On July 5, 2017, the Federal Trade Commission (FTC) entered into a stipulated order to memorialize a settlement with a lead-generation business, Blue Global LLC, and its CEO (Blue Global), in the U.S. District Court for the District of Arizona. The settlement entails both injunctive relief and an award of more than $104 million in damages, all arising from allegations that Blue Global’s “ping tree” lead-generation tool ran afoul of the FTC’s prohibition on unfair or deceptive acts or practices. The settlement comes as the result of the FTC’s complaint filed only days earlier (on July 3).
Blue Global operated a lead-generation business. In its complaint, the FTC alleged that Blue Global operated at least 38 internet domains that offered services to consumers looking for loans. The complaint also alleged that consumers were encouraged to fill out online applications, then “sit back while we do the dirty work” of matching those applications with a “network of more than 100 lending partners.” These applications allegedly required consumers to provide personal information – including their name, address and contact information – as well as sensitive personal information such as Social Security numbers, financial account numbers, and credit and debit card information. Continue Reading