Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 1 of 21
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`UNITED STATES DISTRICT COURT
` DISTRICT OF COLUMBIA
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`Case No. ____________
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`FEDERAL TRADE COMMISSION,
`600 Pennsylvania Avenue, N.W.
`Washington, DC 20580,
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`GRAVITY DEFYER MEDICAL
`TECHNOLOGY CORPORATION, also d/b/a
`GRAVITY DEFYER CORPORATION, a
`corporation,
`10643 Glenoaks Boulevard
`Pacoima, CA 91331, and
`
`ALEXANDER ELNEKAVEH, individually and
`as an officer of GRAVITY DEFYER MEDICAL
`TECHNOLOGY CORPORATION,
`10643 Glenoaks Boulevard
`Pacoima, CA 91331,
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`
`
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`Plaintiff,
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`v.
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`Defendants.
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`
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`COMPLAINT FOR PERMANENT INJUNCTION,
`CIVIL PENALTIES, AND OTHER RELIEF
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`Plaintiff, the Federal Trade Commission (“FTC” or “Commission”), for its Complaint
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`alleges:
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`1.
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`The FTC brings this action under Sections 5(a) and (l) of the FTC Act, 15 U.S.C.
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`§§ 45(a) and (l), which authorize the FTC to seek, and the Court to order, monetary civil
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`penalties and permanent injunctive and other relief for (a) violations of a 2001 order issued by
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`the Commission and (b) Defendants’ acts or practices in violation of Sections 5(a) and 12 of the
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`FTC Act, 15 U.S.C. §§ 45(a) and 52. See Exhibit A, pp. 3-6, In re Esrim Ve Sheva Holding
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`1
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 2 of 21
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`Corp., 132 F.T.C. 736, 2001 FTC LEXIS 192 (“Commission Order”). (The Commission Order
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`is also available at https://www.ftc.gov/sites/default/files/documents/cases/2001/12/evshdo.pdf.)
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`SUMMARY OF CASE
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`2.
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`Defendant Gravity Defyer Medical Technology Corporation (“Gravity Defyer”)
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`labels, advertises, markets, distributes, and sells footwear under the brand name “Gravity
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`Defyer.” Defendant Alexander Elnekaveh owns Gravity Defyer. This action seeks to hold
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`Gravity Defyer and Alexander Elnekaveh accountable for violating the FTC Act by claiming,
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`without substantiation, that Gravity Defyer footwear reduces knee, back, ankle, and foot pain and
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`helps with various conditions, including conditions such as plantar fasciitis, arthritis, joint pain,
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`and heel spurs. This action also seeks to hold Defendants accountable for violating the
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`Commission Order, which prohibits making misrepresentations through user testimonials or
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`about tests, studies, or research.
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`JURISDICTION AND VENUE
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`3.
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`This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a),
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`and 1345.
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`4.
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`Venue is proper in this District under 28 U.S.C. § 1391(b)(2), (b)(3), (c)(2), and
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`15 U.S.C. § 53(b).
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`PLAINTIFF
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`5.
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`The FTC is an independent agency of the United States Government created by
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`the FTC Act, which authorizes the FTC to commence this district court civil action by its own
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`attorneys. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC Act, 15 U.S.C.
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`§ 45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce, and
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`Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false advertisements for food, drugs,
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`2
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 3 of 21
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`devices, services, or cosmetics in or affecting commerce. The FTC also enforces Section 5(l) of
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`the FTC Act, 15 U.S.C. §5(l), which makes it unlawful to violate a Commission order after it has
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`become final and while it is in effect.
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`DEFENDANTS
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`6.
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`Defendant Gravity Defyer Medical Technology Corporation, also doing business
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`as Gravity Defyer Corporation, is a California corporation with its principal place of business at
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`10643 Glenoaks Boulevard, Pacoima, CA 91331. Gravity Defyer transacts or has transacted
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`business in this District and throughout the United States. At all times relevant to this
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`Complaint, acting alone or in concert with others, Gravity Defyer has advertised, marketed,
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`distributed, or sold footwear to consumers throughout the United States, including in the District
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`of Columbia.
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`7.
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`Defendant Alexander Elnekaveh is the founder, chairman, president, secretary,
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`and sole owner of Gravity Defyer. At all times relevant to this Complaint, acting alone or in
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`concert with others, he has formulated, directed, controlled, had the authority to control, or
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`participated in the acts and practices of Gravity Defyer, including the acts and practices set forth
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`in this Complaint. Defendant Elnekaveh invented the VersoShock sole contained in Gravity
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`Defyer footwear and has overseen daily operations of the business, including (a) product
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`development, (b) business strategy, and (c) approval of advertising and marketing materials.
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`Defendant Elnekaveh also (a) conceived of, (b) decided to fund, and (c) participated in
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`formulating a protocol for, clinical research on the VersoShock sole that has been cited in
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`Gravity Defyer ads. Defendant Elnekaveh, in connection with the matters alleged herein,
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`transacts or has transacted business in this District and throughout the United States.
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`3
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 4 of 21
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`COMMERCE
`At all times relevant to this Complaint, Defendants have maintained a substantial
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`8.
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`course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act,
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`15 U.S.C. § 44.
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`THE COMMISSION ORDER
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`9.
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`In 2001, the Commission issued an administrative complaint against Esrim Ve
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`Sheva Holding Corporation, sometimes doing business as Gadget Universe (“Gadget Universe”),
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`and Alexander Elnekaveh, individually and as an officer of the corporation. Exhibit A, pp. 1-3,
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`In re Esrim Ve Sheva Holding Corp., et al., 132 F.T.C. 736, 2001 FTC LEXIS 192 (“2001
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`Complaint”). The 2001 Complaint charged Gadget Universe and Defendant Elnekaveh with
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`engaging in unfair or deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15
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`U.S.C. § 45(a). Id., p. 3, ¶ 12. It alleged that Defendant Elnekaveh, individually or in concert
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`with others, formulated, directed, or controlled the policies, acts, or practices of Gadget
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`Universe. Id., p. 1, ¶ 1b.
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`10.
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`According to the 2001 Complaint, Gadget Universe and Defendant Elnekaveh
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`advertised, offered for sale, sold, and distributed to the public Super FuelMAX, an automotive
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`aftermarket fuel-line magnet device. The Commission alleged that Gadget Universe and
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`Defendant Elnekaveh represented that when applied to a motor vehicle fuel line, Super
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`FuelMAX, among other things: (a) reduced fuel consumption; (b) reduced fuel consumption by
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`27% or up to 27%; (c) reduced harmful emissions or pollutants; and (d) reduced harmful
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`emissions or pollutants by 42% or up to 40%. The Commission asserted that Gadget Universe
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`and Defendant Elnekaveh did not have a reasonable basis that substantiated these representations
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`and that they were therefore false or misleading. Id., p. 2, ¶¶ 5-7.
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`11.
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`The Commission further alleged that Gadget Universe and Defendant Elnekaveh
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`represented that tests performed at a certified EPA laboratory proved that Super FuelMAX
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`increased mileage by 27% and reduced harmful pollutants by 42%. The Commission asserted,
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`however, that tests performed by a certified EPA laboratory did not prove that Super FuelMAX
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`increased mileage by 27% and reduced harmful pollutants by 42%, thus these representations
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`about the test results also were false or misleading. Id., p. 2, ¶¶ 8-9.
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`12.
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`Finally, the Commission alleged that Gadget Universe and Defendant Elnekaveh
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`represented that a testimonial by Defendant Elnekaveh appearing in Super FuelMAX’s
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`advertisements reflected both Defendant Elnekaveh’s actual findings and experience with the
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`product and the typical or ordinary experiences of people who used the product. The
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`Commission asserted, however, that the testimonial did not reflect Defendant Elnekaveh’s actual
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`findings and experience with the product and the typical or ordinary experience of people who
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`used the product and, therefore, also was false or misleading. Id., p. 3, ¶¶ 10-11.
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`13.
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`Gadget Universe and Defendant Elnekaveh settled the 2001 Complaint with the
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`Commission Order. The Commission Order became final in December 2001.
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`14.
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`Part III of the Commission Order states:
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`IT IS FURTHER ORDERED THAT [Gadget Universe and Defendant
`Elnekaveh], directly or through any corporation, subsidiary, division, or other
`device, in connection with the manufacturing, labeling, advertising, promotion,
`offering for sale, sale, or distribution of any product in or affecting commerce,
`shall not misrepresent, in any manner, expressly or by implication, that the
`experience represented by any user testimonial or endorsement of the product
`represents the typical or ordinary experience of members of the public who used
`the product, unless:
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`The representation is true and, at the time it is made,
`A.
`[Gadget Universe and Defendant Elnekaveh] possess and rely upon
`competent and reliable scientific evidence that substantiates the
`representation; or
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`5
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 6 of 21
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`[Gadget Universe and Defendant Elnekaveh] disclose,
`B.
`clearly and prominently, and in close proximity to the endorsement
`or testimonial, either:
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`what the generally expected results would be for
`1.
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`users of the product, or
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`the limited applicability of the endorser’s
`2.
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`experience to what consumers may generally expect to achieve,
`that is, that consumers should not expect to experience similar
`results.
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`For purposes of this Part, “endorsement” shall mean as defined in 16
`C.F.R. § 255.0(b).
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`Exhibit A, p. 5.
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`15.
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`Part IV of the Commission Order states:
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`IT IS FURTHER ORDERED THAT [Gadget Universe and Defendant
`Elnekaveh], directly or through any corporation, subsidiary, division, or other
`device, in connection with the manufacturing, labeling, advertising, promotion,
`offering for sale, sale, or distribution of any product in or affecting commerce,
`shall not misrepresent, in any manner, expressly or by implication, the existence,
`contents, validity, results, conclusions, or interpretations of any test, study or
`research.
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`DEFENDANTS’ NOTICE OF THE COMMISSION ORDER
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`Id.
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`16.
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`On behalf of himself and Gadget Universe, Defendant Elnekaveh signed an
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`Agreement Containing Consent Order (“Agreement”), which included the Commission Order.
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`Among other things, the Agreement states:
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`[Gadget Universe and Defendant Elnekaveh] have read the [2001
`Complaint] and [Commission Order]. They understand that they may be
`liable for civil penalties in the amount provided by law and other
`appropriate relief for each violation of the [Commission Order] after it
`becomes final.
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`Defendant Elnekaveh also signed a statement acknowledging receipt of the Commission
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`6
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`Order.
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 7 of 21
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`17.
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`As an officer and the sole owner of Gravity Defyer, Defendant Elnekaveh’s
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`knowledge of the Commission Order is imputed to Gravity Defyer. Gravity Defyer thus has had
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`actual notice of the Commission Order. By virtue of the business activities described below,
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`Gravity Defyer acted in active concert or participation with Defendant Elnekaveh in violating it.
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`DEFENDANTS’ BUSINESS ACTIVITIES
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`18.
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`Since at least 2011, Defendants have advertised, offered to sell, distributed, and
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`sold Gravity Defyer footwear to consumers. Since at least 2016, Defendants have advertised that
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`Gravity Defyer footwear contains soles with VersoShock technology that relieve pain, including
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`pain in people suffering from numerous conditions. Gravity Defyer’s customers are primarily
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`people aged 55 and older.
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`19.
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`Defendants have sold Gravity Defyer’s footwear to consumers throughout the
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`United States, including to consumers in the District of Columbia, through Gravity Defyer’s
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`website, www.gravitydefyer.com; its in-house call center; stores located in Los Angeles,
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`Huntington Beach, Palm Desert, and Encino, CA; and retailers such as The Walking Company,
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`Hammacher Schlemmer, and Shoe City. At various times relevant to this complaint,
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`gravitydefyer.com has offered for sale over 100 different styles of shoes for men and women,
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`including athletic shoes, casual shoes, dress shoes, hiking shoes and boots, and sandals.
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`20.
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`Retail prices for Gravity Defyer footwear have included, but are not limited to,
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`the following approximate prices: $140 for men’s and women’s sandals; $155 for the Mighty
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`Walk and the Ion, which are widely-advertised men’s and women’s walking shoes; $155 for the
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`Iokia, which is a walking shoe without laces; $170 and $180 for the Compass and the Cloud
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`Walk, respectively, which are part of Gravity Defyer’s ProWork line for people such as medical
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`professionals who are on their feet all day; $185 and $210, respectively, for low-top and high-top
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`hiking shoes; $175 to $200 for various styles of men’s casual and dress shoes; and up to $235 for
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`men’s work boots.
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`21.
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`Gravity Defyer’s annual footwear sales, excluding refunds, totaled approximately
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`$3.9 million in 2016, $9.6 million in 2017, and $13.1 million in 2018. Sales of its footwear
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`minus refunds in the first three quarters of 2019 were approximately $11.2 million.
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`22.
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`Defendants have advertised and marketed Gravity Defyer footwear through
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`magazine advertisements, gravitydefyer.com, Facebook ads, Internet ads, radio commercials, and
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`catalogs. Gravity Defyer’s magazine advertisements have appeared in a wide variety of
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`publications, including Reader’s Digest, The Saturday Evening Post, WebMD, Weight Watchers,
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`Arthritis Today, Diabetes Forecast, Guideposts, Sunset, The National Enquirer, Star, This Old
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`House, Popular Science, Discover, Field & Stream, Outdoor Life, Sierra, Smithsonian, TV
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`Guide, National Review, The New Yorker, The Atlantic, Time, and Military Officer. These
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`advertisements have been widely disseminated to consumers throughout the United States.
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`23.
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`Defendants have represented that Gravity Defyer footwear will relieve pain,
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`including knee, back, ankle, and foot pain, and pain in people suffering from conditions such as
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`plantar fasciitis, arthritis, joint pain, and heel spurs.
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`24.
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`Defendants have represented that Gravity Defyer footwear is clinically proven to
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`relieve pain, including 85% less knee pain, 91% less back pain, 92% less ankle pain, and 75%
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`less foot pain.
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`25.
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`To induce consumers to purchase Gravity Defyer footwear, Defendants have
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`disseminated or caused to be disseminated advertisements for various kinds of Gravity Defyer
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`footwear. These and other advertisements contain the following statements and depictions,
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`among others:
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`8
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 9 of 21
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`An excerpt of a magazine advertisement that ran from approximately 2017 to
`2018:
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`A.
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 10 of 21
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`B.
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`An excerpt of a magazine advertisement that ran from approximately 2018 to
`2020:
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 11 of 21
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`C.
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`An excerpt of gravitydefyer.com captured on October 23, 2019 (page entitled
`“Knee Pain”):
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`D.
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`An excerpt of the gravitydefyer.com landing page captured on December 13,
`2019:
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 12 of 21
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`E. An excerpt of gravitydefyer.com captured on January 15, 2020:
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`F.
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`An excerpt of the gravitydefyer.com technology page captured on April 3, 2020:
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 13 of 21
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`G.
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`A Facebook ad from January 2020:
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`H. A Google ad:
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`I.
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`A Google text ad:
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`Shoes for Plantar Fasciitis
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` Clinically Proven Pain Relief
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`Pain Relief Is What We’re All About!
` No Risk 30 Day Home Trial + Free Shipping
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 15 of 21
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`J.
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`The cover of Gravity Defyer’s September 2019 catalog:
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`15
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 16 of 21
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`26.
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`Defendants have also disseminated or caused to be disseminated advertisements
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`for Gravity Defyer footwear that contain user testimonials. Through these testimonials,
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`Defendants have claimed that Gravity Defyer shoes alleviate pain located in the knees, back, or
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`feet, or associated with conditions such as plantar fasciitis, arthritis, or neuropathy.
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`27.
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`Defendants lacked competent and reliable scientific evidence to substantiate the
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`claims identified above. The study cited in Gravity Defyer’s ads has substantial flaws. Among
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`other things, it was of insufficient size and duration, failed to ensure adequate double-blinding,
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`failed to adequately control for other treatments that participants might have received (such as
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`medications or physical therapy), relied solely on participants’ self-reported pain levels instead
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`of including range of motion or other functional tests, failed to take into account data from
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`approximately twice as many participants who wore Gravity Defyer shoes with and without the
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`VersoShock sole, and included results from participants who stopped wearing the shoes. It was
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`also only designed to measure knee pain. Thus, the study was not sufficient to determine the
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`effects of wearing Gravity Defyer footwear on knee, back, ankle, or foot pain, or pain associated
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`with the specific conditions claimed.
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`28.
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`Based on the facts and violations of law alleged in this Complaint, the FTC has
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`reason to believe that Defendants are violating or are about to violate laws enforced by the
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`Commission because, among other things:
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`A.
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`Defendants continue to make deceptive pain relief claims on the website
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`gravitydefyer.com;
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`B.
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`Defendants have engaged in their unlawful acts and practices repeatedly
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`over a period of approximately ten years;
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`16
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 17 of 21
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`C.
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`Defendant Elnekaveh has previously settled FTC charges of false or
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`misleading advertising;
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`D.
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`Defendants continued to disseminate their deceptive advertising despite
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`repeated recommendations from the National Advertising Division of BBB
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`National Programs, Inc. that they discontinue such claims; and
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`E.
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`Defendants remain in the business of marketing and selling footwear and
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`maintain the means, ability, and incentive to continue their unlawful conduct.
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`VIOLATIONS OF THE COMMISSION ORDER
`Count I
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`MISREPRESENTING THAT A USER TESTIMONIAL IS TYPICAL
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`29.
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`Part III of the Commission Order prohibits Defendant Elnekaveh and those with
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`
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`notice of the Commission Order who act in active concert or participation with him from
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`claiming that the experience described in a user testimonial represents the typical or ordinary
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`experience of people who use the product, unless the representation is true and Defendant
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`Elnekaveh possesses and relies upon competent and reliable scientific evidence that substantiates
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`the claim or there is a disclosure that complies with Part III of the Commission Order.
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`30.
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`Since at least 2016, advertisements for Gravity Defyer footwear have contained
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`user testimonials claiming that the shoes alleviate pain located in the knees, back, or feet, or
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`associated with conditions such as plantar fasciitis, arthritis, or neuropathy. Through these
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`testimonials, Defendants have implied that the experiences described in the testimonials
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`represent the typical or ordinary experiences of people who use the product.
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`31.
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`Defendants’ representation that the experiences described in the testimonials
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`represent the typical or ordinary experiences of people who use the product were not
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 18 of 21
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`substantiated by competent and reliable scientific evidence, nor did they contain a disclosure that
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`complied with Part III of the Commission Order.
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`32.
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`Therefore, the representations set forth in Paragraph 30 violate Part III of the
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`Commission Order.
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`Count II
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`MISREPRESENTING THE RESULTS OF A STUDY
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`Part IV of the Commission Order prohibits Defendant Elnekaveh and those with
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`33.
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`notice of the Commission Order who act in active concert or participation with him from
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`misrepresenting “the existence, contents, validity, results, conclusions, or interpretations of any
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`test, study, or research.”
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`34.
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`Since at least 2017, Defendants, citing a study, have represented that Gravity
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`Defyer footwear is clinically proven to relieve pain, including knee, back, ankle, and foot pain.
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`35.
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`In fact, the study did not demonstrate that Gravity Defyer footwear was clinically
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`proven to relieve pain.
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`36.
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`Therefore, the representations set forth in Paragraph 34 violate Part IV of the
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`Commission Order.
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`VIOLATIONS OF THE FTC ACT
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`37.
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`Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts
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`or practices in or affecting commerce.”
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`38. Misrepresentations or deceptive omissions of material fact constitute deceptive
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`acts or practices prohibited by Section 5(a) of the FTC Act.
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`39.
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`Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the dissemination of any
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`false advertisement in or affecting commerce for the purpose of inducing, or which is likely to
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 19 of 21
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`induce, the purchase of food, drugs, devices, services, or cosmetics. For the purposes of Section
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`12 of the FTC Act, 15 U.S.C. § 52, Gravity Defyer footwear is a “device” as defined in Section
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`15(d) of the FTC Act, 15 U.S.C. § 55(d).
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`Count III
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`FALSE OR UNSUBSTANTIATED EFFICACY CLAIMS
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`In numerous instances in connection with the advertising, marketing, promotion,
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`40.
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`offering for sale, or sale of Gravity Defyer footwear, including through the means described in
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`Paragraphs 18 to 26, Defendants have represented, directly or indirectly, expressly or by
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`implication, that:
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`A.
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`B.
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`C.
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`D.
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`People who have knee pain and wear Gravity Defyer footwear will
`experience significantly less pain, including by as much as 85%;
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`People who have back pain and wear Gravity Defyer footwear will
`experience significantly less pain, including by as much as 91%;
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`People who have ankle pain and wear Gravity Defyer footwear will
`experience significantly less pain, including by as much as 92%;
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`People who have foot pain and wear Gravity Defyer footwear will
`experience significantly less pain, including by as much as 75%; and
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`E.
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`Gravity Defyer footwear will relieve pain, including pain in people
`suffering from conditions such as plantar fasciitis, arthritis, joint pain, and
`heel spurs.
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`The representations set forth in Paragraph 40 are false or misleading or were not
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`41.
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`
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`substantiated at the time the representations were made.
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`42.
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`Therefore, the making of the representations as set forth in Paragraph 40
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`constitutes a deceptive act or practice and the making of false advertisements in violation of
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`Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52.
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`19
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 20 of 21
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`Count IV
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`FALSE PROOF CLAIMS
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`In numerous instances in connection with the advertising, marketing, promotion,
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`43.
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`offering for sale, or sale of Gravity Defyer footwear, including through the means described in
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`Paragraphs 18 to 26, Defendants have represented, directly or indirectly, expressly or by
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`implication, that Gravity Defyer footwear is clinically proven to:
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`44.
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`45.
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`A.
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`B.
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`C.
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`D.
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`E.
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`Relieve pain, including knee, back, ankle, and foot pain;
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`Reduce knee pain by 85%;
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`Reduce back pain by 91%;
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`Reduce ankle pain by 92%; and
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`Reduce foot pain by 75%.
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`The representations set forth in Paragraph 43 are false.
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`Therefore, the making of the representations as set forth in Paragraph 43
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`constitutes a deceptive act or practice and the making of false advertisements in violation of
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`Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52.
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`CONSUMER INJURY
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`46.
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`Consumers are suffering, have suffered, and will continue to suffer substantial
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`injury as a result of Defendants’ violations of the Commission Order and the FTC Act. Absent
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`injunctive relief by this Court, Defendants are likely to continue to injure consumers and harm
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`the public interest.
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`20
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`Case 1:22-cv-01464-RDM Document 1 Filed 05/25/22 Page 21 of 21
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`Wherefore, Plaintiff requests that the Court:
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`PRAYER FOR RELIEF
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`A.
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`Enter judgment against Defendants and in favor of Plaintiff for violating the
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`Commission Order as alleged in this Complaint;
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`B.
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`Enter judgment against Defendants and in favor of Plaintiff for violating the FTC
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`Act as alleged in this Complaint;
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`C.
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`Award Plaintiff monetary civil penalties from Defendants for each violation of the
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`Commission Order;
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`D.
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`E.
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`Enter a permanent injunction to prevent future violations of the FTC Act;
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`Award monetary and other relief within the Court’s power to grant; and
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`Award any additional relief as the Court determines to be just and proper.
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`Respectfully submitted,
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` /s/ Maria Del Monaco_____________
`Maria Del Monaco, OH Bar 0067930
`mdelmonaco@ftc.gov, (216) 263-3405
`Dana C. Barragate, OH Bar 0065748
`dbarragate@ftc.gov, (216) 263-3402
`Mathew M. Scheff, OH Bar 0082229
`mscheff@ftc.gov, (216) 263-3414
`Adrienne M. Jenkins, OH Bar 0089568
`ajenkins@ftc.gov, (216) 263-3411
`Federal Trade Commission
`1111 Superior Avenue, Suite 200
`Cleveland, OH 44114
`(216) 263-3426 (fax)
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`Attorneys for Plaintiff
`Federal Trade Commission
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`F.
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`Dated: May 25, 2022
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`21
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