841
*3660

*7950

*2708
*9068
*4593
*9092
*2858

*6596
*2563
*2240
*1127
*1135
*9239
*1177
*1185
*9221
*4523

*4531

*4556

*4817

APPENDIX 6

Financial Institution
Comerica

Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Comerica

Account Name
HEALTH FORMULAS LLC DBA
SIMPLE PURE NUTRITION
MANAGEMENT ACCOUNT (%
CHAPNICK SMUKLER & CHAPNICK)
HEALTH FORMULAS LLC MERCHANT
ACCOUNT 2 ( % CHAPNICK SMUKLER
& CHAPNICK)
HEALTH PRODUCTS DIRECT LLC
HEALTH PRODUCTS DIRECT LLC
HEALTH PRODUCTS DIRECT LLC
HEALTH PRODUCTS DIRECT LLC
KMS MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
KMS MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
KMS MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
KMS MARKETING LLC (% CHAPNICK
SMUKLER CHAPNICK)
LONGHORN MARKETING LLC
LONGHORN MARKETING LLC ( % CSC)
LONGHORN MARKETING LLC ( % CSC)
LONGHORN MARKETING LLC ( % CSC)
LONGHORN MARKETING LLC
RESERVE (C/O CHAPNICK SMUKLER &
CHAPNICK INC)
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC
MDCC LLC MANAGEMENT ACCOUNT
(%CSC)

Account Number
*0905

MDCC LLC POCKET ACCOUNT (%CSC)
MENS HEALTH FORMULAS LLC (%
CHAPNICK SMUKLER & CHAPNICK)
MENS HEALTH FORMULAS LLC (%
CHAPNICK SMUKLER & CHAPNICK)
MENS HEALTH FORMULAS LLC
RESERVE (% CHAPNICK SMUKLER &
CHAPNICK)
MENS HEALTH FORMULAS LLC #2 (%
CHAPNICK SMUKLER & CHAPNICK)

*8743
*2874

*4549

*9270
*9288
*9296
*1151
*8834
*8842
*8859
*8867
*3678
*7410
*7436
*7428
*3454

*9577
*1037
*1060
*1259
*7901

*4858
*3447

*0939

APPENDIX 6

Financial Institution
Comerica
Comerica
Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Comerica

Comerica

Comerica

Comerica

Comerica
Comerica
Comerica
Comerica
Comerica

Account Name
MENS HEALTH FORMULAS LLC #3 (%
CHAPNICK SMUKLER & CHAPNICK)
MENS HEALTH FORMULAS LLC (%
CHAPNICK SMUKLER & CHAPNICK)
MENS HEALTH FORMULAS LLC
MANAGEMENT ACCOUNT (%
CHAPNICK SMUKLER & CHAPNICK)
METHOD DIRECT LLC
METHOD DIRECT LLC
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD DIRECT LLC DBA PLAYBOY
OFFER DVD ENTERTAINMENT
METHOD FILMS INC DBA PLAYBOY
OFFER DVD ENTERTAINMENT (%
CHAPNICK SMUKLER & CHAPNICK)
METHOD FILMS INC DBA PLAYBOY
OFFER DVD ENTERTAINMENT (%
CHAPNICK SMUKLER & CHAPNICK)
METHOD FILMS INC DBA PLAYBOY
OFFER DVD ENTERTAINMENT MONEY
MARKET(% CHAPNICK SMUKLER &
CHAPNICK)
METHOD FILMS INC MONEY MARKET
(% CHAPNICK SMUKLER &
CHAPNICK)
METHOD FILMS INC TAX ACCOUNT
(% CHAPNICK SMUKLER &
CHAPNICK)
MORINGA MARKETING LLC
MORINGA MARKETING LLC
MORINGA MARKETING LLC
MORINGA MARKETING LLC
NATURAL PRODUCTS DIRECT LLC

Account Number
*0947
*3686
*0913

*4726
*8743
*3162
*3196
*3204
*5594
*5602
*3397
*5895

*2185

*4809

*8826

*8768

*9171
*1193
*1201
*9163
*9254

APPENDIX 6

Financial Institution
Comerica

Account Name
NATURAL PRODUCTS DIRECT LLC

Account Number
*9262

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

NATURAL PRODUCTS DIRECT LLC
NATURAL PRODUCTS DIRECT LLC
NORTHBOUND MARKETING LLC
NORTHBOUND MARKETING LLC
NORTHBOUND MARKETING LLC
NORTHBOUND MARKETING LLC
NORTHERN HEALTH PRODUCTS LLC
NORTHERN HEALTH PRODUCTS LLC
NORTHERN HEALTH PRODUCTS LLC

*1169
*9247
*9213
*1136
*1144
*9205
*9197
*9338
*9346

Comerica

NORTHERN HEALTH PRODUCTS LLC

*9189

Comerica

PURE AND NATURAL HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND NATURAL HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND NATURAL HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND NATURAL HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND SIMPLE HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND SIMPLE HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND SIMPLE HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE AND SIMPLE HEALTH
PRODUCTS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
PURE VITAMINS LLC (%CSC)
PURE VITAMINS LLC (%CSC)
PURE VITAMINS LLC (%CSC)
RADIANT SKIN LLC
RADIANT SKIN LLC
RADIANT SKIN LLC

*5122

Comerica

Comerica

Comerica

Comerica

Comerica

Comerica

Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

*5130

*5148

*2464

*5114

*5155

*5163

*2472

*1865
*1873
*1881
*9544
*9551
*9569

APPENDIX 6

Financial Institution
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Comerica
Comerica

Comerica
Comerica
Comerica
Comerica
Comerica

Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica
Comerica

Account Name
SHIMMERING SKIN LLC
SHIMMERING SKIN LLC
SHIMMERING SKIN LLC
SKINNY 7 LLC
SKINNY 7 LLC
SKINNY 7 LLC
SKINNY 7 LLC
THE BEN FRANKLIN LLC
TINDY FILMS LLC
TINDY FILMS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC MAIN ACCOUNT
WEIGHT LOSS DOJO LLC ACCOUNT
#3 (% CHAPNICK SMUKLER &
CHAPNICK)
WEIGHT LOSS DOJO LLC (%
CHAPNICK SMUKLER & CHAPNICK)
WEIGHT LOSS DOJO LLC DBA FITNESS
DVDS RESERVE ACCOUNT (%
CHAPNICK SMUKLER & CHAPNICK)
WELLNESS LABS LLC
WELLNESS LABS LLC
WELLNESS LABS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
WELLNESS LABS LLC (% CHAPNICK
SMUKLER & CHAPNICK )
WELLNESS LABS LLC RESERVE
ACCOUNT (% CHAPNICK SMUKLER &
CHAPNICK )
WELLNESS PRODUCTS LLC
WELLNESS PRODUCTS LLC
WELLNESS PRODUCTS LLC
WELLNESS PRODUCTS LLC
WELLNESS PRODUCTS LLC
WELLNESS PRODUCTS LLC
YACON MARKETING LLC
YACON MARKETING LLC

Account Number
*9601
*9619
*9627
*8936
*9320
*1110
*1128
*8693
*6024
*8350
*4618
*3702
*8024
*7295
*3694
*7287
*3462

*3371
*4734

*6088
*6047
*6005
*4866
*6655

*5296
*5338
*5965
*3710
*4601
*4874
*9312
*1219

APPENDIX 6

Financial Institution
Comerica
Comerica

Account Name
YACON MARKETING LLC
YACON MARKETING LLC

Account Number
*1227
*9304

APPENDIX 6

APPENDIX 7 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Cynergy Data LLC Accounts
Financial
Institution or
Merchant
Processor
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data

Account Name

DBA

Account Number

BARREL ROLLS

DISCOUNT DVD

*9993

BARREL ROLL
FILMS LLC
BARREL ROLL
FILMS LLC
BARREL ROLL
FILMS LLC
BSC MARKETING
LLC
CSA VENTURES
LLC
KMS MARKETING
LLC
MENS HEALTH
FORMULAS
METHOD DIRECT

BARREL
DVDENTERTAINMENT
BARREL ROLL
DVDENTERTAINMENT
DISCOUNT
DVDENTERTAINMENT
SIMPLE PURE
NUTRITION
EXERCISE DVDS

*8856

SIMPLE PURE HCG

*3206

MENS VITAMINS 800497-0709
DVD ENTERTAINING

*1417

METHOD DIRECT
LLC
METHOD DIRECT
LLC
METHOD DIRECT
LLC
METHOD DIRECT
LLC
METHOD DIRECT
LLC
PURE AND SIMPLE
HEALTH
PRODUCTS
PURE AND SIMPLE
PRODUCTS LLC
PURE VITAMINS
LLC
PURE VITAMINS

DVD ENTERTAINMENT

*0148

DVD ENTERTAINMENT

*2226

VITAMAN LAB

*0189

VITAMAN LABS

*2119

VLABS 800-490-1828

*4309

BSKIN8885967929

*3229

*9359
*9375
*5501
*4171

*3555

BSS*BRIGHTSKINSERUM *9411
MTL*GCBMAXTRIAL

*2287

G4M*GCPLUS4ME

*2311

APPENDIX 7

LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC
Cynergy Data
LLC

LLC
SHIMMERING SKIN SHIMMERING SKIN
LLC
TINDY FILMS LLC
DISCOUNT DVD

*7204
*3013

TINDY FILMS LLC

DISCOUNT DVD

*0496

WEIGHT LOSS
DOJO LLC
WELLNESS
PRODUCTS LLC
WELLNESS
PRODUCTS LLC

FITNESS DVDS

*9761

PEAKNO8886518657

*3203

P4M*PEAK4ME

*9338

APPENDIX 7

APPENDIX 8 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Electronic Merchant Systems, Inc. Accounts
Financial
Institution or
Merchant
Processor
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.
Electronic Merchant
Systems, Inc.

Account Name

DBA

Account Number

MENS HEALTH
FORMULAS, LLC
MENS HEALTH
FORMULAS, LLC
PURE AND NATURAL
HEALTH PRODUCTS,
LLC
PURE AND NATURAL
HEALTH PRODUCTS,
LLC
PURE & SIMPLE
HEALTH PRODUCTS,
LLC
PURE & SIMPLE
HEALTH PRODUCTS,
LLC
PURE VITAMINS, LLC

BBULL8885007505

*7747

TBOOST8884064394

*7754

MYSKIN8883199533

*8553

SKINRX8882962328

*8561

SKINCARE888-2954667

*1302

BSKIN 888-294-5420

*1310

BUYPURE 800-4581775
VIP SAVINGS
CENTER

*1294

VIP SAVINGS, LLC

*2908

APPENDIX 8

APPENDIX 9 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
EVO Payments International LLC (“EVO”) Accounts
Financial
Institution or
Merchant
Processor
EVO
EVO
EVO

Account Name

DBA

Account Number

BRILLIANT SKIN LLC
BRILLIANT SKIN LLC
BSC MARKETING LL

*4593
*7779
*4798

EVO
EVO

BSC MARKETING LLC
BSC MARKETING LLC

SKINRX8004771126
Brilliant Skin LLC
877-283-3402 MAX
VITMN
T10 8005280063
EMAXVITA8009790142

EVO
EVO

BSC MARKETING LLC
BSC MARKETING LLC

ExerciseDVD8666556073
VELVET8005933798

*4780
*4570

EVO

GCMax8882806778

*8238

GRN8886272373

*8246

SKNCARE8882955212

*9552

BrghtSKN8882961322

*0980

Cherry Hill Marketing

*2655

EVO
EVO
EVO

CHERRY HILL
MARKETING, LLC
CHERRY HILL
MARKETING, LLC
CHERRY HILL
MARKETING, LLC
CHERRY HILL
MARKETING, LLC
CHERRY HILL
MARKETING, LLC
CSA VENTURES LLC
CSA VENTURES LLC
CSA VENTURES LLC

*1905
*9818
*9826

EVO

CSA VENTURES LLC

EVO

DIET CONCEPTS

CSA Ventures
REPAIRRx8884064391
SKINREPAIR888406439
2
EXERDVD866-6411488
DIET8882115511

EVO

DIET CONCEPTS

GRNCOF8883199684

*8162

EVO
EVO
EVO

DIET CONCEPTS
DIET CONCEPTS
DIET CONCEPTS

GarC8882682865
Cambogia8882682865
GRNCOF8883199684

*8188
*8778
*8794

EVO
EVO
EVO
EVO

*4927
*9559

*9625
*1111

APPENDIX 9

Financial
Institution or
Merchant
Processor
EVO
EVO

Account Name

DBA

Account Number

DIET8882114873
BrtSKIN8883568999

*9640
*0659

SkinSerum8884054070

*0600

GROCERY8775915914

*4444

Super Grocery Savers

*5191

877-591-5868 PURE
VIT
VITAFIT8666304386

*4500

GC8882691233

*8760

RVITAFIT8666304386

*8577

TVITAFIT8666304386

*8783

GREEN8883473556

*9016

WVITAFIT8666304386

*8643

TSTRN8889241347

*5428

Garcinia8882663259

*5436

Ant Vel 8889241377

*5451

GreenCof8882678545

*5469

TSTRN 888-9241347
GARCINIA8882663259

*4358

EVO

DIET CONCEPTS
DISCOUNT
PROVISIONS
DISCOUNT
PROVISIONS
DISCOUNT
PROVISIONS
DISCOUNT
PROVISIONS LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH FORMULAS
LLC
HEALTH PRODUCTS
DIRECT LLC
HEALTH PRODUCTS
DIRECT LLC
HEALTH PRODUCTS
DIRECT LLC
HEALTH PRODUCTS
DIRECT LLC
HEALTH PRODUCTS
DIRECT LLC
HEALTH PRODUCTS
DIRECT LLC
KMS MARKETING LLC

*2416

EVO

KMS MARKETING LLC

KMS
MARKETING
866-630-4392 FIT
DVD..

EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO

*8718

*4499

*8833

APPENDIX 9

Financial
Institution or
Merchant
Processor
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO

Account Name

DBA

Account Number

KMS MARKETING LLC
LONGHORN
MARKETING
LONGHORN
MARKETING
LONGHORN
MARKETING LLC
LUMINOUS SKIN
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC
LUMINOUS SKIN LLC

Tboost8883486824
Longhorn Marketing

*8679
*2150

SAV8884064568

*9495

ANTLERV8775915916

*4519

GCam8888181861
Luminous Skin LLC
GCPLUS8883199678
RSKIN8887710678
GCBMAX8888240879

*8576
*7787
*6341
*6481
*8584

LUMINOUS SKIN LLC
MENS HEALTH
FORMULAS LLC
MENS HEALTH
FORMULAS LLC
MENS HEALTH
FORMULAS LLC
METHOD DIRECT LLC

Luminous Skin LLC
Velvet8884070266

*7720
*8950

MENS VITAMINS

*7467

MENSVITA8666411487

*9690

VITAFIT8009790430

*4693

METHOD DIRECT LLC
NATURAL PRODUCTS
DIRECT LLC
NATURAL PRODUCTS
DIRECT LLC
NORTHERN HEALTH
PRODUCTS LLC
NORTHERN HEALTH
PRODUCTS LLC
NORTHERN HEALTH
PRODUCTS LLC
NORTHERN HEALTH
PRODUCTS LLC
PURE AND NATURAL
HEALTH PRODUCT

ExtaMax8009790157
GC8886272377

*4332
*8196

GRNLEAN8886272318

*8204

8889241348TBoost

*4553

8882473398GRNCLN

*4561

8889241376Velvet

*4579

8882374123MYGC

*4645

SKINRX8882962328

*6855

APPENDIX 9

Financial
Institution or
Merchant
Processor
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO

Account Name

DBA

Account Number

PURE AND NATURAL
HEALTH PRODUCT
PURE AND NATURAL
HEALTH PRODUCTS
PURE AND NATURAL
HEALTH PRODUCTS
PURE AND SIMPLE
HEALTH PRODUCTS
PURE AND SIMPLE
HEALTH PRODUCTS
PURE VITAMINS LLC
PURE VITAMINS LLC
PURE VITAMINS LLC
PURE VITAMINS LLC
PURE VITAMINS LLC
PURE VITAMINS LLC
PURE VITAMINS, LLC
RADIANT SKIN LLC
RADIANT SKIN LLC
RADIANT SKIN LLC
RADIANT SKIN LLC
SHIMMERING SKIN
LLC
SHIMMERING SKIN
LLC
SHIMMERING SKIN
LLC
SHIMMERING SKIN
LLC
SHIMMERING SKIN
LLC
SHIMMERING SKIN
LLC
SKINNY 7 LLC
SKINNY 7 LLC
SKINNY 7 LLC
SKINNY 7 LLC
SKINNY7 LLC
VIP SAVINGS CENTER

MYSKIN8883199533

*6707

GCLEAN8886272379

*8212

GRN8886272320

*8220

BSKN8882945420

*6954

SKINCARE8882954667

*6830

BuyPure8004581775
WPUREVIT8666304396
RPUREVIT8666304396
TPUREVIT8666304396
PUREVITA8666304396
PureGrn8004670776
8666304396PureVita
Rskin8004818099
SKINRPR8004811766
RSKIN8004818099
SKINRPR8004811766
Sknsrm8004756117

*5387
*8858
*9062
*8924
*8999
*5395
*2418
*2300
*2326
*0217
*0282
*2428

Bright8004711277

*2477

Skincare8885961949

*7834

SKINSERUM888596195
2
BRIGHT8004711277

*7842

sknsrm8004756117

*1435

GC8883481746
Skinny 7 LLC
GCSLIM8888177165
MyGCB8888207341
Skinny 7 LLC
VIPSAVE8666304391

*7885
*7688
*8550
*8568
*7696
*4378

*1252

APPENDIX 9

Financial
Institution or
Merchant
Processor
EVO
EVO
EVO
EVO
EVO
EVO
EVO
EVO

Account Name

DBA

Account Number

VIP SAVINGS LLC
VIP SAVINGS LLC
VIP SAVINGS LLC
WEIGHT LOSS DOJO
LLC
WELLNESS LABS LLC
WELLNESS PRODUCTS
LLC
WELLNESS PRODUCTS
LLC
WELLNESS PRODUCTS
LLC

GCB8883466629
Garcinia8882699189
Vip Savings LLC
WeightDojo8003909409

*9156
*9172
*3351
*4290

wellnss8883199542
800431851
PKNITRICOXDE
GETNITRO8886158898

*0212
*0450

nitro8886080191

*7891

*7909

APPENDIX 9

APPENDIX 10 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Humboldt Merchant Services Accounts
Financial
Institution or
Merchant
Processor
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt
Merchant Services
Humboldt

Account Name

DBA

Account
Number

BSC MARKETING

SUPERIOR VELVET

*6887

BSC MARKETING

T10

*7885

DIET CONCEPTS

Diet Concepts

*4882

HEALTH PRODUCTS
DIRECT
HEALTH PRODUCTS
DIRECT
HEALTH PRODUCTS
DIRECT
HEALTH PRODUCTS
DIRECT
NOTHERN HEALTH
PRODUCTS
NOTHERN HEALTH
PRODUCTS
NOTHERN HEALTH
PRODUCTS
NOTHERN HEALTH
PRODUCTS
NOTHERN HEALTH
PRODUCTS
PURE AND NATURAL
HEALTH
PURE AND NATURAL
HEALTH
PURE AND SIMPLE
HEALTH PRODUCTS LLC
PURE VITAMINS LLC

Tboostmax.com

*6881

AuthenticGCB.com

*7889

AuthenticGC.com

*8887

MAXANTLERVELVET.C
OM
Antlervelvetplus.com

*5883

VELVET 8889241376

*1880

Grn Cln8882473398

*0884

T BOOST 8889241348

*1882

MY GC 18882374123

*2880

GETREMARKABLESKIN.
COM
MYREMARKABLESKIN.
COM
BRAVOBRIGHTSKIN.CO
M
BUY PURE GC

*0882

PURE VITAMINS LLC

PURE GREEN

*8883

RADIANT SKIN LLC

Tryrxrepair.com

*8882

*0882

*1880
*3881
*9881

APPENDIX 10

Merchant Services
Humboldt
Merchant Services

SHIMMERING SKIN LLC

Trybrightskin.com

*9881

APPENDIX 10

APPENDIX 11 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Meritus Payment Solutions, now known as Paysafe Group, a subsidiary of
Optimal Payments (“Meritus”) Accounts
Financial
Institution
or Merchant
Processor
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus
Meritus

Account Name

DBA

Account Number

Cherry Hill Marketing
LLC
Cherry Hill Marketing
LLC
CSA Ventures LLC
CSA Ventures LLC
Diet Concepts LLC
Diet Concepts LLC
Extamax Direct
Marketing LLC
Health Formulas, LLC
Health Formulas
KMS Marketing LLC
KMS Marketing LLC
Longhorn Marketing
LLC
Men’s Health Formulas
LLC
Method Direct LLC
Method Direct LLC
Method Direct LLC
Method Direct LLC
Method Direct LLC
Method Films Limited
Method Films Limited
Method Films Limited
Method Films Limited
Natural Products Direct
LLC
Natural Products Direct
LLC
Shimmering Skin LLC

Pure Green Coffee Bean Plus

*1267

Garcinia Cambogia Lean

*1275

VitaMan Labs
FITNESS DVDS
Skinny 6
Authentic Green Coffee Bean
EXTAMAX DIRECT
MARKETING LLC
Simple Pure Nutrition
Pure Vitamins
DIRECT DVD
Simple Pure Nutrition
Life Vitamins

*9535
*9537
*1150
*1168
*0860

Men’s Health

*7799

VitaMan Labs
DVD Entertainment
DVD Entertainment-2 SK
DVD Entertainment SK
VitaMan Labs SK
Pure Vitamins
Life Vitamins
Men's Health Formulas
Simple Pure Nutrition
Green Coffee Lean

*6519
*6899
*6258
*7059
*7119
*7277
*7539
*7573
*7591
*1176

Garcinia Cambogia Max

*1184

Garcinia Plus

*1192

*8319
*7299
*9538
*7759
*7779

APPENDIX 11

Meritus
Meritus
Meritus
Meritus
Meritus

Shimmering Skin LLC
Tindy Films, LLC
VIP Savings LLC
Weight Loss Dogo,
LLC
Wellness Products LLC

Green Coffee Bean
Weightloss Dojo
VIP Savings Center
FITNESS DVDS

*1200
*1142
*9536
*1079

Peak Nitric Oxide

*3183

APPENDIX 11

APPENDIX 12 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
Orion Payment Systems Accounts
Financial Institution
or Merchant
Processor
Orion Payment
Systems
Orion Payment
Systems
Orion Payment
Systems
Orion Payment
Systems
Orion Payment
Systems
Orion Payment
Systems

Account Name

DBA

Account Number

Diet Concepts, LLC

SKINNY8888284662

*0043

Diet Concepts, LLC

GreenCoffee8886080209

*0044

Pure and Simple
Health Products, LLC
Shimmering Skin,
LLC
Shimmering Skin,
LLC
Wellness Products
LLC

Bskin8887083242

*0046

GREENCOF8886080210

*0047

Bright8885961948

*0048

PEAK8888247530

*0045

APPENDIX 12

APPENDIX 13 TO STIPULATED ORDER
FOR PERMANENT INJUNCTION AND MONETARY JUDGMENT
UBS Financial Services, Inc. Accounts
Financial Institution

Account Name

Account Number

UBS Financial Services
Inc.

Danelle Miller College Fund 529
FBO [REDACTED]

JP-XXX00 (529 Account)

UBS Financial Services
Inc.

Danelle Miller College Fund 529
FBO [REDACTED]

JP-XXX02 (529 Account)

UBS Financial Services
Inc.

Danelle Miller College Fund 529
FBO [REDACTED]

JP-XXX01 (529 Account)

UBS Financial Services
Inc.

Danelle Miller, Jason Miller
JTWROS

34760 (Resource Managed
Account)

UBS Financial Services
Inc.

Danelle Marie Miller SEP-IRA

JP-56767 (Retirement
Account)

UBS Financial Services
Inc.

Danelle Miller SEP-IRA

JP-34759 (Retirement Acct)

UBS Financial Services
Inc.

Jason Miller SEP- IRA

JP-34757 (Retirement
Account)

UBS Financial Services
Inc.

Jason Miller SEP- IRA

JP-39956 (Retirement
Account)

APPENDIX 13