Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.1 Filed 09/08/26 Page 1 of 89

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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

FEDERAL TRADE COMMISSION,

Case No. ____________

Plaintiff,

5967 VENTURES, LLC, a limited

liability company, d/b/a Humboldt

Merchant Services,

COMPLAINT FOR

PERMANENT

INJUNCTION AND OTHER

RELIEF

Defendant.

Plaintiff, the Federal Trade Commission (“FTC”), for its

Complaint alleges:

The FTC brings this action for Defendant’s violations of

Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). For these violations, the

FTC seeks relief, including a permanent injunction and other relief,

pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b).

SUMMARY OF THE CASE

Defendant 5967 Ventures, LLC, which does business as

Humboldt Merchant Services (“Humboldt”), is in the payment

processing business and for years has processed payments for more

than a thousand merchants it knew, or consciously avoided knowing,

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were shell entities that served as fronts or pass-throughs for third

parties engaged in unauthorized billing scams. In December 2023, at

the request of the United States Department of Justice, a federal court

shut down an organization that had set up many of these shell entities

on behalf of fraudulent companies that purportedly sold nutraceutical

supplements and other products online. See United States v. CB Surety

LLC, No. 2:23-cv-2812 (E.D. Cal.). These fraudulent companies used

sham merchant accounts set up under the names of the shell entities to

place unauthorized charges on consumers’ credit and debit cards. From

2021 through 2023 alone, Humboldt processed over $100 million

through these sham merchant accounts.

Humboldt has sponsorship agreements with banks to open

accounts associated with bank identification numbers (“BINs”) licensed

by the card networks for businesses to process consumers’ credit and

debit card payments. When opening and maintaining these accounts,

known as “merchant accounts,” Humboldt is required to follow the rules

established and enforced by credit card networks, such as Mastercard

and Visa.

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Humboldt markets itself as specializing in “tough to place”

or “high risk” merchants—businesses that are usually rejected by other

processors because of disqualifying credit, reputational, or regulatory

risk. In 2017 and 2018, Humboldt’s business consisted primarily of

merchants selling nutraceutical supplements and assorted gadgets on

the Internet, often through “free”-trial offers. Many consumers who

provided their credit card information for these offers were enrolled

automatically into subscription plans that continued to bill them for

unwanted products after the trial period ended. Humboldt referred to

these types of accounts synonymously as “nutra” or “Performance

Marketing,” and they were Humboldt’s most profitable accounts. Driven

by the Performance Marketing business, Humboldt’s annual profits

grew from approximately $7.5 million in 2014 to over $80 million in

2017.

Humboldt was warned that its Performance Marketing

business was permeated with fraud. During reviews from 2017 to 2019,

Mastercard alerted Humboldt that thousands of its accounts appeared

to be involved in “load balancing” and “card sharing” schemes, where

fraudsters place charges on consumers’ credit cards and route the

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transactions across multiple merchant accounts to hide their activities

from the scrutiny of banks and card networks. In 2019, a senior

Humboldt underwriter warned Humboldt’s management that Humboldt

had for years opened shell accounts with straw signers that were being

used for “obvious load balancing” and “obvious card sharing” schemes.

Most of these shell accounts came from merchants referred by just a few

external sales agents, one of whom was a close personal friend of

Humboldt’s President, who personally profited from the agent’s

referrals through a secret arrangement where they split the residuals

that the agent received from Humboldt.

Humboldt ultimately disregarded the senior underwriter’s

warnings, but the scrutiny from Mastercard forced Humboldt to close

thousands of accounts and jeopardized its profitable Performance

Marketing business. Despite known and apparent fraud widespread

among its Performance Marketing accounts, however, Humboldt

continued to pursue the business from the same sales agents. As part of

their efforts to increase revenues from Humboldt’s Performance

Marketing business, Humboldt at the end of 2020 placed Performance

Marketing accounts on a lower-risk BIN licensed and used by an

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affiliated entity, NorthAB, LLC (“NAB”), instead of Humboldt’s BIN,

where they previously had been placed. Humboldt did this because it

believed the accounts’ approval ratios—the percentage of attempted

transactions that get approved and settled by cardholders’ banks

instead of denied—would increase if the accounts were on the lower-risk

BIN, thereby increasing the volume of transactions processed through

the accounts.

By 2021, the Humboldt Performance Marketing accounts

placed on NAB’s BIN collectively had “chargebacks”—transactions that

are reversed and refunded after cardholders dispute them, for example

by reporting charges as unauthorized or fraudulent—at rates of over 7%

of all sales, which was far higher than the thresholds used by the card

brands’ chargeback and fraud monitoring programs (i.e., 0.9% and 1.5%)

and almost 100 times higher than the NAB BIN’s overall chargeback

rate.

Nevertheless, until around the end of 2023, after learning of

the FTC’s investigation, Humboldt continuously opened thousands of

Performance Marketing accounts primarily from two sales agents, even

though their accounts had red flags of being shells and typically

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incurred chargebacks at rates that were almost ten times higher than

what Mastercard and Visa viewed as excessive. While these accounts

often were closed within six months, the continuous supply of shell

accounts was highly profitable for Humboldt, and it enabled the online

scams that used them as fronts to avoid detection and continue harming

consumers.

JURISDICTION AND VENUE

This Court has subject matter jurisdiction pursuant to 28

U.S.C. §§ 1331, 1337(a), and 1345.

10.

Venue is proper in this District under 28 U.S.C.

§§ 1391(b)(1), (b)(2), (c)(2), and (d), and 15 U.S.C. § 53(b).

PLAINTIFF

11.

The FTC is an agency of the United States Government

created by the FTC Act, which authorizes the FTC to commence this

district court civil action by its own attorneys. 15 U.S.C. §§ 41–58. The

FTC enforces Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which

prohibits unfair or deceptive acts or practices in or affecting commerce.

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DEFENDANT

12.

Defendant Humboldt is a Delaware limited liability company

which has an office at 1600 North Desert Drive, Suite 101, Tempe,

Arizona 85281. At times relevant to this Complaint, Humboldt’s

President worked out of the office building used by its corporate

affiliate, NAB (formerly known as North American Bancard, LLC ), at

250 Stephenson Highway, Troy, Michigan 48083. Humboldt transacts

or has transacted business in this District and throughout the United

States.

COMMERCE

13.

At all times relevant to this Complaint, Defendant has

maintained a substantial course of trade in or affecting commerce, as

“commerce” is defined in Section 4 of the FTC Act, 15 U.S.C. § 44.

DEFENDANT’S BUSINESS ACTIVITIES

Humboldt’s Role in the Credit Card System

14.

Humboldt offers and provides credit and debit card

processing services to companies, including by helping them open

merchant accounts at financial institutions (known as sponsor or

acquiring banks, or “Acquirers”) that are members of credit card

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networks (e.g., Visa and Mastercard). Without access to a merchant

account, businesses cannot accept credit or debit card payments.

15.

To participate in the credit card system, consumers obtain a

card-network-sponsored credit card from an “issuing bank” or “Issuer.”

16.

Card networks impose operating rules and restrictions on

sponsor banks and their service providers to deter fraud, increase

transparency, and reduce risk to the payment system. In turn, sponsor

banks enter into contracts with service providers, including ISOs, that

require compliance with the banks’ policies and procedures for

conducting due diligence and underwriting on prospective merchants

and monitoring merchants’ transaction activity to manage risk.

17.

Humboldt is an ISO that is registered with the card

networks. Humboldt solicits merchants and works with them to open

merchant accounts that are held at the acquiring banks with which

Humboldt has sponsor relationships.

18.

In addition to soliciting and communicating with merchants,

Humboldt is also responsible for underwriting, risk management and

compliance for the merchant accounts it opens. Through relationships

with its sponsor banks, Humboldt also has authority to clear and settle

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merchants’ card transactions. In doing so, Humboldt bears the primary

risk of the business.

19.

At all times material to this Complaint, Humboldt operated

as a registered ISO of the acquiring bank BMO Harris Bank, N.A.

(“Acquiring Bank”), which is a member of the card networks.

20.

The diagram in Figure 1 generally illustrates relationships

between consumers, merchants, issuing banks, and acquiring banks in

the credit card system, as well as Humboldt’s role as an ISO that

solicits merchants and underwrites, opens, and performs risk functions

for accounts that are held at an acquiring bank:

Figure 1:

Payment Processing Ecosystem

Credit Card Number

Submitted for Payment

ISO Solicits Merchant

& Performs

Underwriting/Risk on

Account

Merchant

Consumer/Cardholder

Account

Relationship

Account

Relationship

Card Network

(e.g. Visa,

Mastercard)

Issuing Bank

Card Network:

Communicates Payment Data

Sets/Enforces Rules of Conduct

Monitors Activity

Acquiring

Bank

Transaction Authorization

(Merchant & Issuing Bank)

Sales Draft for Settlement

(Issuer & Acquirer)

ISO

(Humboldt)

Acquirer Authorizes

ISO to Solicit

Merchants/Open

Accounts

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21.

Since December 2009, Humboldt has had a direct

sponsorship agreement with the Acquiring Bank. Under this

sponsorship agreement, the Acquiring Bank provides Humboldt BINs

licensed by Visa and Mastercard to clear and settle transactions for

merchant accounts opened by Humboldt. Humboldt refers to these BINs

collectively as the “Humboldt BIN.”

22.

Humboldt is responsible under its sponsorship agreement

with the Acquiring Bank to provide “[m]erchant underwriting” and

“risk/fraud monitoring” in accordance with the card networks’ rules and

the credit policy in the agreement. The credit policy allows Humboldt to

open accounts on the Humboldt BIN for certain “special handling”

accounts that include negative-option billing merchants using trial

offers.

23.

In October 2020, Humboldt also began onboarding its

merchants through its corporate affiliate NAB’s separate sponsorship

relationship with the Acquiring Bank. This separate sponsorship

agreement’s credit policy restricts certain high-risk merchant types that

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are allowed on the Humboldt BIN, including negative-option billing

merchants using trial offers.

(1)

Chargebacks and Fraud Monitoring Programs

24.

A major indicator of fraudulent or deceptive conduct on a

merchant account is a high chargeback rate. Chargebacks occur when

cardholders contact their issuing bank to dispute a charge that

appeared on their account statement. If the consumer’s dispute is

upheld by his or her issuing bank, the amount is charged back to the

merchant’s account and the consumer does not pay for the disputed

charge. If the chargeback is upheld and the merchant cannot or does not

cover it, the acquiring bank and ISO must cover it.

25.

To manage risk and minimize fraud, the card networks have

developed formal programs to monitor merchant accounts that have

excessive chargebacks. Merchant accounts that exceed certain

chargeback thresholds are subjected to heightened monitoring, and the

card networks may impose fines or even terminate accounts if their

chargeback metrics do not improve.

26.

For example, merchants have been subject to the Visa

Dispute Monitoring Program when they have had at least 100 disputed

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transactions (chargebacks) in a single month and their ratio of disputed

transactions to total transactions has been 0.9% or higher. Under

Mastercard’s Excessive Chargeback Program, a merchant is designated

an Excessive Chargeback Merchant when it incurs 100 or more

chargebacks in a single month and its chargeback-to-transaction ratio

reaches 1.5%.

27.

Fraudulent merchants with excessive chargebacks often

attempt to evade detection by these monitoring programs through a

practice called load balancing, in which they distribute sales across

multiple merchant accounts. This lowers the risk that any single

account will exceed the threshold of 100 chargebacks per month that is

a trigger for being placed in the monitoring programs. Fraudulent

merchants often will set up shell corporations or limited liability

companies to act as fronts to obtain new merchant accounts that can be

used to implement load balancing tactics and continue processing sales.

28.

Card networks prohibit the practice of processing credit card

transactions through another company’s merchant account. This

practice is known as “credit card laundering” or “transaction

laundering.” Many fraudulent merchants engage in credit card

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laundering to conceal their real identities from consumers, banks, card

networks, or law enforcement. They may do this by creating shell

companies to act as fronts, applying for merchant accounts in the names

of these shell companies, and then laundering their own transactions

through these shell companies’ merchant accounts. They may also

launder their transactions through an existing merchant account that

purports to be engaged in a different line of business. Laundering helps

fraudulent merchants circumvent underwriting or risk monitoring

criteria established by Acquirers or ISOs—criteria they may be unable

to satisfy if they were to disclose their real identity, for example if they

previously had been flagged for excessive chargebacks or fraud.

29.

When a merchant account is terminated by an Acquirer or

ISO for an adverse reason or non-compliant conduct, the merchant is

added to a database known as the MATCH list (which stands for

Mastercard Alert to Control High-Risk merchants). Reasons for adding

a merchant to the MATCH list include excessive chargebacks, excessive

fraud, laundering activity, bankruptcy, or violations of card network

standards.

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30.

Acquirers and ISOs typically are required to check whether

a prospective merchant is on the MATCH list when performing due

diligence. Merchants on the MATCH list often have difficulty obtaining

or cannot obtain merchant accounts, as they are deemed to be too high

risk by many Acquirers and ISOs. If an Acquirer or ISO is willing to

open an account for a merchant on the MATCH list, they often require

that the merchant agree to more onerous terms, such as higher fees and

heightened monitoring.

(2)

Restrictions on High-Risk and Performance

Marketing Merchants

31.

Card networks and Acquirers impose additional restrictions

on certain categories of merchants deemed to present a heightened risk

to the payment system. The highest risk merchants, such as those

engaged in illegal activity, are prohibited from processing payments

altogether. Other high-risk merchants are allowed to process payments

but are subject to heightened underwriting and monitoring

requirements.

32.

Merchants are often classified as high risk based on the

nature of the products or services they sell or the manner in which they

sell them. In general, merchants with physical retail locations that

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accept payments from customers in person (“card present” transactions)

are considered much lower risk than merchants that do business over

the phone or on the Internet (“card-not-present” or “card absent”

transactions). One reason for this is that card-not-present transactions

have a higher risk of fraud.

33.

The card networks require the assignment of four-digit

merchant category codes (“MCCs”) to classify the type of business in

which a merchant is engaged. A merchant is assigned an MCC when it

first obtains a merchant account. Card networks’ rules require that

merchants be assigned correct MCCs by Acquirers and their ISOs.

Proper MCC classification helps ensure that merchant accounts are

subjected to the appropriate level of risk monitoring.

34.

In October 2018, Mastercard published a bulletin

announcing it was revising its rules for high-risk negative option billing

merchants. Humboldt’s officers received copies of the bulletin.

35.

Mastercard’s revised rules, which became effective April

2019 (“Mastercard’s 5968 Rules”), applied to “any merchant offering a

free or low-cost trial period of a physical good (e.g. cosmetics, dietary

supplement).” Mastercard’s 5968 Rules require Acquirers to use MCC

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5968 for these high-risk negative option billing merchants and their

transactions. Mastercard’s 5968 Rules also require that: Acquirers

Program, thereby requiring Acquirers to verify merchants’ compliance

with Mastercard Standards; and MCC 5968 merchants obtain every

cardholder’s explicit consent to any further payments after a trial

period ends.

36.

A December 2018 report published by the Better Business

Bureau (“BBB”) described the growing problem of online “free trial offer

frauds” that Mastercard’s rules were designed to address. The BBB

report discussed a 2010 FTC case against a company that sold weight

loss pills and colon cleansing products to illustrate how these

fraudulent free trial offers work. The report explained that “customers

were asked to provide their credit or debit card numbers to pay $4.95,

or sometimes $1.95, for the ‘free’ trial’” and “[t]hose who did were

shipped a one-month supply of the pills and were often charged $59.95

right away” and then charged for these pills every month. The terms of

the trial offers “were only disclosed in very fine print if a customer

scrolled down to the bottom of order page where customers entered

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their credit card number.” To avoid being charged, consumers had to

receive the pills and return them within fourteen (14) days and provide

a Return Merchant Authorization Number from the merchant, which

was difficult to obtain.

37.

The BBB report also listed the following common

components of these scams: the products offered “mostly consisted of

diet pills, teeth whiteners, wrinkle and anti-aging creams and, most

recently, cannabis extract products”; “[i]n order to get victims to decide

to try a ‘free trial,’ these frauds often make extreme claims of the

supposed merits of their products” along with phony testimonials from

“supposedly happy customers” or “endorsements by celebrities or other

trust figures”; and “[m]any fake free trial offers use affiliate networks to

advertise their products” and “drive traffic to their website.”

Humboldt’s Pursuit and Growth of the “Performance

Marketing” Business

38.

Humboldt markets itself as a “merchant acquiring” business

focused on “nontraditional” or “specialty” verticals. These verticals

generally consist of businesses that are considered “high risk” and are

subject to heightened regulatory scrutiny or pose a heightened risk of

fraud and chargebacks.

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39.

Since at least 2015, Humboldt’s portfolio has been

concentrated in two verticals. The first is “adult” or “dating,” which

includes, for example, pornography and “cam” websites. The second is

“Performance Marketing.”

40.

Humboldt’s Performance Marketing business has consisted

of e-commerce merchants that generally sell products such as

nutraceutical supplements for weight loss, anti-aging, or sexual

stimulation or enhancement, and assorted gadgets, through negative

option, trial, or subscription billing. Initially, Humboldt’s Performance

Marketing merchants all were classified under MCC 5968.

41.

Humboldt refers to its Performance Marketing business by

other terms, including “nutra” (shorthand for nutraceuticals) and “ERA”

merchants (a reference to Humboldt’s enhanced risk addendum, a form

that Performance Marketing merchants must submit when applying).

The ERA addendum contains additional contractual terms and fees that

Humboldt imposes on Performance Marketing merchants. A version of

the “Enhanced Risk Addendum” used by Humboldt from at least 2016

to 2021 stated: “This addendum . . . is hereby entered into because . . .

merchant may operate a so-called ‘negative option’ program.”

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Humboldt’s internal risk-team meeting notes explain that “The [ERA]

addendum requires the merchant to comply with additional HBMS

policies that mitigate losses.”

42.

Humboldt’s Performance Marketing accounts have

chargeback rates that are consistently higher than its other major highrisk verticals (including adult). In the aggregate, they far exceed the

threshold rates for individual accounts (0.9% and 1.5%) used by the

card networks’ monitoring programs.

43.

In 2015, an outside consulting firm for the Acquiring Bank

conducted a risk review of Humboldt and reported that during the first

quarter of 2015, Humboldt’s Performance Marketing business

represented only 25% of Humboldt’s total processing volume and yet

accounted for 66% of the chargeback volume in Humboldt’s entire

merchant portfolio. Humboldt’s Performance Marketing portfolio had an

overall chargeback rate of 4.6%. And, the report found, “[c]hargebacks

have increased markedly since the last review in 2013 due to Humboldt

materially growing the 5968 continuity merchant base.”

44.

Humboldt insulated itself from financial losses from these

high chargeback levels by imposing “reserves” on all Performance

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Marketing accounts. Humboldt creates a reserve by setting aside a

percentage of the sales proceeds processed by a merchant account.

These funds are not immediately disbursed to the merchant but instead

are held in a separate bank account for Humboldt and the Acquiring

Bank to use to offset potential losses, such as chargebacks that exceed

an account’s sales or that trail an account’s closure. By setting aside

these reserves, Humboldt protects itself from the risk that it would be

left liable for an amount of chargebacks that, if unpaid by the merchant,

could be larger than the fees Humboldt earned on the account. As a

result of this strategy, Humboldt typically netted money on

Performance Marketing accounts even when they were shut down for

excessive chargebacks and incurred trailing chargeback losses. As

stated in internal notes from a 2022 meeting of Humboldt’s risk team:

“We may go through 100 bad accounts to get 10 good accounts, but we

make money on all those accounts[.]”

45.

Humboldt has sourced most of its Performance Marketing

business through external, non-employee sales agents. To compensate

agents, Humboldt pays them “residuals”: a percentage of Humboldt’s

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net profits from the accounts referred by the agent. Humboldt’s

contracts with agents describe this as a “Revenue Share.”

46.

Humboldt’s sales agents worked with sub-agents (also called

“referral partners”) to solicit Performance Marketing merchants. The

sub-agents referred merchants to the sales agents who, in turn, referred

them to Humboldt. Sales agents paid their sub-agents through

residuals as well, paying the sub-agents a percentage of the residuals

that the sales agents received from Humboldt.

47.

Humboldt’s first and second top sales agents for

Performance Marketing accounts were National Bancard Services, LLC,

which does business as Arc Payments (“Arc”), and Merchant Focus

Processing, Inc. (“Merchant Focus”), respectively. Humboldt paid Arc

and Merchant Focus residuals of up to 60% and 50%, respectively, on

the Performance Marketing accounts they referred. Arc’s owner was a

close personal friend of Humboldt’s President, and they had a secret

financial arrangement where they split the residuals that Arc received

from Humboldt.

48.

Performance Marketing was Humboldt’s most profitable

business vertical, with revenue “margins” (a percentage of Humboldt’s

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revenue from the processing volume) of over 15% on Performance

Marketing accounts, compared to 5% or less on other accounts.

49.

In 2017, Humboldt’s Performance Marketing business grew

to account for more than half of Humboldt’s total processing volume and

approximately 80% of its overall profits. Driven by the Performance

Marketing business, Humboldt’s overall profits grew from

approximately $7.5 million in 2014 to over $80 million in 2017.

Humboldt’s Knowledge of Illegal Conduct in its

Performance Marketing Portfolio

50.

As its Performance Marketing business expanded, Humboldt

was warned by Mastercard and a senior Humboldt underwriter of

systemic fraudulent and illegal conduct among the accounts, including

widespread load balancing and transaction laundering through shell

accounts.

(1)

Mastercard Reviews from 2017 to 2019 Exposed

Extensive Load Balancing and Card Sharing in

Humboldt’s Portfolio

51.

In 2017, Mastercard began to undertake a review of

Humboldt’s portfolio that identified a number of Humboldt merchants

engaged in load balancing. In a report to Humboldt, Mastercard

explained “[t]here were numerous instances observed of load balancing

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among merchants in MCC 5968 Direct Marketing

Continuity/Subscription Merchants.” The report described the practice

of “load balancing” as follows:

[W]here a merchant divides its transaction volume between

multiple merchant accounts or Merchant ID numbers to

keep its total number of transactions below Mastercard

fraud monitoring and other compliance thresholds. In most

of these instances, the use of multiple merchant accounts or

Merchant ID numbers serves no legitimate business purpose

and potentially introduces increased risk to the payments

system. Such actions typically are intended to avoid

detection for excessive fraud, excessive chargebacks, or both.

52.

After further investigation, Mastercard in March 2018

exposed widespread suspected load balancing and card sharing activity

across thousands of Humboldt accounts coded with MCC 5968, which

were Performance Marketing accounts. In a report, Mastercard notified

Humboldt that the merchants “operated a negative option billing

business model around the sale of health and beauty products, which is

often associated with deceptive practices that include load balancing

. . . .”

53.

In June 2018, Humboldt’s President discussed with another

executive the “forced attrition [of accounts] by MasterCard” and the

potential to lessen the immediate financial loss if “we . . . can drag our

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feet on terminating the MC [Mastercard] cross sale merchants . . . .”

(The practice of using the same credit card number to run transactions

across multiple merchant accounts within a short period of time is

sometimes referred to as card sharing, PAN (primary account number)

sharing, or cross selling.)

54.

In October 2018, Humboldt’s President circulated to other

executives Mastercard’s bulletin about rule changes for MCC 5968

merchants (see supra ¶ 34). Mastercard’s bulletin notified processors

that these merchants “often” enrolled consumers into subscription plans

without their knowledge and engaged in efforts to “disguise their

activities” from banks and Mastercard:

Mastercard has found that these high-risk merchants often

engage in various behaviors designed to manipulate the

cardholder into unknowingly signing up for a subscription

service (subsequently making it difficult for the cardholder

to cancel the subscription once enrolled.) In addition, these

merchants often engage in practices designed to hide or

disguise their activities from their acquirer, Mastercard, or

both.

55.

In February 2019, Mastercard notified Humboldt that

another review revealed evidence of further ongoing and extensive load

balancing and card sharing involving more than a thousand accounts.

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56.

In October 2019, Humboldt’s President circulated to other

executives an internal memo on “the closures in the 5968 vertical” and

reported that thousands of Performance Marketing merchants in

Humboldt’s portfolio had been closed as a result of Mastercard’s

reviews. Humboldt’s President explained that the accounts were closed

because they were engaged in PAN sharing, projecting the lost sales

volume in 2019 from having to close the accounts to be over $80 million.

(2)

Humboldt Senior Underwriter Warned of Extensive

Shell Accounts from Preferred Sales Agents

57.

Around the same time as Mastercard’s reviews, a Humboldt

senior underwriter warned Humboldt’s management in 2019 that the

underwriting department for years had been identifying patterns of

accounts being “straws,” accounts being engaged in “obvious load

balancing,” and sales being made through unauthorized and

undisclosed websites.

58.

In an April 2019 email to a Humboldt manager who oversaw

risk and underwriting, the senior underwriter identified such patterns

and explained how they are ignored, “especially” if the accounts are

from “one of our special handling” sales agents:

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.26 Filed 09/08/26 Page 26 of 89

Clusters of apps coming with the same rep, same bank, same

corp location, same fulfillment, same website format, same

product type, same pricing, putting their home address on a

business website, trial price points on a straight sale

website, popular CBD pricing, obvious load balancing

techniques, customer contacts who make it clear the website

we have isn’t the website they put the transaction through,

obvious card sharing, calling the principal and they know

nothing about their own business, the occasional CRM

agreement which states the principal get[s] 1% o[f] the

profits or a $500-$750 flat rate for use of their identity. I

could keep going. We’ve been identifying these patterns to

supervisor and manager for years and been told to ignore

them, especially if they were one of our special handling

reps. We have a written policy on how to underwrite and

we’ve had numerous side conversations on how they really

want us to underwrite.

We’ve been sent to seminars that tell how to underwrite to

be told not to use those techniques less than a couple weeks

later as we were declining to[o] many accounts for being

straws.

We can most definitely identify these patterns and forward

to you but it seems like it may get overwhelming as the vast

majority of our accounts fall into multiple patterns.

59.

The same underwriter also reported to Humboldt’s

management that internal details about underwriting decisions

“historically . . . ha[ve] been shared with the sales partner[s],” which

helps fraudulent merchants “restructure submissions” and

“undermine[] risk procedures.”

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.27 Filed 09/08/26 Page 27 of 89

Humboldt Continued to Open and Process for Performance

Marketing Accounts Despite Indications of Pervasive

Fraud

60.

As Mastercard was identifying widespread load balancing

and card sharing among its Performance Marketing accounts in 2018

and 2019, Humboldt continued pursuing the Performance Marketing

business.

61.

To accomplish this, Humboldt in 2020 reclassified its

Performance Marketing accounts under a lower-risk MCC code and

started boarding the accounts on NAB’s BIN at the Acquiring Bank

(“NAB BIN”). These steps avoided Mastercard’s 5968 Rules (which took

effect in April 2019) and enabled Humboldt to increase the sales volume

processed through these accounts, respectively.

62.

Humboldt continued to open thousands of Performance

Marketing accounts from the same sales agents even though the

accounts incurred chargebacks at rates almost ten times higher than

the allowable thresholds used by the card brands and displayed clear

signs of being shell accounts engaged in widespread transaction

laundering.

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.28 Filed 09/08/26 Page 28 of 89

(1)

Humboldt’s Continued Pursuit of Performance

Marketing Accounts

63.

As it was forced by Mastercard to close thousands of

Performance Marketing accounts (classified MCC 5968) in 2018 and

2019 causing profits to substantially drop, Humboldt began to grow

back its Performance Marketing business to increase earnings.

64.

In November 2018, Humboldt’s President in connection with

preparing a proposed budget for 2019 noted that although “[w]e are still

boarding performance marketing 5968 at a nice rate . . . [,] we won’t

know until April 2019” (when Mastercard’s 5968 Rule became effective)

“whether that vertical will continue to grow. Right now it appears to be

a coin flip.”

65.

The following year, in October 2019, Humboldt’s President

sent a text message to another officer that “Visa is rolling out new regs

next year for 5968” and “[w]ho knows if they will want to conduct a

portfolio review.”

66.

In January 2020, Humboldt’s President prepared a revised

budget for 2020 that now projected significant growth in monthly MCC

5968 account volume, from $9.8 million in January 2020 to $41 million

in December 2020. In his 2020 annual performance evaluation,

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.29 Filed 09/08/26 Page 29 of 89

Humboldt’s President noted: “I went into 2020 with the goal of reviving

the Performance Marketing vertical in Q1 which was necessary in order

to meet 2020 plan.” Similarly, in his 2021 annual performance review,

Humboldt’s President listed his “goals and defined objectives” for 2021

as including “[r]esuscitat[ing] the performance marketing vertical.”

67.

Humboldt’s President directed a Humboldt officer who

manages and oversees the underwriting and risk teams to grow the

Performance Marketing vertical after that officer suggested on multiple

occasions that Humboldt stop accepting Performance Marketing

accounts given the risk they were shells.

68.

Humboldt’s management grew the Performance Marketing

vertical even though they knew that its Performance Marketing

accounts consistently incurred chargeback rates higher than the 1%

thresholds used by the card brands.

69.

In April 2020, Humboldt’s President emailed other

executives and explained that Humboldt would not be able to open any

“trial/continuity in the health & beauty space” under a proposed

sponsorship agreement with another Acquirer due to its a chargebackratio limit of 0.75% on each merchant, which would “essentially

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.30 Filed 09/08/26 Page 30 of 89

exclude[]” the merchants in that space. In an apparent reference to load

balancing, Humboldt’s President explained how these merchants,

despite their high chargeback ratios, evade the card brands’ monitoring

programs by keeping their monthly chargeback counts below the card

brands’ thresholds: “those merchants generally run above 1% but under

chargeback threshold count (which we’ve discussed previously).”

(2)

Humboldt’s Efforts to Circumvent Mastercard’s 5968

Rule and Grow the Performance Marketing Vertical

70.

Humboldt undertook several actions beginning in 2020 to

recapture and grow the Performance Marketing business it lost as a

result of the Mastercard reviews of its portfolio.

71.

First, Humboldt by early 2020 began to accept Performance

Marketing merchants that submitted so-called “travel pack”

applications. These applications were used by fraudulent merchants to

mask negative-option trial billing, thereby evading Mastercard’s 5968

Rule, by claiming that small-dollar transactions processed by accounts

were for travel-size products—not trial offers.

72.

Second, Humboldt classified Performance Marketing

accounts under general, lower-risk MCCs (instead of MCC 5968) and

then boarded these accounts onto NAB’s lower-risk BIN at the

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.31 Filed 09/08/26 Page 31 of 89

Acquiring Bank (instead of Humboldt’s BIN at the Acquiring Bank).

Humboldt took these steps to increase the accounts’ “approval ratios”—

the number of transactions authorized (i.e. attempted) compared to the

number of transactions settled (i.e. not declined by issuing banks and

actually processed)—thereby increasing the volume of transactions

processed through Performance Marketing accounts. Humboldt knew

these accounts had excessive chargeback rates but still continued

boarding them on the NAB BIN under the lower-risk MCC codes.

Humboldt Allows “Travel Packs”

73.

After Mastercard’s 5968 Rules for negative-option trial

merchants went into effect in April 2019, Humboldt began receiving

“travel pack” applications from the same sales agents that had referred

Performance Marketing accounts that were closed for fraudulent

activity during the Mastercard reviews.

74.

The travel pack applications listed merchant websites that

were “front websites” or “bank pages,” which are not the websites

actually used by consumers. Instead, bank pages are set up by

fraudsters to apply for and obtain merchant accounts, which are then

used to launder transactions from different, undisclosed websites.

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.32 Filed 09/08/26 Page 32 of 89

75.

The bank pages identified in the travel pack applications

claimed to sell small “travel” size products—for example, a one-day dose

or two pills of a nutraceutical supplement, or 0.02 ounces of a skin

cream—at low price points, such as $4.99 or $6.95, that correspond to

introductory trial promotions used in negative option billing.

76.

Bank pages for travel pack applications, however, were set

up to look like single or straight sales of travel size products. The

webpages were supposed to show no sign of products being sold through

a negative-option trial offer.

77.

An example is shown in Figure 2, which is a September 2021

screenshot of the URL “sayyourhealth.com,” which was listed on an

application for an account opened by Humboldt. The merchant website

in Figure 2 claims to sell a “One week’s supply Travel Size Bottle” for

$4.95:

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.33 Filed 09/08/26 Page 33 of 89

FIGURE 2:

Screenshot of sayyourhealth.com

78.

By 2020, Humboldt’s management decided to start

approving “travel pack” applications even though they appeared

intended to mask trial billing. In January 2020, after receiving a text

message from another executive that “we have to hit [the 2020] plan,”

Humboldt’s President responded that “changing our policy on accepting

travel packs” “should help.”

79.

Around the same time, Humboldt also was focused on

increasing its business with the sales agents whose accounts previously

had been closed. In April 2020, in an email discussing “Daily Stats” on

Humboldt’s account applications and approvals, Humboldt’s President

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.34 Filed 09/08/26 Page 34 of 89

explained to another executive that increased application submissions

were due to “a large effort . . . to earn back trust from existing sales and

referral partners.”

80.

Humboldt opened the “travel pack” accounts under more

general, lower-risk MCC codes for nutraceutical and cosmetic products,

such as 5499, which is for “Miscellaneous Food Store – Convenience

Store and Specialty Markets,” and 5977 for “Cosmetic Stores,” instead

of MCC 5968.

81.

Indeed, Humboldt completely stopped opening Performance

Marketing accounts under MCC 5968 after 2019 and did not register

any accounts with Mastercard as negative option billing merchants

under Mastercard’s 5968 Rules. Humboldt’s President told another

executive that classifying Performance Marketing accounts with the

lower-risk MCC 5499 also had the potential “benefit” of increasing sales

volume, because MCC 5499 “has historically had higher [approval]

ratios” than MCC 5968.

82.

Humboldt’s management made sales agents aware that

“travel pack” applications would not be flagged by Humboldt’s

underwriting as potential trial merchants and instructed sales agents

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.35 Filed 09/08/26 Page 35 of 89

that the websites used with the applications should use “Travel Size

verbiage.”

83.

For example, in January 2021, a Humboldt manager who

oversaw risk and underwriting emailed Arc, Humboldt’s top sales

agents for Performance Marketing accounts, and directed that the

website in an application submitted by Arc be revised to use “Travel

Size verbiage” to describe a “smaller product option,” instead of using

the term “Sample size,” which “implies Trial” and would be flagged by

Humboldt’s underwriting. Arc relayed these directions to its referral

sources, describing “travel pack” as a kind of a “non-true trial business

model” in an email to a primary sub-agent.

84.

In other instances, Humboldt instructed merchants to

specifically remove all instances of the word “trial” and replace them

with the word “travel.” For example, internal records reflect that a

Humboldt employee provided the following instructions to a merchant

in response to an application submitted in December 2022: “Replace the

word trial on products to travel (ex. NO2-Trial, protein powder trial)”

and “remove trial offer from terms and conditions when referring to

products (replace with travel).”

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.36 Filed 09/08/26 Page 36 of 89

85.

Humboldt was aware that “travel pack” accounts were used

to process negative option trial transactions. Humboldt’s internal risk

meeting notes from August 2021 reported that accounts selling only

“travel packs” were “commonly used to hide trials.” Humboldt also

received notices of fines from Mastercard that it assessed on “travel

pack” accounts that were discovered to be engaged in unapproved highrisk negative-option billing practices. Nevertheless, Humboldt

continued to process transactions for travel pack accounts through at

least 2022.

Humboldt Boards Performance Marketing Accounts on the

NAB BIN

86.

Despite its decision to allow “travel pack” accounts and to

open accounts under MCC 5499, Humboldt’s Performance Marketing

business did not meet financial projections through the first half of

2020.

87.

During this time, Humboldt’s President discussed with other

executives that an impediment to Humboldt’s growth was that MCC

5499 accounts on Humboldt’s BIN had a lower percentage of their

attempted transactions approved (instead of declined) for payment—a

metric referred to as an “authorization rate” or an “approval ratio”—

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.37 Filed 09/08/26 Page 37 of 89

when compared to 5499 accounts that were on lower-risk BINs, such as

NAB’s BIN at the Acquiring Bank. An internal document prepared by

Humboldt’s President in September 2020 explained that “many issuers

have labeled” Humboldt “as having a ‘bad BIN’, of which the primary

cause is that we have segregated our high-risk business from our lowrisk business.” (That is, Humboldt’s high-risk business was segregated

onto the Humboldt BIN, while NAB’s low-risk business was on the NAB

BIN.) The result was that “NAB[’s BIN] outperforms HMS by 34%”

according to “a comparative analysis on MCC 5499” merchants.

88.

By October 2020 Humboldt began boarding Performance

Marketing accounts classified as MCC 5499 onto the NAB BIN.

89.

Humboldt directed its sales agents to make sure travel pack

accounts were using “EPX branded application[s]” so they could be

placed on the NAB BIN. For example, in a November 2020 email, Arc

directed a sub-agent: “So for all nutra, HMS [Humboldt] wants us using

the [NAB] branded application and supporting docs going forward. The

only exception is if they have trial (not travel pack but a true trial

billing model) which we [sic] still use the HMS branded application.”

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.38 Filed 09/08/26 Page 38 of 89

90.

Around the same time that Humboldt started boarding

Performance Marketing accounts onto the NAB BIN, Humboldt

changed its internal risk policies to make them more lenient and

conducive for merchants engaged in load balancing techniques, by

raising Humboldt’s internal limit on an individual account’s chargeback

rate from 5% to 9% so long as the account’s monthly chargeback counts

did not approach the thresholds used by the card brands to trigger

placing merchants in their monitoring programs.

91.

Humboldt’s efforts were successful, and a large number of its

Performance Marketing accounts were boarded onto the NAB BIN. The

number of Performance Accounts referred by Arc and Merchant Focus

that were opened on NAB BIN spiked in 2021. Figure 3 shows that the

number of open Arc and Merchant Focus accounts on the NAB BIN

increased from 80 in December 2020 to 750 in October 2021, while the

number of open Arc and Merchant Focus accounts on Humboldt’s BIN

decreased. As the number of Arc and Merchant Focus accounts spiked

from December 2020 to October 2021, virtually no accounts were opened

on the NAB BIN by any of Humboldt’s other top-referring sales agents.

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.39 Filed 09/08/26 Page 39 of 89

FIGURE 3:

Number of Open Arc and Merchant Focus Accounts by BIN

(Dec. 2020 to Oct. 2021)

92.

As this shift to the NAB BIN was occurring, Humboldt’s

President emailed other executives in January 2021 with “an analysis

showing approval ratios for Performance Marketing merchants,”

reporting “that the [NAB BIN] approves at 82% and [Humboldt’s BIN]

approves at 47%.” He further explained: “The merchants that were

chosen for the analysis are about as similar as they come. In addition to

sharing the same payment data points (MCCs, ticket sizes, and average

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.40 Filed 09/08/26 Page 40 of 89

processing volumes), they also sell the same products, and share

referral and traffic sources.”

93.

Humboldt used the prospect of increased approval ratios to

solicit more Performance Marketing business. In a January 2021 email

to other executives, Humboldt’s President explained that Performance

Marketing merchants decide which accounts “to route transactions”

through based on “approval ratio metrics [they receive] from the CRMs .

. . .” (CRMs refer to third-party entities known as “customer

relationship managers,” used by Performance Marketing merchants for

transaction management services, including tools that enable

merchants to route transactions across multiple merchant accounts at

different processors.)

94.

The importance of higher approval ratios was also discussed

in chat messages between Arc’s owner and his referral sources. For

example, in a September 2022 chat message, Arc’s owner told a leading

sub-agent that “if we can get the higher approval ratios, you know guys

will use those MID’s [merchant accounts] first[.]” The sub-agent

responded: “yea approvals [sic] rates seem to be the name of the game

right now.”

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.41 Filed 09/08/26 Page 41 of 89

95.

As a result of these efforts, Humboldt’s revenues from

Performance Marketing accounts classified with lower-risk MCCs 5499

and 5977 increased from approximately $30 million in 2020 to

approximately $50 million in 2021.

96.

By mid-2021, Humboldt’s Performance Marketing accounts

on NAB’s BIN collectively had a chargeback rate of over 7%, which was

almost 100 times higher than the NAB BIN’s overall chargeback rate of

0.08%. In June 2021, a risk officer reported that Humboldt’s accounts

on the NAB BIN had “high return and chargeback percentages based on

the type of merchants they have been boarding (nutra).” Humboldt’s

MCC 5499 accounts on NAB’s BIN processed more than $19 million

from January 2021 through May 2021 with a chargeback rate of over

7%, while the other MCC 5499 accounts on NAB’s BIN (excluding the

Humboldt accounts) had a chargeback rate of just 0.02%.

(3)

Humboldt Continued to Open Performance

Marketing Accounts Despite Clear Indications They

Were Shell Accounts

Humboldt’s Performance Marketing Business Largely

Came from Two Sales Agents

97.

Most of Humboldt’s Performance Marketing accounts came

from two sales agents, Arc and Merchant Focus. For years, Humboldt

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.42 Filed 09/08/26 Page 42 of 89

continued to open thousands of Performance Marketing accounts from

these two agents even though the accounts they referred consistently

incurred chargebacks at rates almost ten times higher than thresholds

used by the card brands and displayed clear signs of being shell

accounts involved in transaction laundering. Humboldt continued to

rely on referrals from Arc and Merchant Focus to grow its Performance

Marketing business through 2023 (until after Humboldt learned of the

FTC’s investigation).

98.

From 2020 to December 2023, Arc and Merchant Focus

accounts together accounted for more than 70% of Humboldt’s total

processing volume referred by its principal sales agents (those who

referred 100 or more accounts during this period).

99.

The accounts referred by both Arc and Merchant Focus

consistently had excessive levels of chargebacks and credit card decline

rates, which are indicators of fraudulent or deceptive practices. For

example, from December 2020 to December 2023, the overall

chargeback rate (calculated by dollar amount of chargebacks divided by

gross sales) of accounts referred by Arc and Merchant Focus during that

time period was each over 12%.

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.43 Filed 09/08/26 Page 43 of 89

100. Additionally, the two top chargeback reason codes, by a large

margin, for chargebacks on accounts referred by Arc and Merchant

Focus were Visa Reason Code 10.4 (“Other Fraud-Card Absent

Environment”) and Mastercard Reason Code 4837 (“No Cardholder

Authorization”).

101. From December 2020 to December 2023, the overall decline

rates (calculated by the number of declined transactions over the

number of attempted transactions) for accounts referred by Arc and

Merchant Focus during that time period was approximately 76% and

64%, respectively. In other words, issuing banks were declining

attempted transactions from merchants referred by Arc and Merchant

Focus at a 60% rate or higher during this period.

102. The account applications referred by both Arc and Merchant

Focus often listed recently-formed entities (such as limited liability

companies or “LLCs”) with no prior business or sales history; UPS store

mailboxes as their business addresses; and nearly all of the business’s

core operations, such as product fulfillment, customer relationship

management, customer service, and advertising or affiliate marketing,

performed by third parties. In addition, virtually all the applications

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.44 Filed 09/08/26 Page 44 of 89

from Arc and Merchant Focus sought and were approved for accounts

that were limited to processing no more than $100,000 per month.

103. The accounts referred by Arc and Merchant Focus were

usually closed less than a year after they were opened. Most of these

accounts were closed for “excessive chargebacks” or “Unacceptable Level

of Risk,” which is the description Humboldt used for closures for

transaction laundering or engaging in unauthorized trials.

104. Additionally, throughout 2021, 2022, and 2023, Humboldt’s

management had repeated discussions with Arc’s owner about patterns

and connections among Arc’s referrals indicative of straw accounts.

These connections included account applications for LLCs having a

similar naming convention along with similar website templates and

URLs.

105. For example, in October 2021, Humboldt’s management

listed accounts opened by LLCs that were engaged in nearly identical

processing activity; that had formulaic entity names that shared

unusual words (such as “Crest,” “Dream,” “Gardens,” “Grinds,”

“Standings,” “Venturing,” and “Vines”); and that had websites with

URLs beginning with the word “get.” These patterns are displayed in

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.45 Filed 09/08/26 Page 45 of 89

Figure 4, which is an excerpt of a spreadsheet that Humboldt’s

management sent to Arc’s owner. The patterns of common words in the

LLC names were highlighted in different colors by Humboldt.

FIGURE 4:

Excerpt of Spreadsheet Sent by Humboldt’s Management

to Arc in October 2021

LBN

Safana Glossy Dream LLC

Soarna Rested Advertising LLC

Anayna Icy Vines LLC

Mecole Gypse Venturing LLC

Domira Young Crest LLC

Deblina Hopes Gardens LLC

Avahna Kinder Grinds LLC

Modzla Scally Company LLC

Swaleha Jolly Grinds LLC

Spafty Jummping Gardens LLc

Diamon Vintage Harmony LLC

Duniya Koala Standings LLC

Syafira Kind Makings LLC

Pyriel Zaya Arches LLC

Slausy Runny Freedom LLC

Meddina Glowing Vines LLC

Mojay Pearl Dreams LLC

Slabem Ewan Breeze LLC

Sudyka Lili Venturing LLC

Plaski Rio Blooms LLC

Jacion Geese Marketing LLC

Drakkon Fresh Standings

Doctrix Toasted Rays LLC

Julain Awning Crest LLC

URL

getsefanapump.com

getsoarnapump.com

getaaynapump.com

getmodztacream.com

getdomirapump.com

deblinaderm.com

getaaynacream.com

getmodztapump.com

getsoarnacream.com

getslausypump.com

getduniyacream.com

getduniyapump.com

getsyafiracream.com

getplaskipump.com

getspaftycream.com

meddinatrim.com

getmojayserum.com

getslabencream.com

getslabenpump.com

getplaskicream.com

getjacionglow.com

drakkonfitgear.com

getdoctrixtrim.com

getdoctrixglow.com

getjulaincharge.com

URL (2)

getsyafirapump.com

getswalehapump.com

getavahnapump

getmecolecream.com

getdomiraslim.com

getdeblinacream.com

getavahnacream.com

getmecolepump.com

getswalehacream.com

getspaftypump.com

getdiamoncream.com

getduniyapump.com

getsefanacream.com

getpyrielpump.com

getslausycream.com

meddinablast.com

buymojayderm.com

getsudykacream

sudykaignite.com

getpyrielcream.com

getjulainbalm.com

N/A

getjulaintrim.com

106. Then, more than half a year later, in August 2022, a

Humboldt manager emailed Arc’s owner describing the same patterns

involving similar URL and entity names continuing to occur among

Arc’s accounts:

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.46 Filed 09/08/26 Page 46 of 89

We are seeing these similar DBA setups coming through

again and we are seeing similarities in their processing . . . .

These ‘Get’, ‘buy’ or ‘try’ commonalities in the DBA and

URL’s. I do not know what referral sources these are from,

but they are following patterns we have seen previously. . . .

I would recommend your team watch the common URL and

DBAs be submitted and from where they are coming from.

Might need to have a convo with those sources or firm action

based on your findings.

107. Despite these red flags, Humboldt continued to open

accounts from Arc even after Arc refused to identify the sources of shell

accounts onboarded at Humboldt.

Humboldt Opened Over a Thousand Shell Accounts

Connected to at Least One Known Credit Card

Laundering Network

108. From January 2021 through 2023, Humboldt opened more

than one thousand accounts for merchants referred by Arc and

Merchant Focus that were shell entities set up to engage in transaction

laundering by an organization named Reseller Consultants, Inc.

(“Reseller Consultants”).

109. Reseller Consultants recruited individuals across the

country to serve as straw signers for shell accounts controlled by third

parties referred to as “advertisers.” Most of the “advertisers” that paid

Reseller Consultants to secure straw signers were “in the nutra space

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.47 Filed 09/08/26 Page 47 of 89

(skin care, diet products, muscle products, etc)[,]” according to an

internal document prepared by Reseller Consultants’ owner.

110. For example, one “advertiser” that paid Reseller Consultants

to secure straw signers was a group of entities controlled by a United

Kingdom resident, Harshil Topiwala, according to a complaint filed by

the FTC in June 2024. See FTC v. Legion Media, LLC, No. 8:24-cv-1459

(M.D. Fla. June 17, 2024), ECF No. 1. As alleged in the complaint,

Topiwala and entities he controlled (the “Legion Media Defendants”)

participated in business impersonation scams where consumers

received communications appearing to be from known businesses

inviting them to pay a small shipping fee for a supposedly free “gift”

online. However, after consumers used their credit and debit cards to

pay a fee, they incurred recurring unauthorized charges on their cards.

The Legion Media Defendants facilitated the scams by securing

merchant accounts using shell entities from Reseller Consultants to

process the unauthorized online charges. The complaint alleged

violations of the FTC Act, the Restore Online Shoppers’ Confidence Act,

15 U.S.C. §§ 8401-05, and the Electronic Fund Transfer Act, 15 U.S.C. §

1693e(a), and Regulation E, 12 C.F.R. § 1005.10(b).

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.48 Filed 09/08/26 Page 48 of 89

111. On June 18, 2024, the court granted the FTC’s motion for an

ex parte temporary restraining order and froze defendants’ assets and

placed the Legion Media companies in a temporary receivership. On

September 16, 2024, the court entered stipulated orders against the

Legion Media Defendants that permanently shut down their operations

and required the forfeiture of assets.

112. Reseller Consultants recruited individuals by promising they

can earn $750 dollars a month without having to use any of their own

money by becoming “resellers” on merchant accounts used by

“advertisers” to sell products online. Reseller Consultants directed the

signers to form an LLC and open a mailbox at a UPS store and a

corporate bank account in the name of the newly formed LLC.

113. In at least one instance, one of the individuals recruited by

Reseller Consultants described to Humboldt (during efforts to collect an

overdue account balance) how the shell accounts were set up. In August

2021, a Humboldt manager relayed to Arc’s owner what the signer had

reported to Humboldt, while suggesting only that Arc’s owner “might

need to review the referral source”:

[H]e said they called him to check his credit score, they had

him set up an LLC at the bank and a box at the post office,

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.49 Filed 09/08/26 Page 49 of 89

and they kept over drafting his account. They were to pay

him 750.00 per month for the use of the account.

114. The “advertisers,” not the “resellers,” built websites in the

names of the shell entities and then used them in applications for

merchant accounts. The “resellers’” involvement was limited to signing

the applications. If an ISO or bank happened to ask questions, Reseller

Consultants coached the “resellers” through the call. According to an

internal document prepared by Reseller Consultants’ owner, “[t]he

advertisers are provided full access to the reseller bank accounts” and

“will manage the day to day activity of the account” even though the

advertisers “[n]ever actually are signers or owners of the bank account.”

115. In December 2023, the United States Department of Justice

filed a complaint under seal against Reseller Consultants and others to

“enjoin the ongoing commission of criminal wire fraud and bank fraud

and conspiracy to commit those offenses in violation of 18 U.S.C. §§

1343, 1344, and 1349.” United States v. CB Surety LLC, No. 2:23-cv2812 (E.D. Cal. Dec. 1, 2023). In January 2024, the court issued a

preliminary injunction, placing Reseller Consultants in a temporary

receivership and freezing its assets.

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.50 Filed 09/08/26 Page 50 of 89

116. The shell entities set up by Reseller Consultants have a

unique, formulaic naming convention where the entity’s name consists

of three seemingly unrelated words, with the first letter of the entity’s

name being the same as the first letter of the signer’s first name. In

addition, the entities’ names shared unusual words (including those

previously identified as patterns by Humboldt’s management, see supra

¶ 124, Fig. 4). This naming pattern is illustrated in Appendix A hereto,

which lists these shell accounts opened by Humboldt, identifying them

by legal entity name and setting forth the number of merchant accounts

that Humboldt opened for each legal entity.

117. Humboldt processed at least $139 million through these

shell accounts from January 2021 through January 2024, with the

accounts comprising approximately 25% of all transactions processed by

Humboldt from Arc and Merchant Focus accounts during this time.

118. Consumers incurred unauthorized charges directly linked to

shell accounts identified in Appendix A. Consumer complaints referring

to entity or DBA names listed on shell account applications report

similar incidents of incurring unauthorized charges after ordering

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.51 Filed 09/08/26 Page 51 of 89

online purported health and cosmetic products (including cannabidiolrelated or “CBD” related products).

119. Other consumer complaints referring to the DBA names

report similar business impersonation scams. These scams involve

communications sent to consumers that purport to be from known

businesses inviting them to enter an online sweepstakes, fill out a

survey for a reward, or claim a supposedly “free” gift they won.

However, after consumers used their credit and debit cards to pay a

small fee, they incurred recurring unauthorized charges on their cards.

120. Based on the facts and violations of law alleged in this

Complaint, the FTC has reason to believe that Defendant is violating or

are about to violate laws enforced by the FTC because, among other

things:

Defendant engaged in its unlawful acts and practices

repeatedly over a period of several years;

Defendant earned significant revenues from participating in

these unlawful acts and practices;

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.52 Filed 09/08/26 Page 52 of 89

To the extent that Defendant stopped certain unlawful

conduct, Defendant did so only after learning that the FTC

was investigating its conduct; and

Defendant remains in the payment processing business and

maintains the means, ability, and incentive to resume its

unlawful conduct.

VIOLATIONS OF THE FTC ACT

121. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits

“unfair or deceptive acts or practices in or affecting commerce.” Acts or

practices are unfair under Section 5 of the FTC Act if they cause or are

likely to cause substantial injury to consumers that consumers cannot

reasonably avoid themselves and that is not outweighed by

countervailing benefits to consumers or competition. 15 U.S.C. § 45(n).

COUNT I – UNFAIR PAYMENT PROCESSING PRACTICES

122. In numerous instances, Defendant has:

(a) Opened or maintained payment processing accounts for

merchants that Defendant knew or should have known

were shell companies or engaged in fraud;

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.53 Filed 09/08/26 Page 53 of 89

(b) Processed transactions to consumers’ credit card or debit

card accounts for merchants that Defendant knew or

should have known were shell companies or engaged in

fraud;

knew or should have known were shell companies or

engaged in fraud; and

(d) Ignored evidence of fraudulent activity on merchant

accounts, including that accounts were shell companies.

123. Defendant’s acts or practices cause or are likely to cause

substantial injury to consumers that consumers cannot reasonably

avoid themselves and that is not outweighed by countervailing benefits

to consumers or competition.

124. Therefore, Defendant’s acts or practices as described in

Paragraph 122 constitute unfair acts or practices in violation of Section

5 of the FTC Act, 15 U.S.C. § 45(a), (n).

CONSUMER INJURY

125. Consumers have suffered substantial injury as a result of

Defendant’s violations of the FTC Act. Absent injunctive relief by this

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.54 Filed 09/08/26 Page 54 of 89

Court, Defendant is likely to continue to injure consumers and harm the

public interest.

PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court:

Enter a permanent injunction to prevent future violations of

the FTC Act; and

Award any additional relief as the Court determines to be

just and proper.

Respectfully submitted,

Dated: September 8, 2026

Local Counsel for the

Federal Trade Commission

s/ Darren Lubetzky_______________

Darren Lubetzky (NY Bar #4932976)

Vikram Jagadish (NY Bar # 5516588)

Christopher Y. Miller

(NY Bar #3983160)

Pursuant to Local Rule 83.20(g)

Kevin R. Erskine

Federal Trade Commission

Chief, Civil Division

Northeast Regional Office

United States Attorney’s Office One Bowling Green, Suite 318

Eastern District of Michigan

New York, NY 10004

211 W. Fort Street, Suite 2001 Email: dlubetzky@ftc.gov

Detroit, MI 48226

Email: vjagadish@ftc.gov

Email: Kevin.Erskine@usdoj.gov Email: cmiller@ftc.gov

Office phone: (313) 226-961

Tel: (212) 607-2808

Attorneys for Plaintiff Federal Trade

Commission

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.55 Filed 09/08/26 Page 55 of 89

Appendix A

Federal Trade Commission v. 5967 Ventures, LLC

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.56 Filed 09/08/26 Page 56 of 89

Legal Entity Name

4Store Ventures Inc

Aag Lane Health LLC

Aamair Noice Venturing LLC

Aaquil Creative Group LLC

Aarome Quan Creations LLC

Aatamia Tia Group LLC

Aaura Fizzy Dreams LLC

Aavony Kinder Harvest LLC

Aavya Crusing Shores LLC

Aayna Icy Vines LLC

Aazan Grace Standings LLC

Abadia Misted Harmony LLC

Abale Marketing Creations LLC

Abatuto Ness Ventures LLC

Abb Grain Nutrition LLC

Abeel Local Makings LLC

Abelia Lane Group LLC

Abiade Demi Media LLC

Abidur Lily Group LLC

Ablawa Laana Waves LLC

Ablox Flow Creations LLC

Absical Browning Systems LLC

Acarmia Pearl Company LLC

Acava Willow Sales LLC

Acelita Greek Knolls LLC

Acellus Bending Standings LLC

Acetty Tate Media LLC

Achuil Cole Global LLC

Ackenz Positive Services LLC

Actimel Creative Group LLC

Aculio Urban Mantra LLC

Adacia Savy Waves LLC

Adalius Cooling Sunshine LLC

A-1

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.57 Filed 09/08/26 Page 57 of 89

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Adalon Popular Beauty LLC

Adeenix Lacy National LLC

Adesola Longlife Company LLC

Adross Lasting Ventures LLC

Aeriyon Colorful Venturing LLC

Aethan Jib Marketing LLC

Afeera Lea Group LLC

Afolayan Brilliant Makings LLC

Afryna Legend Media LLC

Agcara Zee Wisdom LLC

Aguita Roman Harmony LLC

Ahania Milo Grinds LLC

Aheyo Union Creations LLC

Ahg Lasting Crest LLC

Ahvey Rising Marketing LLC

Aimviz Inc

Ajh Crest Group LLC

Ajway Gaia Pines LLC

Akamai Lear Media LLC

Akinia Gea Makings LLC

Ameire Drifed Makings LLC

Apoleo Clear Ventures LLC

Aquira Grace Force LLC

Aradune Evan Force LLC

Arafa Peace Breeze LLC

Arepo Xeno Dreams LLC

Asado Productive Creations LLC

Ashoo Jumping Advertising LLC

Ataraxy Dante Media LLC

Atherva Jolly Gardens LLC

Athlan Treasured Ventures LLC

Attelia Media Sales LLC

Aubrea Natural Marketing LLC

A-2

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.58 Filed 09/08/26 Page 58 of 89

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Augur Kinder Venturing LLC

Autumn Moves LLC

Avahna Kinder Grinds LLC

Avalanna Vintage Media LLC

Avalith Kali Dreams LLC

Avander Oscar Yearning LLC

Avant Gaff Venturing LLC

Averey Oxford Company LLC

Aviate Normal Force LLC

Avigai Hoping Media LLC

Awardal Sans Flowers LLC

Awert Rolling Branches LLC

Awwmit Ruby Media LLC

Axtin Lasting Skys LLC

Aybeniz Flash Marketing LLC

Azavier Theo Creations LLC

Azina Profound Sales LLC

Azrin Kelis Consulting LLC

Azrina Yearney Company LLC

Aztuvi Finna Opals LLC

Babilla Rocking Advertising LLC

Babita Nocking Mantra LLC

Bacala Peaceful Ventures LLC

Bacau Fairly Company LLC

Bachata Qib Group LLC

Badejo Ollie Ventures LLC

Badres Hazel Wisdom LLC

Baelyn Swag Pines LLC

Bahour Vented Advertising LLC

Bahtzee Urban Shores LLC

Baistin Ruby Knolls LLC

Baixue Arc Waves LLC

Bajedo Pip Hope LLC

A-3

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.59 Filed 09/08/26 Page 59 of 89

100

101

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

131

132

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Bakiza Alluring Dreams LLC

Balanza Kinder Vines LLC

Balbina Treasured Group LLC

Balconia Hoden Vines LLC

Banlete Wave Flowers LLC

Bantan Angelic Wisdom LLC

Baoyen Misted Advertising LLC

Be Young Corp

Beacon Miracle Company LLC

Beaming Arches Sales LLC

Beaula Val Company LLC

Bebesta Halo Marketing LLC

Becci Starry Company LLC

Beccre Rosey Harvest LLC

Beckley Xen Industries LLC

Beckta Otis Media LLC

Bedina Krafty Freedoms LLC

Beibi Eclipse Sales LLC

Biando Lawl Media LLC

Biezbo Kai Greens LLC

Bifana Caress Ventures LLC

Bobak Jetting Sales LLC

Bodary Nautical Sales LLC

Boffola Remy Crest LLC

Bracher Striving Marketing LLC

Braddaz Jaring Company LLC

Bth Arching Lands LLC

Buboa Lily Dreams LLC

Bubska Lucky Advertising LLC

Bufalus Kara Media LLC

Bunzor Pleb American LLC

Byerly Vibe Associates LLC

Byford Daring Media LLC

A-4

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.60 Filed 09/08/26 Page 60 of 89

Legal Entity Name

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

Cabral Bright Ventures LLC

Cabual Klassic Blooms LLC

Cadelyn Nova Ambers LLC

Cahsia Owl Gardens LLC

Caitren Heavy Strategies LLC

Caliyah Nacky Harmony LLC

Calvey Sweet Ventures LLC

Camaira Krafty Yearning LLC

Canson Rolling Willows LLC

Carima Star Brands LLC

Ceaira Rocky Media LLC

Ceann Lifting Advertising LLC

Cedalia Jaring Group LLC

Cederian Kali Media LLC

Cedra Rustic Blooms LLC

Cehlie Massi Skys LLC

Celeny Teal Nights LLC

Celissa Lasting Force LLC

Cemara Daring Wilderness LLC

Cenovia Positive Harmony LLC

Cenzina Young Blooms LLC

Cevel Local Marketing LLC

Cezzan Vibe Wilderness LLC

Challey Yearney Waves LLC

Chioni Daring Rounds LLC

Ciagan Piao Group LLC

Cibo Rocking Makings

Cicren Loaf Makings LLC

Cilentia Ventures Inc

Cimmara Wicked Horizons LLC

Cinmy Positive Ventures LLC

Cinter Alley Waves LLC

Ck Supplements Inc

A-5

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.61 Filed 09/08/26 Page 61 of 89

166

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

185

186

187

188

189

190

191

192

193

194

195

196

197

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Clade Beaming Sales LLC

Clain Marketing Company LLC

Clarkia Freedom Marketing LLC

Clavida Rosey Adventures LLC

Coaching Creative Media LLC

Cobee Venturing Enterprises

LLC

Coday Bucket Adventures LLC

Coeli Savy Makings LLC

Colasia Starry Brilliance LLC

Colena Oli Blooms LLC

Colorful Hills LLC

Cooling Grinds LLC

Cragle Twinkle Journey LLC

Craiper Melody Winds LLC

Cravyn Arching Group LLC

Craya Igloo Pines LLC

Creble Essay Gardens LLC

Crysa Ruby Mantra LLC

Cubesis Pom Creations LLC

Cudderin Qais Sales LLC

Cuhryn Kelis Marketing LLC

Cullars Jetted Horizons LLC

Cullen Rubey Advertising LLC

Curman Berry Paths LLC

Cutting Binds LLC

Cuzzar Vented Minds LLC

Cyade Oak Ventures LLC

Cyalista Pom Group LLC

Cyncier Zaya Creations LLC

Cyort Zipped Ventures LLC

Cyraih Base Maze LLC

Cyress Rosey Enterprise LLC

A-6

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.62 Filed 09/08/26 Page 62 of 89

Legal Entity Name

198

199

200

201

202

203

204

205

206

207

208

209

210

211

212

213

214

215

216

217

Cyrian Rustic Wilderness LLC

Cztier Ace Makings LLC

Dabess Koala Group LLC

Dabin Harvesting Ambers LLC

Dabira Lucia Willow LLC

Dable Radiant Venturing LLC

Dacen Halo Breeze LLC

Dacey Creative Ventures LLC

Daeleah Beauty Standings LLC

Dafta Creative Marketing LLC

Dahlyla Kindest Makings LLC

Dairion Grace Advertising LLC

Dairre Arching Wisdom LLC

Dajane Positive Scene LLC

Dakodi Trance Media LLC

Daleth Goat Creations LLC

Damaira Oak Group LLC

Danadie Crown Beams LLC

Danelda Bass Creations LLC

Dannard Venting Advertising

LLC

Daring Brilliance LLC

Deacy Motivated Solstice LLC

Deafore Niko Marketing LLC

Dealcon Tate Advertising LLC

Dealof Clara Ventures LLC

Dealsy Liv Blooms LLC

Deanzo Lyba Group LLC

Deasa Abstract Horizon LLC

Deasley Poppy Creations LLC

Deasy Quirky Ventures LLC

Debann Local Group LLC

Debria Intense Harmony LLC

218

219

220

221

222

223

224

225

226

227

228

229

A-7

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.63 Filed 09/08/26 Page 63 of 89

Legal Entity Name

230

231

232

233

234

235

236

237

238

239

240

241

242

243

244

245

246

247

248

249

250

251

252

253

254

255

256

257

258

259

260

261

262

Deetch Jubi Pines LLC

Degamo Nice Ventures LLC

Dejaye Alluring Creations LLC

Delanah Willow Marketing LLC

Diabro Kitty Harmony LLC

Diaconia Awesome Pines LLC

Diagon Vented Sales LLC

Diamine Path Marketing LLC

Diamon Vintage Harmony LLC

Dianara Rising Advertising LLC

Dicasali Koala Ways LLC

Dk Trinity American LLC

Dmb Arching Media LLC

Dobert Bold Freedom LLC

Doctrix Toasted Rays LLC

Doffins Venting Wilderness LLC

Domira Young Crest LLC

Donnery Colorful Blooms LLC

Dotted Wings LLC

Drade Jetted Ventures LLC

Drafin Zipped Company LLC

Drafton Crown Lands LLC

Dragily Growing Standings LLC

Draken Rustic Group LLC

Drakkon Fresh Standings LLC

Drakona Beaming Gardens LLC

Drapin Kool Wisdom LLC

Drate Toasted Minds LLC

Draxy Coaching Sales LLC

Dreamer Skys LLC

Dreka Piper Media LLC

Dreyona Melody Creations LLC

Drisen Oak Company LLC

A-8

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.64 Filed 09/08/26 Page 64 of 89

Legal Entity Name

263

264

265

266

267

268

269

270

271

272

273

274

275

276

277

278

279

280

281

282

283

284

285

Druham Reese Sales LLC

Druien Xeno Wings LLC

Druxzy Heavy Advertising LLC

Ds Whipped Team LLC

Dst Nacky Advertising LLC

Dt Wholesale Holdings LLC

Dubarry Pearl Solstice LLC

Duberry Finn Creations LLC

Dubeta Ollie Ventures LLC

Dubiler Cloud Adventures LLC

Dudel Harvest Media LLC

Dudita Natural Ways LLC

Dukaan Centura Blooms LLC

Dulley Abstract Rays LLC

Dulma Poppy Group LLC

Dunai Bright Creations LLC

Dunery Toasted Harmony LLC

Duniya Koala Standings LLC

Dunneil Berry Standings LLC

Dunow Creative Ventures

Durazi Rock Venturing LLC

Dviih Starry Lands LLC

Dxeorvai Treasured Marketing

LLC

Dyanni Kai Force LLC

Dydek Whimsy Gardens LLC

Dyfan Popular Group LLC

Dylena Brave Creations LLC

Dynali Crest Marketing LLC

Dynamic Greater Advertising

LLC

Dynamic Marketing LLC

Dyogi Misted Advertising LLC

286

287

288

289

290

291

292

293

A-9

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.65 Filed 09/08/26 Page 65 of 89

Legal Entity Name

294

295

296

297

298

299

300

301

302

303

304

305

306

307

308

309

310

311

312

313

314

315

316

317

318

319

320

321

322

323

324

325

326

Dyona Pine Opals LLC

Dyrlm Leet Wisdom LLC

Dystany Hoden Venturing LLC

Dyuti Pine Blooms LLC

Ea Marketing Group LLC

Eager Outback LLC

Eamon Wishful Ventures LLC

Ebaad Mighty Gardens LLC

Ebanie Piper Gardens LLC

Ebian Dutch Harps LLC

Eborn Growing Makings LLC

Ebosti Vibe Freedom LLC

Ecm Positive Nutrition LLC

Econo Random Greens LLC

Edella Gaia Makings LLC

Edelyn Haxel Designs LLC

Edevan Colorful Freedom LLC

Editate Luna Affiliates LLC

Edrolo Lucky Supply LLC

Efraib Liv Wisdom LLC

Efrona Bright Makings LLC

Egita Peace Media LLC

Ekans Colorful Yearning LLC

Ekwem Young Grains LLC

Eladdy Nova Gardens LLC

Eladia Rosey Group LLC

Elamai Hood Makings LLC

Elandra Arching Crest LLC

Eldon Crafting Sales LLC

Eldy Staring Media LLC

Emania Hot Shores LLC

Emanlee Tea Ventures LLC

Emaree Utopia Adventures LLC

A-10

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.66 Filed 09/08/26 Page 66 of 89

Legal Entity Name

327

328

329

330

331

332

333

334

335

336

337

338

339

340

341

342

343

344

345

346

347

348

349

350

351

352

353

354

355

356

357

358

359

Emarlie Xen Venturing LLC

Enalee Beaming Rounds LLC

Ending Crest LLC

Enita Creative Thyme LLC

Epicito Rustic Adventures LLC

Erv Bold Ads LLC

Esha Dreaming Group LLC

Esma Beauty Gardens LLC

Eternal Happy Adventures LLC

Ethalia Mia Standings LLC

Eufracio Growing Media LLC

Ewere Cloud Willows LLC

Exanna Mia Beams LLC

Exaudie Clear Gardens LLC

Ezallie Gentle Harmony LLC

Ezekai Rustic Media LLC

Ezmee Popular Marketing LLC

Ezrah Glowing Advertising LLC

Fabaw Creative Gardens LLC

Fabel Creative Ventures LLC

Fabrash Kinder Wilderness LLC

Fabrini Masterful Sales LLC

Faieza Artistic Health LLC

Faleen Colorful Standings LLC

Fanar Creative Sales LLC

Fedelyn Clay Gardens LLC

Ferne Willow Company LLC

Figata Dazzle Minds LLC

Flangg Ruby Vines LLC

Foligno Arching Marketing LLC

Fyela Classic Venturing LLC

Gabela Majestic Dreams LLC

Gaije Kool Force LLC

A-11

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.67 Filed 09/08/26 Page 67 of 89

Legal Entity Name

360

361

362

363

364

365

366

367

368

369

370

371

372

373

374

375

376

377

378

379

380

381

382

383

384

385

386

387

388

389

390

391

392

Galiba Reese Products LLC

Ganzul Imax Advertising LLC

Garja Precious Harmony LLC

Gasmyr Pearl Crest LLC

Geala Masterful Media LLC

Geara Bountiful Creations LLC

Genevi Colorful Sales LLC

Gerrit Sharp Pines LLC

Gibish Rising Lands LLC

Giella Climbing Dreams LLC

Gierel Clay Brands LLC

Githmi Beaming Service LLC

Gkg Misted Associates LLC

Glispe Nocking Marketing LLC

Goetta Positive Yearning LLC

Goladi Recent Journey LLC

Golar Venturing Group LLC

Graedon Uyen Media LLC

Grafix Cooling Adventure LLC

Gravan Brick Harps LLC

Greater Crest LLC

Guape Brilliant Sales LLC

Guska Young Media LLC

Gwahn Willow Rays LLC

Gweta Treasured Learning LLC

Habast Kale Ventures LLC

Habbes Clay Advertising LLC

Habbi Swag Ventures LLC

Habent Top Adventures LLC

Haemi Massi Creations LLC

Haidel Advertising Group LLC

Halawa Milo Sunshine LLC

Hamsika Xen Company LLC

A-12

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.68 Filed 09/08/26 Page 68 of 89

393

394

395

396

397

398

399

400

401

402

403

404

405

406

407

408

409

410

411

412

413

414

415

416

417

418

419

420

421

422

423

424

425

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Harith Cool Group LLC

Healite Piper Creations LLC

Healthy Glow Skincare Inc

Heiden Sleek Gardens LLC

Hellovork Trading Inc

Hembel Yan Marketing LLC

Hendell Beauty Group LLC

Hibee Trendy Standings LLC

Hoaye Xen Sales LLC

Homire Wan Media LLC

Hueck Willow Technology LLC

Hulena Crafty Ventures LLC

Iconnery Amber Marketing LLC

Ideatic Scoop Media LLC

Ikaria Greater Company LLC

Imaginize Clear Marketing LLC

Imare Quest Sales LLC

Imaree Gypsy Makings LLC

Inaya Creative Group LLC

Jabarro Yoshi Company LLC

Jabbari Yearning Creations LLC

Jabbery Yoko Arches LLC

Jabbigle Rising Dreams LLC

Jaber Lush Grinds LLC

Jaboi Dreaming Company LLC

Jaboo Honey Ventures LLC

Jacion Geese Marketing LLC

Jacire Happy Adventures LLC

Jacole Glowing Group LLC

Jadasia Eden Group LLC

Jadina Kiana Wilderness LLC

Jaehwi Yearning Designs LLC

Jaezali Krafty Wisdom LLC

A-13

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.69 Filed 09/08/26 Page 69 of 89

Legal Entity Name

426

427

428

Jaezel Essay Arches LLC

Jagati Crest Systems LLC

Jahana Popular Advertising

LLC

Jahanvi Popular Services LLC

Jahlile Crest Waves LLC

Jahnaye Amber Group LLC

Jahnya Colorful Partners LLC

Jahzia Ace Group LLC

Jaica Abi Brands LLC

Jaikia Nacky Yearning LLC

Jaimeh Popular Dreams LLC

Jaline Bright Grinds LLC

Jalvan Creative Nights LLC

Jamiza Key Adventures LLC

Janeyris Assist Endeavor LLC

Janow Kool Force LLC

Jariatu Move Endeavor LLC

Jb Pipe Arts LLC

Jeahcri Bop Ventures LLC

Jeaniel Gabi Paths LLC

Jeaniya Star Advertising LLC

Jeannell Berry Media LLC

Jearon Deky Media LLC

Jease Marketing Ventures LLC

Jeason Unique Ventures LLC

Jeazzy Kind Harmony LLC

Jebber Beaming Ventures LLC

Jebnist Vintage Glows LLC

Jecaine Bendy Ventures LLC

Jecen Kool Force LLC

Jecolia Clear Group LLC

Jedah Xen Willows LLC

429

430

431

432

433

434

435

436

437

438

439

440

441

442

443

444

445

446

447

448

449

450

451

452

453

454

455

456

457

A-14

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.70 Filed 09/08/26 Page 70 of 89

Legal Entity Name

458

459

460

461

462

463

464

465

466

467

468

469

470

471

472

473

474

475

476

477

478

479

480

481

482

483

484

485

486

487

488

489

490

Jeddon Gaia Media LLC

Jedin Creative Sales LLC

Jediya Ziggy Vines LLC

Jeein Noa Venturing LLC

Jeevall Abstract Palms LLC

Jeevitha Lush Makings LLC

Jegbola Venting Wings LLC

Jelavic Radiant Shores LLC

Jellien Top Venturing LLC

Jelsa Creative Media LLC

Jembri Clear Media LLC

Jenald Xander Brilliance LLC

Jendi Klassic Makings LLC

Jennet Urban Advertising LLC

Jetted Harps LLC

Jetur Dazzle Ambers LLC

Jhoanny Yobble Media LLC

Jhr Miramar Exchange LLC

Jiahni Hait Media LLC

Jianni Hazel Media LLC

Jiaray Syall Harmony LLC

Jiball Lawl Ventures LLC

Jibi Lasting Grinds LLC

Jigni Envy Gardens LLC

Jillien Panda Venturing LLC

Jilmar Piece Force LLC

Jinee Clear Sales LLC

Jingxi Greek Pines LLC

Jmd Pip Associates LLC

Joanzin Arching Group LLC

Jobbie Great Creations LLC

Jobius Scally Media LLC

Jobonie Uyen Company LLC

A-15

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.71 Filed 09/08/26 Page 71 of 89

Legal Entity Name

491

492

493

494

495

496

497

498

499

500

501

502

503

504

505

506

507

508

509

510

511

512

513

514

515

516

517

518

519

520

521

522

523

Joceliz Miracle Greens LLC

Jochi Bending Advertising LLC

Joctan Alley Blooms LLC

Jodding Cole Venturing LLC

Johari Lucky Marketing LLC

Joheli Awning Dreams LLC

Jolanta Koala Gardens LLC

Jozarie Sleek Industries LLC

Jozzin Legend Direct LLC

Jpm Noice Endeavor LLC

Jpm Tiger Advertising LLC

Jt Marketing LLC

Juadlol Ruby Hope LLC

Juahn Lad Creations LLC

Juanjo Positive Ventures LLC

Juanta Crafty Grains LLC

Juanya Rosey Sales LLC

Jubber Bold Adventures LLC

Jubean Advertising Group LLC

Judine Ozzy Sales LLC

Judlie Angelic Ventures LLC

Juell Kali Skys LLC

Julaani Kirk Crest LLC

Julain Awning Crest LLC

Julina Soft Company LLC

Julora Halo Blooms LLC

Jumka Whimsy Ventures LLC

Junilla Milo Standings LLC

Junyi Hoping Agility LLC

Juofex Starry Lands LLC

Juriana Yara Wilderness LLC

Justified Beauty LLC

Justist Lad Advertising LLC

A-16

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.72 Filed 09/08/26 Page 72 of 89

Legal Entity Name

524

525

526

527

528

529

530

531

532

533

534

535

536

537

538

539

540

541

542

543

544

545

Justly Dreams LLC

Juxtim Young Gardens LLC

Jw Technologies LLC

Jwanka Noice Group LLC

Jwc Krafty Health LLC

Jwellin Greek Advertsing LLC

Jycario Rocking Arches LLC

Jyrah Rosey Group LLC

Jyrinna Kelis Ventures LLC

Jyrnee Niko Media LLC

Kabao Jaring Company LLC

Kabary Pipe Willows LLC

Kabat Brilliance Sales LLC

Kabel Qualified Sales LLC

Kabelo Jumping Company LLC

Kaborq Hait Adventuring LLC

Kabrin Nyah Creations LLC

Kadny Miramar Pines LLC

Kaiana Positive Marketing LLC

Kaiann Masterful Blooms LLC

Kalaivani Beam Ads LLC

Kalam Advertising Company

LLC

Kali Jubilee Marketing LLC

Kamesa Oak Wisdom LLC

Karing Carts LLC

Kb Intense Studios LLC

Keadue Ollie Media LLC

Keanni Beauty Marketing LLC

Keante Sweet Nights LLC

Kearne Omar Venturing LLC

Keason Callum Group LLC

Keater Jaring Media LLC

546

547

548

549

550

551

552

553

554

555

A-17

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.73 Filed 09/08/26 Page 73 of 89

Legal Entity Name

556

557

558

559

560

561

562

563

564

565

566

567

568

569

570

571

572

573

574

575

576

577

578

579

580

581

582

583

584

585

586

587

588

Keauta Peace Force LLC

Keayla Lia Dreams LLC

Kedna Jaring Standing LLC

Keeanii Rustic Group LLC

Keeayra Turning Group LLC

Keeoni Xen Venturing LLC

Kefvie Blush Opals LLC

Kehana Xandra Brilliance LLC

Keilah Teal Creations LLC

Keimya Gentle Company LLC

Keirran Pearl Marketing LLC

Keiyala Nova Dreams LLC

Keleyna Beauty Crest LLC

Kellani Harvest Group LLC

Kelly Sales LLC

Kelty Wave Adventures LLC

Khairril Cooling Marketing LLC

Khrya Pearl Adventuring LLC

Kiajah Beauty Paths LLC

Kiajani Wan Advertising LLC

Kj Consulting Dreams LLC

Klaas Business Ventures LLC

Kleemo Lia Beams LLC

Kleiah Waffle Force LLC

Klemao World Sales LLC

Knoth Finn Media LLC

Koda Crafty Makings LLC

Kodey Blooming Marketing LLC

Kodi Hoping Media LLC

Koehn Clear Freedom LLC

Koelle Adorable Company LLC

Koemi Yearny Horizons LLC

Kohlie Tops Company LLC

A-18

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.74 Filed 09/08/26 Page 74 of 89

Legal Entity Name

589

590

591

592

593

594

595

596

597

Kohner Media Creations LLC

Kokila Utopia Group LLC

Krawk Happy Marketing LLC

Kuana Chain Rounds LLC

Kubik Path Sales LLC

Kuchzo Caring Rounds LLC

Kuini Avery Ventures LLC

Kuljot Maya Gardens LLC

Kumari Masterful Company

LLC

Kutting Moves LLC

Kyeran Rock Grinds LLC

Kyhara Halo Dreams LLC

Kynlei Braaj Ventures LLC

Kynsli Dutch Advertising LLC

Kyrica Rising Creations LLC

Kyrim Colorful Ventures LLC

Kyunga Daring Strategies LLC

Labi Kinder Rounds LLC

Labren Eagle Dreams LLC

Lacavia Fap Dreams LLC

Ladane Toasted Minds LLC

Lagaria Growing Creations LLC

Laggna Obz Paths LLC

Lagony Koala Creations LLC

Lahari Pip Advertising LLC

Lahayla Fresh Vines LLC

Laihya Rising Sales LLC

Laisah Fap Company LLC

Lajeena Jaring Willows LLC

Lalauni Zesty Wisdom LLC

Lallina Colorful Makings LLC

Lallor Popular Dreams LLC

598

599

600

601

602

603

604

605

606

607

608

609

610

611

612

613

614

615

616

617

618

619

620

A-19

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.75 Filed 09/08/26 Page 75 of 89

Legal Entity Name

621

622

623

624

Langeza Oak Wisdom LLC

Langstyn Kinder Vines LLC

Leabow Scoop Media LLC

Leading Climbing Marketing

LLC

Leafion Pom Group LLC

Leaford Dreamer Ventures LLC

Leanka Yate Marketing LLC

Leanni Artistic Sales LLC

Learic Chatting Harmony LLC

Ledion Plank Knolls LLC

Ledourx Kool Mantra LLC

Leifan Zipped Wilderness LLC

Lelyan Telling Harmony LLC

Lemari Creative Marketing LLC

Leoniki Pearl Harmony LLC

Libbit Yearning Dreams LLC

Libbs Creative Advertising LLC

Lieka Oasis Wisdom LLC

Lindl Gardens Media LLC

Living Wellness Inc

Ljc Brave Paths LLC

Lobatio Misted Advertising LLC

Lobda Amber Ventures LLC

Lobey Jaring Sales LLC

Lobke Green Media LLC

Lohany Zee Marketing LLC

Lolka Bear Media LLC

Luboo Boi Grinds LLC

Lucely Bright Minds LLC

Luchin Amazing Willows LLC

Lucien Strategic Dreams LLC

Ludovie Bea Grinds LLC

625

626

627

628

629

630

631

632

633

634

635

636

637

638

639

640

641

642

643

644

645

646

647

648

649

650

651

652

A-20

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.76 Filed 09/08/26 Page 76 of 89

653

654

655

656

657

658

659

660

661

662

663

664

665

666

667

668

669

670

671

672

673

674

675

676

677

678

679

680

681

682

683

684

685

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Lugzati Neary Grains LLC

Lya Halo Direct LLC

Lyanna Misted Creations LLC

Lyari Running Advertising LLC

Lydian Jotting Willow LLC

Lyhara Hoping Media LLC

Lyrican Urban Flowers LLC

M Thompson Sales LLC

Maarja Jasmine Harps LLC

Mabika Daring Lands LLC

Macai Zorb Company LLC

Mackala Eclipse Group LLC

Maclaughlin Advertising LLC

Madsci Peaceful Venturing LLC

Magony Willow Creations LLC

Mahega Pearl Technology LLC

Maholla Arching Shores LLC

Maliree Lasting Willows LLC

Manestic Yearney Ventures LLC

Marshall Enterprises Inc

Matco Enterprises Inc

Mayflower Point LLC

Mc General Brands LLC

Meable Longlife Creations LLC

Meadow True Paths LLC

Meanna Soft Blooms LLC

Mearph Twinkle Creations LLC

Mechlar Nature Group LLC

Mecole Gypsy Venturing LLC

Mectic Drifted Ventures LLC

Mectic Rosey Adventures LLC

Medally Quail Adventures LLC

Medani Priceless Harmony LLC

A-21

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.77 Filed 09/08/26 Page 77 of 89

686

687

688

689

690

691

692

693

694

695

696

697

698

699

700

701

702

703

704

705

706

707

708

709

710

711

712

713

714

715

716

717

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Meddina Glowing Vines LLC

Medina Lia Company LLC

Medixi Tate Crest LLC

Medora Justified Sales LLC

Medrick Lush Breeze LLC

Medroa Zesty Service LLC

Meekery Rosey Stars LLC

Meelad Brick Adventuring LLC

Meerp Beauty Stars LLC

Meester Rolling Ventures LLC

Megisa Colorful Adventures LLC

Mehany Jolly Standings LLC

Mehki Eden Blooms LLC

Meiqo Lucky Wisdom LLC

Meizuo Lush Blooms LLC

Mekah Crest Vines LLC

Melitza Striving Dreams LLC

Melouin Avery Creations LLC

Memdi Ice Harmony LLC

Menila Byed Adventures LLC

Merkle Advertising LLC

Miarma Finn Company LLC

Miecca Wodi Standings LLC

Milaniz Berry Start LLC

Misted Winds LLC

Mj Notting Products LLC

Moala Jace Company LLC

Moasi Delicate Beauty LLC

Mobify Feather Group LLC

Mobin Running Horizons LLC

Mobolaji Centural Venturing

LLC

Moccony Raven Advertising LLC

A-22

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.78 Filed 09/08/26 Page 78 of 89

Legal Entity Name

718

719

720

721

722

723

724

Mocheala Zia Creations LLC

Modai Positive Company LLC

Modar Creative Group LLC

Modawi Delicate Beauty LLC

Moddis Natural Horizon LLC

Modemz Kindly Greens LLC

Modern Venturing Company

LLC

Modex Artistic Media LLC

Modzta Scally Company LLC

Modzy Envy Binds LLC

Moety Starry Lands LLC

Mojay Pearl Dreams LLC

Mrazik Telling Advertising LLC

Mrazzle Waffle Sales LLC

Muacle Bright Adventures LLC

Mubean Beaming Sales LLC

Mudasar Rap Company LLC

Mufasi Crest Makings LLC

Mufkie Radiant Blooms LLC

Muggalo Gator Advertising LLC

Muhay Awning Grinds LLC

Muhina Zesty Pines LLC

Mukasa Bars Gardens LLC

Mukul Wave Sales LLC

Mulyani Sweet Zander LLC

Mumfie Jetting Ventures LLC

Murphy Marketing LLC

Murzap Quan Direct LLC

Mushira Savy Company LLC

Mussar Rock Pines LLC

Musta Harvest Sales LLC

Muth Sales LLC

725

726

727

728

729

730

731

732

733

734

735

736

737

738

739

740

741

742

743

744

745

746

747

748

749

A-23

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.79 Filed 09/08/26 Page 79 of 89

Legal Entity Name

750

751

752

753

Mwaka Noar Venturing LLC

Myael Jubel Standings LLC

Myha Creative Theme LLC

Mykiah Natural Consultants

LLC

Mykol Pottery Crest LLC

Mylahn Pipe Freedom LLC

Mylez Niko Willow LLC

Myliane Crafty Wellness LLC

Myrios Eve Brands LLC

Myrra Red Adventure LLC

Mystical Meaning LLC

Mythen Crafty Willow LLC

Mzuzi Legend Greens LLC

Naarai Envy Yearning LLC

Nabay Goat Sales LLC

Nabulu Wodi Media LLC

Nadhira Business Sales LLC

Najati Quail Group LLC

Nalexis Urban Advertising LLC

Nautical Jumps LLC

Neato Owl Sales LLC

Nebila Lana Dreams LLC

Nedoma Advertising Company

LLC

Nedoma Popular Brilliance LLC

Neelu Jaring Ventures LLC

Neemi Awning Gardens LLC

Neiwa Rylee Standings LLC

Niaya Pink Ventures LLC

Nicolli Kitten Waves LLC

Nimya Pace Blossoms LLC

Noblar Alley Opals LLC

754

755

756

757

758

759

760

761

762

763

764

765

766

767

768

769

770

771

772

773

774

775

776

777

778

779

780

A-24

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.80 Filed 09/08/26 Page 80 of 89

781

782

783

784

785

786

787

788

789

790

791

792

793

794

795

796

797

798

799

800

801

802

803

804

805

806

807

808

809

810

811

812

813

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Nodab Lifting Adventures LLC

Nodeue Dreaming Sales LLC

Noelen Classic Horizons LLC

Noirad Lucky Sales LLC

Nuala Brick Media LLC

Nubeta Fish Pines LLC

Nubia Jaring Lands LLC

Nuemi Colorful Horizons LLC

Nwanko Qwop Media LLC

Nyarie Grace Creations LLC

Nyasha Drawing Media LLC

Nyota Johab Ventures LLC

Oberen Holden Group LLC

Obinne Vibing Blooms LLC

Odiana Sharper Horizons LLC

Padidas Top Horizons LLC

Padmay Frosty Sales LLC

Pahty Jaring Ventures LLC

Paikot Artistic Dreams LLC

Palais Colorful Services LLC

Palmont Lucky Makings LLC

Paylov Inc

Peachy Brilliance Creations LLC

Peacing Harvest Company LLC

Piatrece Green Freedom LLC

Pictate Krafty Freedom LLC

Piscoski Otis Company LLC

Pixarch Inc

Plaski Rio Blooms LLC

Podna Brilliance Sales LLC

Poetess Yoga Shores LLC

Poetify Grace Blooms LLC

Polvoran Blast Venturing LLC

A-25

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.81 Filed 09/08/26 Page 81 of 89

Legal Entity Name

814

815

816

817

818

819

820

821

822

823

824

825

826

827

828

829

830

831

832

833

Pomax Fun Venturing LLC

Pragya Reese Creations LLC

Praize Sleek Ways LLC

Prasna Jaring Advertising LLC

Pulpie Rosey Shores LLC

Puranda Savy Crest LLC

Purvai Color Makings LLC

Pymont Lily Funnels LLC

Pyran Yoshi Marketing LLC

Pyriel Zaya Arches LLC

Pythia Koas Wisdom LLC

Raashi Dean Winds LLC

Rabbani Glossy Mantra LLC

Rabshan Lee Dreams LLC

Rabyah Fly Crest LLC

Racelyn Cole Venturing LLC

Racust Jace Ventures LLC

Radane Starry Company LLC

Radeon Arch Gardens LLC

Radimus Precious Marketing

LLC

Radley Willow Services LLC

Radomir Green Industries LLC

Radonic Owen Palms LLC

Raekel Trance Stars LLC

Raelina Xeno Standings LLC

Raemar Arc Scene LLC

Raeven Kind Pines LLC

Rafeliu Sweet Yearning LLC

Ragavi Jelling Venturing LLC

Raheeni Sweet Crest LLC

Rahela Kinder Advertising LLC

Rahiel Young Advertising LLC

834

835

836

837

838

839

840

841

842

843

844

845

A-26

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.82 Filed 09/08/26 Page 82 of 89

846

847

848

849

850

851

852

853

854

855

856

857

858

859

860

861

862

863

864

865

866

867

868

869

870

871

872

873

874

875

876

877

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Rahzel Alluring Companies LLC

Raika Willow Paths LLC

Rainald Clear Winds LLC

Ramarn Cooling Sunshine LLC

Ramero Kai Marketing LLC

Rampin Longing Sales LLC

Ramzan Arching Willow LLC

Rb Starry Communications LLC

Realtin Alley Opals LLC

Reanan Positive Lands LLC

Reani Harmony Makings LLC

Rebeaut Metal Venturing LLC

Rebien Ace Pines LLC

Recato Braaj Media LLC

Recepo Enzo Venturing LLC

Reeios Crafty Health LLC

Reesey Kirk Crest LLC

Regana Kool Brands LLC

Reigna Lush Standing LLC

Reinell Path Advertising LLC

Reniel Tia Paths LLC

Resting Mixes LLC

Reudi Lasting Skys LLC

Rhodium Alluring Ventures LLC

Rianke Jace Shores LLC

Ridhii Turning Wisdom LLC

Ritchie Sales LLC

Roamie Green Company LLC

Robinnio Dreamer Advertising

LLC

Rocendo Oli Sales LLC

Rodmey Piper Sales LLC

Rossul Beautiful Ying LLC

A-27

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.83 Filed 09/08/26 Page 83 of 89

Legal Entity Name

878

879

880

881

882

883

884

885

886

Rubaya Max Creations LLC

Rubayat Gypsy Pines LLC

Rudan Green Venturing LLC

Rudhir Bendy Dreams LLC

Rudian Daring Willows LLC

Rueya Genius Ventures LLC

Ruffell Kool Group LLC

Rumina Daisy Guild LLC

Rushdi Natural Technologies

LLC

Ruvin Classic Thyme LLC

Rylnn Lola Sales LLC

Rynal Angelic Company LLC

Rynon Scoop Venturing LLC

Ryoken Indie Services LLC

Saanil Kindest Brands LLC

Sabal Mighty Dreams LLC

Sabawon Berry Opals LLC

Sabbily Kitty Mantra LLC

Sabela Piper Gardens LLC

Sadalio Hoja Yearnings LLC

Sadee Blast Vines LLC

Sahima Arch Group LLC

Sahnari Dutch Maze LLC

Saidan Motivated Brands LLC

Saiden Trinity Makings LLC

Sajra Popular Grace LLC

Sakir Bogan Media LLC

Salgron Kinder Marketing LLC

Salinda Daisy Brands LLC

Samial Yara Adventures LLC

Saving Ambers LLC

Scamara Drifted Hope LLC

887

888

889

890

891

892

893

894

895

896

897

898

899

900

901

902

903

904

905

906

907

908

909

A-28

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.84 Filed 09/08/26 Page 84 of 89

910

911

912

913

914

915

916

917

918

919

920

921

922

923

924

925

926

927

928

929

930

931

932

933

934

935

936

937

938

939

940

941

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Scarbella Lace Ventures LLC

Scarletta Top Makings LLC

Scarlit Radiant Company LLC

Scerzy Uzan Agility LLC

Scharm Creative Sales LLC

Scharxy Grace Advertising LLC

Schasi Oasis Dreams LLC

Schibo Ness Winds LLC

Schoka Ruby Designs LLC

Seaborn Quaid Marketing LLC

Seabreeze Daisy Company LLC

Seaora Rising Arches LLC

Seaple Advertising Group LLC

Seavan Ice Zander LLC

Sedra Venturing Group LLC

Sefana Glossy Dreams LLC

Segosa Grip Willows LLC

Shadell Jasmine Designs LLC

Shadxy Running Ventures LLC

Shamar Harmony Company LLC

Sibba Outdoors LLC

Sibela Hazel Adventures LLC

Sibina Halo Adventuring LLC

Sible Branding Company LLC

Skarlette Cool Media LLC

Skibbit Lia Media LLC

Skizzy Clay Group LLC

Slaben Ewan Breeze LLC

Slausy Running Freedom LLC

Sln Awesome Company LLC

Sm Ziggy International LLC

Snazzi Charming Marketing

LLC

A-29

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.85 Filed 09/08/26 Page 85 of 89

942

943

944

945

946

947

948

949

950

951

952

953

954

955

956

957

958

959

960

961

962

963

964

965

966

967

968

969

970

971

972

973

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

Snazzler Halo Company LLC

Snibba Crest Ventures LLC

Soarna Rested Advertising LLC

Sobby Furby Creations LLC

Socorro Brave Adventures LLC

Soelis Rainbow Mobile LLC

Soffit Rosey Breeze LLC

Solvita Bloom Company LLC

Sonata Bass Creations LLC

Spacekin Floating Ventures LLC

Spadina Ray Dreams LLC

Spafty Jumping Gardens LLC

Sparcle Genius Harmony LLC

Sparoh Wizard Ambers LLC

Spartan Motivated Company

LLC

Sparvo Max Willows LLC

Squanzo Eli Dreams LLC

Starscal Quinlain Designs LLC

Striving Pines LLC

Stunning Hearts LLC

Suado Jumping Marketing LLC

Suan Harvest Advertising LLC

Subeen Essential Venturing LLC

Subervi Jelling Waves LLC

Subhan Colorful Gardens LLC

Subika Jay Marketing LLC

Subla Majestic Company LLC

Sublam Finn Blooms LLC

Suditty Kind Venturing LLC

Sudyka Lili Venturing LLC

Sunwise Trading Inc

Swagler Jace Media LLC

A-30

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.86 Filed 09/08/26 Page 86 of 89

974

975

976

977

978

979

980

981

982

983

984

985

986

987

988

989

990

991

992

993

994

995

996

997

998

999

1000

1001

1002

1003

1004

1005

1006

Legal Entity Name

Swaleha Jolly Grinds LLC

Swallah Precious Ventures LLC

Swally Pipe Adventures LLC

Sweet Standings LLC

Syaffa Wicked Group LLC

Syafia Flash Advertising LLC

Syafir Tea Dreams LLC

Syafira Kind Makings LLC

Syahiera Overt Paths LLC

Syahira Arching Marketing LLC

Sybble Venice Media LLC

Sykora Flaming Whispers LLC

Symun Theo Marketing LLC

Synera Young Gardens LLC

Syonlette Daisy Harmony LLC

Syrvia Alley Venturing LLC

Syvriel Glowing Pines LLC

Szanja Mug Resources LLC

Szymon Urban Makings LLC

Tabash Arching Ventures LLC

Tabbi Vintage Media LLC

Tadrian Knob Ventures LLC

Taecee Arching Services LLC

Taedza Eden Wings LLC

Taguro Honey Marketing LLC

Taisie Oak Makings LLC

Tajanae Coral Gardens LLC

Taleta Cole Sales LLC

Tamasia Ace Media LLC

Tamazi Intense Creations LLC

Tanelya Noar Skys LLC

Tasch Marketing Corp

Teaggo Motivated Dreams LLC

A-31

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.87 Filed 09/08/26 Page 87 of 89

Legal Entity Name

Num. of

Merchant

Accts.

(MIDs)

1007 Teasley Striving Lands LLC

1008 Teawa Brady Horizons LLC

1009 Tebyna Kinder Marketing LLC

1010 Teiajah Ace Health LLC

1011 Teishan Willow Advertising LLC

1012 Teluxe Misted Blooms LLC

1013 Teppid Misted Brands LLC

1014 Thahmila Pipe Group LLC

1015 Toating Blooming LLC

1016 Tobaria Gentle Ventures LLC

1017 Toetry Rock Ventures LLC

1018 Tofola Laana Media LLC

1019 Tondy Creative Sales LLC

1020 Townsend Trading Inc

1021 Trackle Caress Marketing LLC

1022 Traeson Fam Nights LLC

1023 Tralyn Positive Grinds LLC

1024 Trason Kane Opals LLC

1025 Trenity Positive Hope LLC

1026 Tripzy Popular Ventures LLC

1027 Tuana Fairly Waves LLC

1028 Tuaniz Daisy Media LLC

1029 Tubbekin Wing Advertising LLC

1030 Tulane Harvest Wilderness LLC

1031 Tulisa Oxford Group LLC

1032 Tullian Glow Media LLC

1033 Tuska Wild Creations LLC

1034 Tw Arching Resources LLC

1035 Tykila Hoden Vines LLC

1036 Tylea Kind Flash LLC

1037 Tysenna Classic Venturing LLC

1038 Tysheria Wikka Makings LLC

1039 Ubyan Max Company LLC

A-32

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.88 Filed 09/08/26 Page 88 of 89

1040

1041

1042

1043

1044

1045

1046

1047

1048

1049

1050

1051

1052

1053

1054

1055

1056

1057

1058

1059

1060

1061

1062

1063

1064

1065

1066

1067

1068

1069

1070

1071

1072

Legal Entity Name

Udatta Harvest Creations LLC

Umesha Brave Marketing LLC

Vedica Lacey Marketing LLC

Veerin Positive Company LLC

Veikka Artistic Gardens LLC

Veliin Blast Makings LLC

Veloury Trance Sales LLC

Vemma Cole Breeze LLC

Venting Hope LLC

Vibeke Urban Ventures LLC

Vibular Ava Marketing LLC

Vital Supplements Inc

Vk Zeek Resources LLC

Vosilla Fox Creations LLC

Vozdra Jib Media LLC

Vrati Rose Wisdom LLC

Vsd Image Health LLC

Wadin Ginger Adventures LLC

Wagerah Tate Media LLC

Waizir Fresh Marketing LLC

Walaka Yearny Creations LLC

Walgin Treasured Freedom LLC

Walster Crown Lands LLC

Wamusi Essential Group LLC

Wedika Fancy Media LLC

Weirmo Clay Blooms LLC

Welbie Daring Holdings LLC

Welled Misted Grains LLC

Whazzle Freya Sales LLC

Whitzel Rested Avenue LLC

Woyat Luna Vines LLC

Yaelys Bold Dreams LLC

Yaemi Pine Makings LLC

A-33

Num. of

Merchant

Accts.

(MIDs)

Case 2:26-cv-13303-SKD-EAS ECF No. 1, PageID.89 Filed 09/08/26 Page 89 of 89

Legal Entity Name

1073 Zegory Trendy Harmony LLC

1074 Zolbian Mining Greens LLC

Total

A-34

Num. of

Merchant

Accts.

(MIDs)

1695

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.