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`UNITED STATES DISTRICT COURT
`IN THE MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
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`UNITED STATES OF AMERICA,
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`Case No.
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`Plaintiff,
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`v.
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`VOIP TERMINATOR, INC., a corporation,
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`BLMARKETING, INC., a corporation, and
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`MUHAMMED USMAN KHAN, individually and
`as an officer of VOIP TERMINATOR, INC. and
`BLMARKETING, INC.,
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`Defendants.
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`STIPULATED ORDER FOR
`PERMANENT INJUNCTION,
`CIVIL PENALTY JUDGMENT, AND
`OTHER RELIEF
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`Plaintiff, the United States of America, acting upon notification and authorization to the
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`Attorney General by the Federal Trade Commission (“Commission” or “FTC”), filed its
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`Complaint for a permanent injunction, civil penalties, and other relief (“Complaint”), pursuant
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`to Sections 5(a), 5(m)(1)(A), 13(b), and 16(a)(1) of the Federal Trade Commission Act (“FTC
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`Act”), 15 U.S.C. §§ 45(a), 45(m)(1)(A), 53(b), and 56(a)(1), and Section 6 of the Telemarketing
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`and Consumer Fraud and Abuse Prevention Act (the “Telemarketing Act”), 15 U.S.C. § 6105.
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`Defendants have waived service of the summons and the Complaint. Plaintiff and Defendants
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`stipulate to the entry of this Stipulated Order for Permanent Injunction, Civil Penalty Judgment,
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`and Other Relief (“Order”) to resolve all matters in dispute in this action between them.
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`THEREFORE, IT IS ORDERED as follows:
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 2 of 19 PageID 34
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`1.
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`2.
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`This Court has jurisdiction over this matter.
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`FINDINGS
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`The Complaint charges that Defendants participated in acts or practices in violation of
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`Section 5 of the FTC Act, 15 U.S.C. § 45 and the FTC’s Telemarketing Sales Rule (the “TSR” or
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`“Rule”), as amended, 16 C.F.R. Part 310, by, among other things, assisting and facilitating:
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`(a) placing telemarketing calls to consumers that delivered prerecorded messages; (b) placing
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`telemarketing calls to consumers whose telephone numbers were on the National Do Not Call
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`(“DNC”) Registry; and (c) transmitting inaccurate caller ID numbers and names with their
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`telemarketing calls.
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`3.
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`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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`Defendants waive any claim that they may have under the Equal Access to Justice Act,
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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.
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`5.
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`Defendants and the Plaintiff waive all rights to appeal or otherwise challenge or contest
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`the validity of this Order.
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`DEFINITIONS
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`For the purpose of this Order, the following definitions apply:
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`A. “Assisting” includes, among other conduct, providing or reselling Voice over
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`Internet Protocol (“VoIP”) telephony services and providing or licensing telephone
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`numbers.
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`B. “Defendants” means the Individual Defendant and Corporate Defendants,
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`individually, collectively, or in any combination.
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`1.
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`“Corporate Defendants” means VoIP Terminator, Inc. and BLMarketing,
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`Inc. and their successors and assigns.
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`2.
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`“Individual Defendant” means Muhammed Usman Khan.
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`C. “Invalid Number” means any caller ID number that is invalid under the North American
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`Numbering Plan (“NANP”), including, for example, any number that does not contain the
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`requisite number of digits.
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`D. “National Do Not Call Registry” means the National Do Not Call Registry, which is the
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`“do-not-call” registry maintained by the Commission pursuant to 16 C.F.R.
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`§ 310.4(b)(1)(iii)(B).
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`E. “Person” means any individual, group, unincorporated association, limited or
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`general partnership, corporation, or other business entity.
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`F. “Seller” means any person who, in connection with a Telemarketing transaction,
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`provides, offers to provide, or arranges for others to provide goods or services to
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`the customer in exchange for consideration, whether or not such person is under the
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`jurisdiction of the Commission.
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`G. “Telemarketing” means a plan, program, or campaign which is conducted to induce
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`the purchase of goods or services or a charitable contribution, by use of one or more
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`telephones, and which involves more than one interstate telephone call.
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`H. “Traceback Request” means any request from:
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`1.
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`2.
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`A telecommunications carrier or voice service provider;
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`A consortium that conducts privately-led efforts to trace back the origin of
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`suspected unlawful robocalls, as contemplated under Section 13 of the
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`TRACED Act; or
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`3.
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`Any other industry organization comprised of telecommunications carriers
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`and/or voice service providers that seek to combat and reduce unlawful
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`robocalls to disclose information in order to protect the rights or property
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`of such entity, or to protect users of telecommunications and voice
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`services and others from fraudulent, abusive, or unlawful use of, or
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`subscription to, telecommunications services.
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`I. “Unassigned Number” means any caller ID number for which the administrator
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`of NANP has never opened:
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`1.
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`2.
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`The NPA area code for carrier number assignments; or
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`The NPA-NXX central office code for carrier number assignments.
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`ORDER
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`I.
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`PROHIBITION ON ASSISTING AND FACILITATING
`ABUSIVE TELEMARKETING
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`IT IS ORDERED that Defendants, their officers, agents, employees, and attorneys, and
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`all other persons in active concert or participation with any of them, whether acting directly or
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`indirectly, are permanently restrained and enjoined from Assisting or providing substantial
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`assistance or support to any Person that Defendants know, or should know, is engaged in,
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`causing others to engage in, or assisting others engaging in, any of the following practices:
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`A. Initiating, causing the initiation of, or transmitting Telemarketing calls that: (1)
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`deliver prerecorded messages; or (2) are placed to numbers on the Do Not Call
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`Registry; or
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`B. Initiating, causing the initiation of, or transmitting any telephone call displaying a
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`caller ID number that the calling party does not have legal authority to use.
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`II.
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`PROHIBITION ON VIOLATING THE TELEMARKETING SALES RULE
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`IT IS FURTHER ORDERED that Defendants, their officers, agents, employees, and all
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`other Persons in active concert or participation with any of them, who receive actual notice of
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`this Order, whether acting directly or indirectly, in connection with Telemarketing, are
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`permanently restrained and enjoined from engaging in, causing others to engage in, or Assisting
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`others engaging in violating the Telemarketing Sales Rule, 16 C.F.R. Part 310, a copy of which
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`is attached to this Order as Attachment A.
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`III. BAN ON CERTAIN TELEPHONE CALLS
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`IT IS FURTHER ORDERED that Defendants, whether acting directly or through an
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`intermediary, are permanently restrained and enjoined from providing interconnected VoIP
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`telephony services or provisioning or assigning telephone numbers without having ongoing
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`automated procedures in place to block calls that:
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`A. Display as the caller ID number any Unassigned Number, or any Invalid Number; Or
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`B. Are not authenticated through the Federal Communications Commission’s STIR/SHAKEN
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`Authentication Framework, or a successor authentication framework if subsequently
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`mandated by applicable federal law or regulation.
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`Provided, however, that Section III shall not apply to inbound calls dialed to Defendants’
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`Customers by Persons who are not Defendants’ Customers.
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`IV.
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`SCREENING OF CURRENT AND PROSPECTIVE CUSTOMERS
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`IT IS FURTHER ORDERED that Defendants, their officers, agents, employees, and all
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`other Persons in active concert or participation with any of them, who receive actual notice of
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`this Order, whether acting directly or indirectly, are permanently restrained and enjoined from
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`providing VoIP telephony services or telephone numbers to any new or prospective customer,
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`without first engaging in a reasonable screening of that customer. For new or prospective
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`customers, such reasonable screening must occur and be completed before beginning to provide
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`services to the new customer. For existing customers, such reasonable screening must occur and
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`be completed within 60 days of the entry of this Order. For all customers, such reasonable
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`screening must recur annually. Such reasonable screening must include, but not be limited to:
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`A. Obtaining from each prospective or current customer (including the principal(s) and
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`controlling Person(s) with a majority interest in the entity, and any alter egos, corporate
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`DBA names, trade name, fictitious name or aliases under which such Person(s) conduct
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`or have conducted the business) the following information:
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`1.
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`A description of the nature of the prospective customer’s business,
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`including describing the nature of the goods and services sold and
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`methods of sale. For prospective customers who describe their business as
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`involving Telemarketing or telephone calls to solicit the purchase of goods
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`or services or charitable contributions, confirmation that the prospective
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`customer will use software or other means to filter out numbers on the Do
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`Not Call Registry;
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`2.
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`The name of the principal(s) and controlling Person(s) of the entity, and
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`Person(s) with a majority ownership interest in the entity;
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`3.
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`The name of the entity’s employee responsible for compliance with the
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`Telemarketing Sales Rule and other state and federal laws governing
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`Telemarketing and automated dialing;
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`4.
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`A list of all business and trade names, fictitious names, DBAs, and
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`Internet websites under or through which the customer has transacted
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`business;
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`5.
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`Each physical address at which the prospective customer has conducted
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`business or will conduct the business(es) identified pursuant to subsection
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`(1) of this Section IV.A;
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`6.
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`The billing address and email address associated with the customer’s
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`means and source of payment for Defendants’ services, as well as the
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`name of the Person or entity paying for Defendants’ services;
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`7.
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`For U.S.-domiciled companies, the customer’s federal taxpayer
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`8.
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`identification number;
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`The customer’s state or country of incorporation;
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`If the customer engages in Telemarketing, a list of all caller ID numbers
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`and callback numbers the customer will use, substantiated by proof that
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`the customer has authorization to use each such phone number; and
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`10. Whether the prospective customer (including the principal(s), controlling
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`Person(s) of the entity, and any Person(s) with a majority ownership
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`interest in the entity) has ever been the subject of a lawsuit alleging claims
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`under the TSR, the Telephone Consumer Protection Act of 1991, or any
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`other lawsuit regarding illegal robocalling, illegal automated dialing, calls
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`to the federal or any state Do Not Call registry, or spoofed caller IDs.
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`B. Reviewing whether Defendants have received subpoenas, civil investigative demands, or
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`other complaints about the customer or its principal(s), and any alter egos, corporate
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`DBA names, trade name, fictitious name or aliases under which such customer or
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`Person(s) conduct or have conducted business; and
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`C. Taking reasonable steps to review and assess the accuracy of the information provided
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`pursuant to Section IV.A of this Order, including but not limited to: (1) reviewing the
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`websites used by the customer; (2) searching the FTC’s website to determine if the
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`customer or its control Persons have been the subject of FTC enforcement action; (3)
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`reviewing all formal written inquiries, subpoenas, civil investigative demands,
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`Traceback Requests, and complaints about the customer or calls dialed, originated,
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`routed, or transmitted by the customer, sent to or shared with Defendants to (a)
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`determine whether the call was spoofed, (b) review and listen to prerecorded messages
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`that are identified in or are the subject of such requests, (c) determine whether copies
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`of such prerecorded messages are found in the request itself or in public databases that
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`compile recordings of such messages, and (d) determine if the customer is sending,
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`routing, transmitting, dialing, originating, or terminating calls that deliver a message
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`that misrepresents that the call is from a government agency or law enforcement; and
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`(4) performing internet searches about the customer and its control Persons.
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`CLIENT REVIEW AND TERMINATION
`V.
`IT IS FURTHER ORDERED that:
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`A. Defendants must immediately terminate, or refrain from entering into, any business
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`relationship with a customer if a review under Section IV reveals that the customer:
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`1.
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`Engages in Telemarketing without a Subscription Account Number for
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`accessing the DNC Registry or otherwise checking numbers against the
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`DNC Registry;
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`2.
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`Is offering VoIP telephony services, the provisioning and/or assignment of
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`telephone numbers, or any other telecommunications or information
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`services, without a current, valid Universal Service Fund registration
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`3.
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`4.
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`5.
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`6.
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`Number;
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`States it does not have a taxpayer identification number if it is a U.S.-
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`domiciled company;
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`Has provided false, inaccurate, or misleading information in response to
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`Defendants’ screening process pursuant to Section IV and declined to
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`correct that information upon request;
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`Refuses to provide any of the information described in Section IV;
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`Is a customer that has been the subject of, or calls dialed, originated,
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`transmitted, or routed by the customer have been the subject of, a total of
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`three (3) or more federal or state government agency subpoenas or civil
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`investigative demands to Defendants or otherwise shared with Defendants;
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`or
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`7.
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`Is a customer that has been the subject of, or calls dialed, originated,
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`transmitted, or routed by the customer have been the subject of a total of
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`three (3) or more Traceback Requests or upstream or downstream carrier
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`complaints sent to or shared with Defendants during any sixty (60) day
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`period.
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`B. Defendants must also immediately terminate, or refrain from entering into, any
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`business relationship with a customer if Defendants become aware of or obtain any
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`information suggesting that the customer is engaging in conduct prohibited in Sections
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`I, II, or III of this Order.
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 10 of 19 PageID 42
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`VI. MONETARY JUDGMENT FOR CIVIL PENALTY AND PARTIAL SUSPENSION
`IT IS FURTHER ORDERED that:
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`A. Judgment in the amount of Three Million Two Hundred Fifty-Six Thousand One
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`Hundred Ninety Dollars ($3,256,190) is entered in favor of Plaintiff against Individual
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`Defendant and Corporate Defendants, jointly and severally, as a civil penalty. The
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`judgment is suspended subject to the Subsections below.
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`B. The Commission’s and Plaintiff’s agreement to the suspension of the judgment is
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`expressly premised upon the truthfulness, accuracy, and completeness of Defendants’
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`sworn financial statements and related documents (collectively, “financial
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`representations”) submitted to the Commission, namely:
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`1.
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`the Financial Statement of VoIP Terminator, Inc. signed by Muhammed Usman
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`Khan on February 8, 2022;
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`2.
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`the Financial Statement of BLMarketing, Inc. signed by Muhammed Usman Khan
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`on February 8, 2022; and
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`3.
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`the Financial Statement of Muhammed Usman Khan signed by Muhammed
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`Usman Khan on February 8, 2022.
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`C. The suspension of the judgment will be lifted as to any Defendant if, upon motion by the
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`Commission or Plaintiff, the Court finds that Defendant failed to disclose any material
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`asset, materially misstated the value of any asset, or made any other material
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`misstatement or omission in the financial representations identified above.
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`D. If the suspension of the judgment is lifted, the judgment becomes immediately due as to
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`that Defendant in the amount specified in Subsection A. above (which the parties
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`stipulate only for purposes of this Section represents the amount of the civil penalty for
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`the violations alleged in the Complaint), less any payment previously made pursuant to
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`this Section, plus interest computed from the date of entry of this Order.
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`E. Defendants relinquish dominion and all legal and equitable right, title, and interest in
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`all assets transferred pursuant to this Order and may not seek the return of any assets.
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`F. The facts alleged in the Complaint will be taken as true, without further proof, in
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`any subsequent civil litigation by or on behalf of the Commission, including in a
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`proceeding to enforce its rights to any payment or monetary judgment pursuant to
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`this Order.
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`G. The facts alleged in the Complaint establish all elements necessary to sustain an action
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`by the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C.
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`§ 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes.
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`H. Defendants agree that the judgment represents a civil penalty owed to the government of
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`the United States, is not compensation for actual pecuniary loss, and therefore it is not
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`subject to discharge under the Bankruptcy Code pursuant to 11 U.S.C. § 523(a)(7).
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`VII. COOPERATION
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`IT IS FURTHER ORDERED that Defendants must fully cooperate with representatives
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`of Plaintiff and the Commission in this case and in any investigation related to or associated
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`with the transactions or the occurrences that are the subject of the Complaint. Defendants must
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`provide truthful and complete information, evidence, and testimony. Defendants must appear,
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`and must cause their officers, employees, representatives, or agents to appear, for interviews,
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`discovery, hearings, trials, and any other proceedings that a Plaintiff or Commission
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`representative may reasonably request upon 5 days written notice, or other reasonable notice, at
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`such places and times as a Plaintiff or Commission representative may designate, without the
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`service of a subpoena.
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`Further, to assist the Commission with any investigation related to or associated with the
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`transactions or the occurrences that are the subject of the Complaint, and with monitoring
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`Defendants’ compliance with this order, Defendants consent, for purposes of the Electronic
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`Communications Privacy Act, to the disclosure, by electronic communications service providers
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`and remote computing service providers, of the contents of their auto-dialed, telemarketing, or
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`pre-recorded telephone communications and records or other information pertaining to their
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`autodialed, telemarketing, or pre-recorded telephone communications. Defendants further agree
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`to execute, within five days of a request from the Commission, any forms or other documents
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`evidencing their consent that may be required by such electronic communications service
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`providers or remote computing service providers.
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`VIII. ORDER ACKNOWLEDGMENTS
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`IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of this
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`Order:
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`A. Each Defendant, within seven (7) days of entry of this Order, must submit to the
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`Commission an acknowledgment of receipt of this Order sworn under penalty of
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`perjury.
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`B. For 5 years after entry of this Order, Individual Defendant, for any business that he,
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`individually or collectively with any other Defendant, is the majority owner or controls
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`directly or indirectly, and each Corporate Defendant, must deliver a copy of this Order
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`to: (1) all principals, officers, directors, and LLC managers and members; (2) all
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`employees having managerial responsibilities for conduct related to the subject matter
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`of the Order and all agents and representatives who participate in conduct related to the
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`subject matter of the Order and (3) any business entity resulting from any change in
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`structure as set forth in the Section titled Compliance Reporting. Delivery must occur
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`within seven (7) days of entry of this Order for current personnel. For all others,
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`delivery must occur before they assume their responsibilities.
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`C. From each individual or entity to which a Defendant delivered a copy of this Order,
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`that Defendant must obtain, within 30 days, a signed and dated acknowledgment of
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`receipt of this Order.
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`IX. COMPLIANCE REPORTING
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`IT IS FURTHER ORDERED that Defendants make timely submissions to the Commission:
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`A. One year after entry of this Order, each Defendant must submit a compliance
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`report, sworn under penalty of perjury:
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`1.
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`Each Defendant must: (a) identify the primary physical, postal, and email address
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`and telephone number, as designated points of contact, which representatives of
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`the Commission and Plaintiff may use to communicate with Defendant; (b)
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`identify all of that Defendant’s businesses by all of their names, telephone
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`numbers, and physical, postal, email, and Internet addresses; (c) describe the
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`activities of each business, including the goods and services offered, the means of
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`advertising, marketing, and sales, and the involvement of any other Defendant
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`(which Individual Defendant must describe if he knows or should know due to
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`his own involvement); (d) describe in detail whether and how that Defendant is
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`in compliance with each Section of this Order; and (e) provide a copy of each
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`Order Acknowledgment obtained pursuant to this Order, unless previously
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`submitted to the Commission.
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`2.
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`Additionally, each Defendant must: (a) identify all telephone numbers and all
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`physical, postal, email and Internet addresses, including all residences; (b)
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`identify all business activities, including any business for which such
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`Defendant performs services whether as an employee or otherwise and any
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`entity in which such Defendant has any ownership interest; and (c) describe in
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`detail such Defendant’s involvement in each such business, including title, role,
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`responsibilities, participation, authority, control, and any ownership.
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`B. For 10 years after entry of this Order, each Defendant must submit a compliance
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`notice, sworn under penalty of perjury, within 14 days of any change in the following:
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`1.
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`Each Defendant must report any change in: (a) any designated point of contact; or
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`(b) the structure of and Corporate Defendant or any entity that Defendant has any
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`ownership interest in or controls directly or indirectly that may affect compliance
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`obligations arising under this Order, including: creation, merger, sale, or dissolution
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`of the entity or any subsidiary, parent, or affiliate that engages in any acts or
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`practices subject to this Order.
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`2.
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`Additionally, Individual Defendant must report any change in: (a) name,
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`including aliases or fictitious name, or residence address; or (b) title or role in
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`any business activity, including any business for which he performs services
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`whether as an employee or otherwise and any entity in which he has any
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`ownership interest, and identify the name, physical address, and any Internet
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`address of the business or entity.
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`C. Each Defendant must submit to the Commission notice of the filing of any bankruptcy
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`petition, insolvency proceeding, or similar proceeding by or against it within 14 days of
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`its filing.
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`D. Any submission to the Commission required by this Order to be sworn under penalty
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`of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by
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`concluding: “I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct. Executed on:
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`” and supplying the
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`date, signatory’s full name, title (if applicable), and signature.
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`E. Unless otherwise directed by a Commission representative in writing, all submissions to
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`the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by
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`overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement,
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`Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue
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`NW, Washington, DC 20580. The subject line must begin: FTC v. VoIP Terminator,
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`Inc.
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`X.
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`RECORDKEEPING
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`IT IS FURTHER ORDERED that Defendants must create certain records for 10 years
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`after entry of the Order, and retain each such record for five (5) years. Specifically, Defendants
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`for any business that they, individually or collectively with any other Defendants, is a majority
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`owner or controls directly or indirectly, must create and retain the following records:
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`A. accounting records showing the revenues from all goods or services sold;
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`B. personnel records showing, for each person providing services, whether as an employee
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`or otherwise, that person’s: name; addresses; telephone numbers; job title or position;
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`dates of service; and (if applicable) the reason for termination;
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`C. records of all consumer complaints and refund requests, whether received directly
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`or indirectly, such as through a third party, and any response;
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`D. all records necessary to demonstrate full compliance with each provision of this
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`Order, including, among other documents and information:
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`1.
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`2.
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`All submissions to Plaintiff or the Commission;
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`Records of all Telephone Calls dialed by Defendants or dialed on behalf of
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`Defendants or their businesses by their vendors, contractors, or
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 16 of 19 PageID 48
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`Representatives, including for each call: (a) the number called; (b) the
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`caller ID number displayed; (c) the time and date of the call; (d) the
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`duration of the call; and (e) any telephone number or IP address to which
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`the call was forwarded or transferred; and
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`E. a copy of each unique advertisement or other marketing material.
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`XI. COMPLIANCE MONITORING
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`IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants’
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`compliance with this Order, including the financial representations upon which part of the
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`judgment was suspended, and any failure to transfer any assets as required by this Order:
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`A. Within 14 days of receipt of a written request from a representative of the Commission
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`or Plaintiff, Defendants must: submit additional compliance reports or other requested
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`information, which must be sworn under penalty of perjury; appear for depositions; and
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`produce documents for inspection and copying. The Commission and Plaintiff are also
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`authorized to obtain discovery, without further leave of court, using any of the
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`procedures prescribed by Federal Rules of Civil Procedure 29, 30 (including telephonic
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`depositions), 31, 33, 34, 36, 45, and 69.
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`B. For matters concerning this Order, the Commission and Plaintiff are authorized to
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`communicate directly with each Defendant. Defendants must permit representatives of
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`the Commission and Plaintiff to interview any employee or other person affiliated with
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`him who has agreed to such an interview. The person interviewed may have counsel
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`present.
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`C. The Commission and Plaintiff may use all other lawful means, including posing,
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`through its representatives as consumers, suppliers, or other individuals or entities, to
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`Defendants or any individual or entity affiliated with Defendants, without the necessity
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 17 of 19 PageID 49
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`of identification or prior notice. Nothing in this Order limits the Commission’s lawful
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`use of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§
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`49, 57b-1.
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`XII. RETENTION OF JURISDICTION
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`IT IS FURTHER ORDERED THAT, this court retains jurisdiction of this matter for
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`
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`purposes of construction, modification, and enforcement of this Order.
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`SO ORDERED this
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`day of , 2022.
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`UNITED STATES DISTRICT JUDGE
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`17
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 18 of 19 PageID 50
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`
`SO STIPULATED AND AGREED:
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`FOR PLAINTIFF:
`
`THE UNITED STATES OF AMERICA
`
`BRIAN M. BOYNTON
`Principal Deputy Assistant Attorney General
`Civil Division
`
`ARUN G. RAO
`Deputy Assistant Attorney General
`
`ROGER B. HANDBERG
`United States Attorney
`Middle District of Florida
`
`LACY R. HARWELL, JR.
`Chief, Civil Division
`Florida Bar No. 714623
`400 N. Tampa Street, Suite 3200
`Telephone: (813) 274-6000
`Facsimile: (813) 274-6200
`Email: Randy.Harwell@usdoj.gov
`
`GUSTAV W. EYLER
`Director
`Consumer Protection Branch
`
`LISA K. HSIAO
`Assistant Director
`
`
`s/ Ellen Bowden McIntyre
`ELLEN BOWDEN MCINTYRE
`ZACHARY A. DIETERT
`Trial Attorneys Appearing Pursuant to 28 U.S.C. § 517
`Consumer Protection Branch
`U.S. Department of Justice
`P.O. Box 386 Washington, DC 20044
`Telephone: (202) 451-7731
`Email: ellen.bowden.mcintyre@usdoj.gov
`Telephone: (202) 616-9027
`Email: zachary.a.dietert@usdoj.gov
`
` Date: 4/25/22
`
`
`
`
`
`
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`18
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`Case 6:22-cv-00798-PGB-GJK Document 2-1 Filed 04/26/22 Page 19 of 19 PageID 51
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`FEDERAL TRADE COMMISSION
`
` Date: 4/22/22
`
`
`
`
`
`JODY GOODMAN
`RYAN MCAULIFFE
`Federal Trade Commission
`
` Bureau of Consumer Protection/Division of Marketing Practices, CC-8533
`Org 1144, Mail Stop CC-5201
`600 Pennsylvania Ave., NW
`Washington, DC 20580
`(202) 326-3096; jgoodman1@ftc.gov
`(202) 326-3044; rmcauliffe@ftc.gov
`
`FOR DEFENDANTS:
`
`
`
`Muhammed Usman Khan
`
`Individually and on behalf of VoIP Terminator, Inc.
`and BLMarketing, Inc.
`
`
`
`
`
`Date:
`
`
`
`
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`2/18/2022
`
`
`
`19
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`