BULLETIN: (UPDATED 9:04 P.M. EDT (U.S.A.) The SEC has sanctioned MLMHelpDesk Blogger Adam “Troy” Dooly, amid allegations he accepted money from the Zeek Rewards MLM “program” operated by Rex Venture Group LLC without disclosing to Blog readers and radio listeners that Rex “was paying him” to publicize the Zeek venture.
Section 17(b) of the Securities Act “prohibits publishing, giving publicity, or circulating ‘any notice, circular, advertisement . . . or communication which, though not purporting to offer a security for sale, describes such security for a consideration received or to be received, directly or indirectly, from an issuer . . . without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof,’” the SEC said.
Zeek has been described by the SEC in court papers (August 2012) as a $600 million Ponzi- and pyramid fraud that was selling unregistered securities as investment contracts. Dooly consented to the sanctions and an accompanying cease-and-desist order without admitting or denying wrongdoing.
“In each instance of public relations or promotion in various media outlets, Dooly failed to disclose to his readers and listeners that RVG was paying him for such publicity,” the SEC asserted in an administrative filing dated today. “Dooly believed that, pursuant to a non-disclosure agreement, RVG maintained the exclusive right to determine whether or not to disclose Dooly’s consulting agreement and the amount of compensation. Because RVG did not authorize such disclosure, Dooly declined to reveal his compensation and, in at least one instance, Dooly denied (or misled his audience about) receiving compensation from RVG (apart from reimbursement of expenses) when asked about his compensation during a public radio program.
Dooly, 49, has settled with the SEC by agreeing to pay disgorgement of $3,000, prejudgment interest of $98.81, and civil penalties of $3,000 to the court-appointed receiver in the case. The receiver is Kenneth D. Bell, who is in the process of preparing lawsuits against Zeek winners and insiders.
From the SEC (italics added):
2. From at least April 2012 until August 2012, Dooly served as a paid consultant to Rex Venture Group, LLC (“RVG”), the parent company of ZeekRewards.com (“ZeekRewards”), the self-described “affiliate advertising division” for a penny auction website known as Zeekler.com. ZeekRewards operated as a multi-level marketing program offering subscription memberships to affiliates who then recruited new affiliates and bought and gave away as samples, or sold, bid packages for the penny auction website. Rather than promoting penny auctions, however, RVG primarily marketed ZeekRewards to investors as an opportunity to earn passive income indefinitely through their participation in the program.
3. Under two successive contracts, RVG agreed to pay Dooly $6,000 per month to provide various consulting and public relations services that included, among other things, responding to negative press about RVG and ZeekRewards; providing live reporting from company events; conducting video chat interviews to “promote company, founders, officers, products and culture”; and providing media exposure to facilitate market penetration and improve public perception. In furtherance of the foregoing, Dooly promoted ZeekRewards on his website, MLMHelpdesk.com; posted blog entries and youtube.com videos giving publicity to ZeekRewards; and conducted at least one radio interview promoting the company.
4. Dooly provided the agreed services until ZeekRewards was shut down by the SEC in August 2012 for operating an illegal pyramid and Ponzi scheme. For all his services, Dooly earned $24,000 in consulting fees, but he never received the last $6,000 payment because the company’s assets were frozen (thus receiving only $18,000). Of that total, $3,000 or approximately 17% was attributed to public relations or promotion in various media outlets.
See “EDITORIAL: A Friday Evening In MLM Radio La-La Land” from the PP Blog on June 10, 2012.
The SEC moved against Zeek a little more than two months after Dooly interviewed then-Zeek executive Dawn Wright-Olivares on ACES Radio Live.
Read the SEC order against Dooly.








