Tag: AdSurfDaily

  • URGENT >> BULLETIN >> MOVING: Andy Bowdoin, AdSurfDaily Lose Appeal Of $65.8 Million Forfeiture Order; Panel Unanimously Upholds District Judge

    Andy Bowdoin

    BULLETIN: Andy Bowdoin and AdSurfDaily Inc. have lost their appeal of a January 2010 order by U.S. District Judge Rosemary Collyer that $65.8 million be forfeited to the government in the August 2008 civil Ponzi scheme case against Bowdoin’s assets.

    The U.S. Appeals Court for the District of Columbia unanimously upheld Collyer, rejecting Bowdoin’s claims he had been denied due process and been hoodwinked by his former attorneys into releasing his claims to the seized cash in January 2009.

    “To begin with, there can be no doubt that appellants meant to withdraw their claims,” the panel ruled. “Their withdrawal motion expressly stated that they wished to ‘withdraw and release with prejudice’ their verified claims and that they ‘consent[ed] to the forfeiture of the properties.”

    “Nor is there any basis to conclude that appellants were somehow tricked into releasing their claims,” the panel continued. “Despite Bowdoin’s protests to the contrary, his own affidavit shows that he understood well that he was receiving no promise in return for relinquishing his claims.”

    Bowdoin’s withdrawal of his claims was “free and deliberate,” the panel ruled.

    Although Bowdoin blamed one of his former lawyers for giving him bad advice, the appeals panel said nonsense.

    “[F]ar from being negligent, appellants’ attorney had sound reasons for recommending that they cooperate with prosecutors by relinquishing their claims,” the panel ruled.

    The ruling means that the government now has title to about $80 million seized in the ASD case. Bowdoin lost a previous appeal for a smaller sum in a separate forfeiture action brought in December 2008, and Collyer ordered the forfeiture of more than $14 million from Golden Panda Ad Builder in July 2009.

    Golden Panda was the purported “Chinese” arm of ASD. It was operated by Clarence Busby, whom the SEC had implicated in three prime-bank schemes in the 1990s, according to court filings.

    About $65.8 million of the total sum seized in the August 2008 forfeiture case was in Bowdoin’s personal bank accounts, including one account that contained more than $31 million.

    Bowdoin initially released his claims to the money in January 2009. By late February of the same year, he sought to reassert his claims as a pro se litigant.  He ultimately retained new counsel, and unsuccessfully sought to have Collyer removed from the case.

    Collyer refused to step down, and issued the forfeiture order for $65.8 million in January 2010. At least one other ASD member also sought unsuccessfully to force Collyer to disqualify herself from hearing the case.

    That member — Curtis Richmond — accused the judge of treason. In a separate case in Utah in 2008, Richmond claimed a federal judge owed him $30 million. That judge, too, refused to step down, finding that a purported Indian tribe with which Richmond was associated was a “sham.”

    Richmond has claimed to be a “sovereign” being, as have other people with ties to ASD.

    Bowdoin was charged criminally with wire fraud, securities fraud and selling unregistered securities in December 2010. The U.S. Secret Service said he was operating a Ponzi scheme that had gathered at least $110 million by disguising itself as a “advertising” business.

    ASD perhaps created as many as 40,000 victims, according to court filings.  The civil portion of the case featured dozens of templated, pro se filings from ASD members who asserted the government had no “EVIDENCE” of wrongdoing.

    Almost three years into the case, some ASD members still are claiming the government has no evidence — despite the fact that the evidence has been discussed in open court and in public filings dating back to August 2008.

    Read the ruling.

  • EDITORIAL: Why The Internet Marketing ‘Syndicate’ Product-Launch Model MUST And WILL Fail — And Why The Trade Should Reject The Mind-Numbing Babble Of Frank Kern

    “[A]nd the poets down here don’t write nothing at all, they just stand back and let it all be.”“Jungleland,” Bruce Springsteen

    There is no delicate way to put it: Frank Kern is among a core group of well-known Internet Marketers who are playing a dangerous and destructive game. If you’ve absently become one of his product-launch automatons and your gradually dulling brain is slow to signal the gag reflex when Kern says things such as “syndicate” is just another word for “trade union,” you may be on the verge of losing your marketing soul.

    Frank Kern and his serial excuse-makers are selling a one-way ticket to the junk heaps of IM history and exposing the entire industry to well-deserved, intense scorn. The only real question that remains is whether that scorn will translate into government scrutiny — and it’s not as though the FTC isn’t well-versed on the subject of Irwin F. “Frank” Kern IV.

    Kern is an advocate for what has become known as the “Syndicate” model of selling products online. Under the Syndicate model, competitors at all levels bizarrely reimagine themselves as strategic partners and divine a construction by which they’re no longer competitors. They agree formally or informally to product-launch schedules and pricing, positioning their ruinous conduct as genuine wisdom. Plenty of people extol the faux virtues of the Syndicate. The most cloddish among them even may suggest you should be executed by shotgun blast for seeing things a different way.

    In spreading the cultish feel and wink-nod idiocy of Syndicate gospel and positioning himself as a control expert, Kern potentially has put the industry on the radar screens of U.S. regulators and law-enforcement agencies while vainly creating a monstrous PR problem. Like Andy Bowdoin of AdSurfDaily infamy, Kern has a never-ending supply of Stepfordian apologists who claim the critics don’t “get it” and are motivated by jealously and hatred.

    What the critics don’t understand, according to the apologists, is that Frank Kern is a genius who is being unfairly labeled a huckster, particularly by the Salty Droid Blog. The people and companies joining Kern . . . well, they’re geniuses, too.

    To imagine the breathtaking gall and sheer lunacy of the “Syndicate” model, imagine a scheme by which 10 top competitors in any product-creation niche would form a sales wedge and magically redefine themselves as strategic partners. These sudden partners then would agree to a product-launch schedule, agree to sell the products of companies or people who just the day before were rivals, agree to sell at a predetermined, premium price point of, say, $2,000, agree to take a turn as the featured seller and thus get most of the proceeds from an individual launch, agree to limit the sales ceiling to just 500 units to create precisely $1 million in sales volume before closing up shop, agree to describe the products as innovative and even life-changing despite the arbitrarily imposed ceiling of 500 sales, agree to reopen sales if order cancellations or chargebacks caused the sales number to fall below 500 — and also agree to create populist fervor by inviting all the freelance salespeople for all of the Syndicate purveyors to become partners in the scheme.

    Or simply imagine Bruce Springsteen selling out both his artistic integrity and his legions of fans by getting Paul McCartney on the phone and telling him there is a way that 10 hand-selected, A-List rockers can split the lion’s share of multiple $1 million pots repeatedly over the course of a year by simply chatting each other up and emailing their fans to invite them to join the scheme. The rockers wouldn’t even have to leave home to do it, wouldn’t have to do a critical assessment of their colleagues’ music, wouldn’t have to purchase the music to determine if it was praiseworthy, wouldn’t have to listen to the music — and could split millions of dollars by simply stating that the most recent $2,000 digital album in the marketplace had come from a legend (and new strategic business partner), so it must be good.

    Nor would they have to burden themselves with thoughts of creating a hit song or doing anything musically innovative or interesting. Meanwhile, they wouldn’t have to hire roadies to haul the equipment and stage from city to city, and wouldn’t have to hire a single new employee or expand the support operation to accommodate a hit song. The person or persons currently employed to answer the phone and take notes would do just fine.

    All the A-List rockers would have to do was digitize a recording, claim it was unique, claim it was worth $2,000, sell it online, limit sales to precisely 500 units, take one turn in the catbird seat, agree to tell their fans to visit the sites of the other nine rockers when it was their turn to sit in the million-dollar catbird seat — and instruct their fans that, they, too, would have the high honor of participating in the new profit-sharing model. A single sale by a fan of a $2,000 recording would net the fan $1,000 — a commission of 50 percent.

    The fans, who  have become a source of free labor, would get to collect the cash so long as an aggrieved customer didn’t charge it back or cancel the order after reflecting on the wisdom of putting $2,000 on a credit card to listen to an acoustic recording of, say, “Thunder Road” or “Let it Be” and sift through hundreds of pages of “special” liner notes and high thoughts from the legends on DVD.

    Springsteen and McCartney, of course, wouldn’t even think of involving themselves in such a harebrained scheme, particularly a harebrained scheme bizarrely mapped out on a whiteboard with a camera capturing it all, a harebrained scheme openly called the “Syndicate” model with the word “GODFATHER” neatly drawn on the whiteboard, and a harebrained scheme positioned in the marketplace as the byproduct of genius.

    Beyond that, they certainly wouldn’t insult their fans by describing them as the B-Team underlings who make the A-Team profits possible, as Kern does.

    The scandal such a harebrained scheme would cause in the recording industry if it gained so much as a day’s worth of traction among established musicians and up-and-comers would bring the business to its knees. There would be front-page stories in the New York Times, even as the National Enquirer rushed special editions to the news stands and members of various Congressional committees were barking orders to their attorneys and staffers to start issuing subpoenas pronto — like right now.

    The Attorney General or maybe even the President of the United States might feel compelled to chime in. No responsible capitalist would tolerate this behavior, and no responsible individual or company would participate in it. In Kern’s world, Jif would be selling peanut butter for Skippy (and others); McDonald’s would be selling hamburgers for Burger King (and others); Apple would be selling tablet computers for Motorola (and others); HP would be selling laptops for Sony (and others); Comcast would be selling satellite subscriptions for DIRECTV (and others); Verizon would be selling cell-phone subscriptions for AT&T (and others); the New York Times would be selling subscriptions for the Wall Street Journal (and others); CNN would be selling ad space for Fox News (and others); and Madonna would be selling old recordings for the estate of Perry Como (and others). The initial beneficiaries later would reciprocate — for all of the “others” on a predetermined schedule.

    Pricing, R&D,  innovation and hiring to accommodate demand would become instant casualties, and the marketplace would be dominated by interchangeable wolves who put up a “Sold Out” sign after artificially constraining the supply not only of their products and services, but also the products and services of their strategic partners. The star-struck fans of the individual brands would become “B-Team” purveyors of the madness, hoping against hope to wrest a commission check in a universe in which the major product-makers all were selling against them and closing up shop within days, if not hours.

    That’s how harebrained Frank Kern’s Syndicate scheme is.

    And yet Kern is accorded the description of genius in the IM sphere, a sphere outside of which such thoughts would be abandoned instantly if formed. The madness and impossibility are obvious to most people outside of the sphere, but somehow get packaged (and pass) as genuine wisdom inside the sphere. Some of the people helping popularize his myth are the very people he’s leading down the primrose path. He calls fans thirsty to make a $1,000 commission the “B-Team.” IM rockstars with big lists who dominate the market and actually are selling against the fans are the “A-Team” in the Syndicate model.

    Even if the U.S. government does not intervene — and  even if the New York Times and National Enquirer never publish a story on the Syndicate and the model doesn’t cause a single blip to appear on the Congressional radar screens — the Syndicate model will fail. It will fail because it must fail.

    And the reason it must fail is that it is a system that requires a fantastical construction and complete suspension of disbelief to thrive. The Syndicate model has nothing to do with genuine innovation and everything to do with avoidance of the responsibilities of success. It is designed to reward men who behave badly before reporting to the site of the next scheme to be rewarded again for behaving badly.

    It is deviously simple. One of its aims is to stay under the radar of the credit-card chargeback monitors by minimizing the universe of possible complainers during any given launch. Another is to keep seats unfilled at the support desk.  The money gets counted and divided off-stage, and the A-Listers move to the scene of the next scheduled hack job — and the process repeats itself.

    There isn’t even the pretense of trying to create a hit. Indeed, the strategy is to quickly siphon $1 million from a collection of 500 suckers authorized by their credit-card companies to charge at least $2,000, close up shop, declare a win and start rehearsing the noise that will attract the next group of 500 suckers who can put at least $2,000 on their individual cards.

    Nothing about the Syndicate model is consistent with a commitment to quality, innovation and  excellence. Simply put, it is the ravenous A-Team vultures leading the hungry B-Team crows to the kill site with the suggestion that some chunks of choice $2,000 flesh will remain after the principal gorging and gluttony end.

    The Syndicate method is an Internet Marketing abomination advanced by a collection of fools who’ve reimagined themselves as coaches, leaders, trainers and deep thinkers. This asinine business approach is utterly ruinous. The stain it leaves behind is indelible, the stench permanent.

    Kern’s Syndicate avoids the challenges business leaders and entrepreneurs with genuine vision embrace: how to put the biggest number of fannies in the biggest number of seats, how to create hits and deliver them to the widest possible audience, how to scale distribution systems to accommodate demand instead of putting artificial constraints on supply, how to instill brand loyalty, how to sell nobly, capably and proudly instead of poisoning the marketplace with gimmickry.

    The Syndicate model is all about avoidance of worthy aims. It is something to be jeered, not embraced — and certainly not emulated. It is the byproduct of vanity and greed run amok, not genius. And it is delivered to your inbox — on cue — by a group of professional hacks. They do it because it works, not because it is good. Period.

    Unlike Bruce Springsteen, the people delivering it to you are poets of the most awful kind: They just stand back and let it all be. What’s worse, they do it by design.

    Make no mistake: No savior graces these miserable Internet Marketing streets, which are dominated by hacks who are pretenders to the title of genius.

    “You can hide ‘neath your covers
    And study your pain
    Make crosses from your lovers
    Throw roses in the rain
    Waste your summer praying in vain
    For a savior to rise from these streets,” “Thunder Road,” Bruce Springsteen

  • PRIMING THE PUMP: TalkGold, MoneyMakerGroup Publish String Of ‘I Got Paid’ Posts From Club Asteria Members; ‘It’s No Scam Now,’ Poster Declares

    Two forums listed in federal court documents as places from which Ponzi schemes are promoted have published a series of “I got paid” posts from commentators who say they are members of Club Asteria (CA).

    The “I got paid” posts on MoneyMakerGroup and TalkGold appeared after CA members had complained publicly about not getting paid and fretted about the firm’s slow-loading website.

    Both the complaints and the “I got paid” posts lead to questions about whether CA’s revenue stream is polluted by Ponzi proceeds.

    “It’s no scam now,” a poster on MoneyMakerGroup confidently opined after the “I got paid” posts began to appear. A link under the comment led to the affiliate’s CA registration page,  which implied prospects were receiving guidance from an “Investment” company or professional financial adviser.

    This Club Asteria affiliate's sign-up page is accessible from a link on the MoneyMakerGroup Ponzi forum. The registration page implies that CA prospects are receiving guidance from a professional "Investment" company or adviser. In May 2010, the U.S. Postal Inspection Service identified MoneyMaker group as a site from which the alleged Pathway To Prosperity Ponzi scheme was pushed. Pathway To Prosperity gathered more than $70 million, creating about 40,000 victims from "all of the permanently inhabited continents of the world," according to federal court filings in the Southern District of Illinois.

    Separately on MoneyMakerGroup, another CA poster declared, “I am in over 35 forums and everyone is posting paid.”

    In July 2010, the Financial Industry Regulatory Authority (FINRA) issued an alert about investment scams and how they spread on the Internet.  Separately, court filings from May 2008 in the SEC’s case against an alleged $70 million Ponzi scheme known as Legisi include a handwritten note from a Legisi enrollee.

    “Money Maker Group.com,” the note read in part. The note was part of a 267-page evidence exhibit the SEC presented a federal judge. The SEC alleged that Legisi created thousands of victims.

    On both MoneyMakerGroup and TalkGold, posters have repeatedly noted that CA payments come from “Asteria Holdings Limited (Hong Kong).”

    CA says it accepts money through SolidTrustPay and AlertPay, both of which are Canada-based payment processors. Both companies are referenced in federal court filings in the alleged AdSurfDaily Ponzi scheme, which the U.S. Secret Service said gathered at least $110 million and created as many as 40,000 victims.

    ASD also was promoted on MoneyMakerGroup and TalkGold. Solid Trust Pay and AlertPay also are referenced in court filings in the Pathway To Prosperity Ponzi case.

    CA also notes that it conducts business with CashX, another Canadian firm. When the ASAMonitor Ponzi scheme and criminals’ forum mysteriously vanished in October 2010, the site’s landing page initially redirected to CashX.

    Some CA members are selling the “program” by describing what it is not. It is not a Ponzi scheme, and it is not an investment, they claim.

  • URGENT >> BULLETIN >> MOVING: Federal Judge Refuses To Toss Indictment Against AdSurfDaily President Andy Bowdoin; Ruling May Deal Crushing Blow To ‘Autosurf’ Trade; ‘These Alleged Facts Smack Of An Investment,’ Court Says

    Andy Bowdoin

    BULLETIN: U.S. District Judge Rosemary Collyer has rejected AdSurfDaily President Andy Bowdoin’s sweeping claim that the indictment against him should be dismissed because ASD met none of the three prongs of the “Howey Test” under federal securities laws and a Supreme Court precedent that determines what constitutes an “investment contract.”

    Collyer’s refusal to dismiss the indictment may deal a crushing blow to autosurf operators monitoring the ASD case from the murkiest corners of the Internet and hoping that the Howey Test somehow could provide a legal cover to line up suckers and steal millions of dollars from them.

    In a pointed, 15-page memo, Collyer walked through all of Bowdoin’s Howey challenges, concluding that a jury reasonably could find that ASD met all three prongs. Specifically, the judge ruled that a jury could find that ASD members were “investing,” that there was a “pooling of investment funds, shared profits, and shared losses” and that “ASD members were paid based on the efforts of others.”

    Citing evidence that some ASD members apparently refuse to believe exists despite the fact it is part of the public record of the case, Collyer ruled that part of ASD’s current defense was at odds with statements that appeared on ASD’s own website and in offering materials.

    “Based on the allegations set forth in the Indictment, the evidence already before the Court, and the government’s proffers of expected trial evidence, the Court finds that the allegations, if proven, would be sufficient to permit a jury to find that ASD members were investing,” Collyer ruled.

    Dozens of ASD members claimed in pro se court filings in 2009 — when the case was in civil court — that “NO EVIDENCE” existed against ASD.

    Collyer’s ruling also addressed the subject of payments to members, which ASD called “rebates.”

    “Contrary to Mr. Bowdoin’s characterization of the ASD business, ASD’s promise to pay back 125% of the value paid to ASD by an advertiser strongly indicates that the joining of ASD via the purchase of an ‘advertisement’ on the rotator in fact constituted an ‘investment for a financial return,” Collyer ruled.

    And, Collyer noted, “these alleged facts smack of an investment.

    “Indeed,” she continued, “the government proffers that Mr. Bowdoin awarded ad packages to employees in the way that an employer awards bonuses. It argues that Mr. Bowdoin and the employees of AS[D] treated the ‘ad packages’ as shares from which they could expect to earn returns.”

    Collyer cited passages allegedly spoken by Bowdoin himself in offering materials. Meanwhile, she rejected Bowdoin’s claim that the government’s assertion that he was selling “investment contracts” was unconstitutionally vague.

    “Mr. Bowdoin’s attack on the facial vagueness of the term ‘investment contract’ as a type of security covered by the Securities Act is without merit,” she ruled. She noted that, despite the fact Bowdoin had argued that ASD met none of the Howey prongs, “Bowdoin did not provide evidence through affidavits or otherwise as to how ASD actually operated — or any other basis — from which the Court could draw legal conclusions on whether ASD operations met the Howey test.”

    The prosecution, on the other hand, had supplied actual evidence, had entered it in the record of the case and provided a basis for the court to make preliminary determinations about what a jury potentially could find after considering the evidence, according to the ruling.

    Bowdoin’s own words from promos appeared in the ruling. Although he argued to Collyer earlier this year that money sent in by members did not constitute an investment, “[d]irect statements from ASD seemingly contradict this defense,” the judge ruled.

    Citing evidence entered by the government, Collyer pointed to a passage on ASD’s own website that said, “[a]dvertisers will be paid rebates until they receive 125% of their ad packages.”

    And Collyer noted there is both written and recorded evidence, including at least one email attributed to Bowdoin is which he allgedly wrote, “[l]et’s don’t [sic] use the words investment and returns. Instead, lets [sic] use ad sales and surfing commissions. The Attorney Generals in the U.S. don’t like for us to use these words in our program.”

    Prosecutors have argued for nearly three years that ASD engaged in wordplay to skirt securities laws and that Bowdoin was well aware that he was selling securities.

    Bowdoin’s “motion to dismiss the Indictment ignores the teaching of the Supreme Court — that courts should examine the substance, not form, of a transaction and evaluate its economic reality,” Collyer ruled.

    Read the ruling.

     

  • BULLETIN: Federal Judge Declines To Transfer AdSurfDaily Ponzi Case To Florida, Says Andy Bowdoin Will Be Tried On Criminal Charges In District Of Columbia

    Andy Bowdoin

    BULLETIN: Describing the AdSurfDaily Ponzi case as one with a “tortured history” now dating back years, U.S. District Judge Rosemary Collyer of the District of Columbia has refused to transfer the criminal case against ASD President Andy Bowdoin to Florida.

    Bowdoin, who lives in Florida, had argued for the transfer more than a month ago, citing his health problems, his wife’s health problems and inconvenience to witnesses as reasons to move the case.

    In a 16-page opinion, Collyer said no.

    “Mr. Bowdoin’s bald assertions of witness expense and inconvenience fail to counter the presumption that a criminal prosecution should be retained in the district where the indictment was returned, in this case, Washington, D.C.,” Collyer found Wednesday.

    And although Collyer expressed sympathy for various medical issues with which Bowdoin’s wife is contending, the case will remain in Washington, the judge ruled.

    Read Collyer’s 16-page opinion.

  • PP Blog Operated By ‘Self-Appointed Idiot,’ Fan Of Nonexistent Nation Of ‘New Utopia’ Suggests; Blog Invited, Then Uninvited To Ceremony At ‘Palace’

    A man using the anonymous identity of “Mr. Protector,” a hotmail address and an IP in the Netherlands has scolded the PP Blog for a story that described “New Utopia” as a nonexistent nation in the Caribbean.

    New Utopia is the fanciful “tax haven” allegedly dreamed up by Lazarus R. Long, an American who declared himself a “prince” and hatched a plan to form a “new country” that would “rise from the Caribbean on giant concrete platforms built on an underwater land mass,” according to the SEC.

    Using the phrase “selfappointedidiotyouare” [Self Appointed Idiot You Are] apparently to chide the PP Blog for giving less than favorable coverage to the nonexistent nation, the man sent an email to the Blog this morning that both invited and uninvited the Blog to view New Utopia’s “Palace” on a date uncertain.

    “How about we print your words out about New Utopia in size 12 font and then, when New Utopia Construction begins, we can invite you there in front of the Palace and watch you eat the words and the paper they are written on?” the man wrote.

    In the very next paragraph, however, he uninvited the Blog.

    “[H]ow will we know to not allow you to visit The Principality of New Utopia?” the man inquired. “We will find a way of that be assured.”

    Although the context in which the man used the word “Protector” was unclear, it is a word that has been used by members of certain so-called “private associations” that challenge the authority of governments to regulate commerce and the securities industry.

    The AdViewGlobal (AVG) autosurf, for example, identified a member as a “Protector.” AVG has been identified in a racketeering lawsuit as an offshoot of the AdSurfDaily (ASD) autosurf. The lawsuit was filed by members of ASD.

    ASD was accused separately by the U.S. Secret Service of operating a $110 million Ponzi scheme and of committing wire fraud, securities fraud and engaging in the sale of unregistered securities.

    On Feb. 18, the PP Blog reported that federal agents — working with law-enforcement partners worldwide — had broken up a fraud ring operating in part from Florida, Costa Rica and elsewhere.

    Among the defendants charged both criminally and civilly was Jonathan R. Curshen. Curshen has been described as the one-time “honorary counsel” of St. Kitts-Nevis to Costa Rica and a purported “consulate” to New Utopia.

    New Utopia has its own website from which it sells an “International Drivers license” issued by New Utopia for $140.

    According to court records, the nonexistent principality is said to be located undersea “approximately 115 miles west of the Cayman Islands.” It would rise out of the water only after concrete stilts were erected and an above-sea base were anchored to a submerged land base.

    New Utopia, indeed, will rise, according to “Mr. Protector,” the author of the email sent to the PP Blog this morning.

    “Too many of us have worked too hard for too many years to just abandon this project,” he wrote.

    “Your ‘reporting’ does not help,” he complained.

    Long, also known as Howard Turney, was accused by the SEC in 1999 of promoting a fraudulent bond offering over the Internet to fund his upstart country. He settled with the agency in 2000 and was assessed a penalty of $24,000, but the penalty was waived.

    “Prince” Long has used the New Utopia website to complain bitterly about anonymous critics on the Internet. Whether “Mr. Protector” risked a royal scolding from the “Prince” for using an anonymous identity to contact the PP Blog was not immediately clear.

  • THIS AFTERNOON: 9 Visitors From 6 Countries Arrive At PP Blog Within 5 Minutes; All Pull Exact Same September 2010 Story About MPB Today Multilevel Marketing Program, Then Vanish

    In a highly unusual — and statistically improbable occurrence — nine visitors from six countries arrived on the PP Blog within five minutes today and sought unsuccessfully to pull the exact same story on the MPB Today multilevel marketing program. With the apparent aid of a script, all of the visitors also attempted unsuccessfully to pull a story about an alleged Ponzi caper in New Jersey.

    The MPB Today story was nearly six months old, and the New Jersey story was nearly seven months old. The visitors left as quickly as they came, and appear not to have sought to pull any other stories.  Although it is common for individual visitors to pull “old” stories, it is decidedly uncommon for multiple visitors to attempt to pull the same “old” stories from the Blog’s archives of nearly 1,100 stories virtually simultaneously.

    Because the pattern suddenly ceased and no other individual reader outside the subset of “sudden” visitors sought to pull the same stories, it does not appear likely that the URLs for the stories appeared on a common website today through which visitors all sought to load the same pages virtually simultaneously.

    Readers routinely post links to the PP Blog on forums. But as the forum posts age and are buried by new posts, the Blog receives fewer and fewer visits from the older links.

    MPB Today is based in Florida. It purportedly operates a “grocery” program, and the U.S. Department of Agriculture said last year that it was investigating certain claims made about the firm.

    The circumstances and motives surrounding the visits were not immediately clear. The Blog recorded visits from IPs in the United States, Russia, Brazil, Spain, Thailand and South Korea. Logs suggest a script of some sort was used, and that the visitors sought to pull an MPB Today story that was published Sept. 25.

    Logs also suggest that the same visitors sought to pull  a story that appeared Aug. 12 about Eli Weinstein. Weinstein was charged in an alleged Ponzi caper that may involve $200 million or more.

    The PP Blog’s Weinstein story included a reference to Nevin Shapiro, who was arrested in New Jersey in April 2010 on charges of running an $880 million Ponzi scheme involving a bogus wholesale grocery business.

    In October and November, the PP Blog experienced sustained DDoS attacks. During one three-hour window, the Blog received more than 6 million “hits.” The attacks were reported to law enforcement, and coincided with the Blog’s reporting on MPB Today and Ponzi scheme and criminals’ forums.

    The PP Blog also has been subjected to email spoofing, virtually relentless spamming, YouTube attacks, threats of “war” and threats to start “fires” because of its reporting about the alleged ASD Ponzi scheme, and a false registration to a “program” in which the Blog was referred to as “Rat Bastard.” The “Rat Bastard” reference appears to have been associated with a cash-gifting program.

  • EDITORIAL: Salt Lake Tribune Publishes Series On MLM; Reader Claims Reporter A ‘Broke’ Purveyor Of ‘Negativity’; Separately, Len Clements (IQ-155) ‘Assumes’ Reporter Was ‘Duped’ By The ‘Flimflam’ Of MLM Critics

    We highly recommend an even-handed series the Salt Lake Tribune published on the subject of multilevel marketing in Utah. (Link appears at bottom of post.) The series includes comments from MLM enthusiasts, the Direct Selling Association, attorneys for well-known MLM companies, MLM critics and the FTC.

    Meanwhile, the series shows that MLM has some political clout, and points out that Utah has more MLM firms per capita than any other place in the United States. It also publishes data supplied by a number of companies.

    The series is accessible through a “State of the Debate” Blog entry by George Pyle, a longtime journalist who was a finalist in 1998 for the Pulitzer Prize in Editorial Writing. Don’t miss the cartoon that accompanies Pyle’s presentation of the links to the stories. The cartoon pokes fun at the ready supply of over-the-top MLM sales pitches.

    Pyle’s Blog entry does not hold forth on the subject of MLM; it simply introduces the series. Readers can draw their own conclusions after clicking on the links and reading the stories

    The series consists of articles by Tribune reporters Steven Oberbeck, Matt Canham, Tom Harvey and Kirsten Stewart.

    MLM Fans (Again) Demonstrate Lack Of PR Savvy

    As often is the case when media outlets tackle the subject of MLM, the post-publication opinions of the Tribune’s readers were strongly divided. MLM perhaps always will be a “scam” to one side in the long-running debate — and a marvelous thing to the other. One of the best things about the series is the comments submitted by readers. The PP Blog believes the comments submitted by MLM enthusiasts are the most instructive.

    Although the PP Blog publishes relatively few stories about MLM, the ones it has published have been met with organized (and bizarre) resistance. After publishing a series of stories on the MPB Today “grocery” MLM last summer and fall, supporters of the firm arrived on the Blog to call MPB Today’s critics  “roaches,” “IDIOTS,” “clowns,” “terrible” people, “misleading” people, people who have led a “sheltered life,” people who have been “chained up in a basement,” people who have “chips” on their shoulders, spewers of “hot air,” “naysayers,” “complainers,” “trouble maker[s]” and “crybabies.” (See this editorial.)

    They were doing this on behalf of a business that had any number of reps who apparently licensed themselves to film commercials inside Walmart stores and to use Walmart’s intellectual property to drive dollars to MPB Today. At least two reps declared it best to do business with them because other MPB Today affiliates were lying scammers. Meanwhile, another MPB rep sought to drive business to the firm by creating a script that depicted President Obama and Michelle Obama as welfare recipients aspiring to eat dog food. The President and Secretary of State Hillary Clinton were cast as Nazis, with Obama subordinate to Clinton, who also was cast as a drunk.

    One thing that continues to drive criticism of MLM is the bizarre  behavior of some of its supporters. This behavior can be described fairly as cult-like, Stepfordian, incongruous, supremely awkward and monumentally ham-handed. It is utterly predictable, and the lack of PR savvy contributes to the industry’s poor reputation.

    In response to Oberbeck’s story, which referenced the disclosure statements of a number of well-known companies and reported that “nearly all” distributors “will fail,” one reader surmised in a Comments thread that the Tribune reporter was “broke” and driven by “negativity.” It was a familiar refrain.

    Naturally the comment precluded the possibility that the reporter had any pure motives such as enlightening the Tribune’s readership about some of the realities of MLM. How the industry ever could hope to elevate the debate by attacking the messenger — in this case, Oberbeck — is left to the imagination.

    What happened at the Tribune, however, is hardly unique.

    After the U.S. Secret Service seized tens of millions of dollars in the AdSurfDaily Ponzi MLM case in 2008, some ASD affiliates advanced theories that the agency’s work was the work of “Satan” and that a Florida television station should be charged with Deceptive Trade Practices for carrying news unflattering to the company. They later complained that reporters seemed disinclined to put much stock in their point of view.

    Prosecutors said ASD created as many as 40,000 victims while gathering at least $110 million in a classic Ponzi scheme put together by Andy Bowdoin, a recidivist felon. Rather than distancing themselves from Bowdoin, some ASD members reportedly sent him brownies and delicious baked goods. Others signed a petition calling for the prosecutors to be investigated. Still others advanced a theory that the U.S. Secret Service was guilty of interference with commerce. The key prong of the theory was that all commerce is legal as long as both parties to a contract agree it is legal, a position that would legalize (and legitimize) Ponzi schemes, slavery, human trafficking and narcotics trafficking, among other crimes.

    Len Clements Lectures Tribune Reporter

    Well-known MLM aficionado Len Clements, who advertises his IQ of 155, apparently believed that Oberbeck’s story in the Tribune deserved a response in the form of a five-page “open Response Letter.”

    Clements noted in his “open Response Letter” to Oberbeck that he assumed the reporter had been “duped” by MLM critics Robert FitzPatrick and Jon Taylor — and Tracy Coenen before them.

    In his “open Response Letter,” Clements accused Fitzpatrick, Taylor and Coenen, a forensic accountant, of being “anti-MLM antagonists” who were “slathering” the profession with misplaced criticism.

    “Slathering” is a good and powerful word. It doesn’t describe the efforts of FitzPatrick, Taylor and Coenen to educate the public about the perils of endless-chain recruiting schemes, but it’s a good word nonetheless. We’re glad that Clements, who advertises his IQ of 155, used it; it gives us a chance to use the word “unctuous.”

    Indeed, we view Clements’ “open Response Letter” as “unctuous.” It begins with a doozy of a misplaced modifier, but that’s only worth a brief mention — and only because Clements advertises his IQ of 155. Plenty of people with high IQs don’t have command of grammar, which likely bores them to tears.

    The reason we’re using the word “unctuous” to describe Clements’ “open Response Letter” is that it practically drips with stinking, vomitous verbal slime. It’s the sort of passive-aggressive letter in which the insult is deeply embedded in the vomit of the opening lines, with the vomit theoretically neutralized later with softer words that are supposed to demonstrate Clements’ sincere desire to be helpful.

    Any “professional journalist” should be interested in “accurately, fairly and responsibly” presenting the topics they write about, Clements unctuously points out at the top of the letter, setting himself up as a journalism cop. After implying that Oberbeck isn’t a pro and hasn’t done his homework, Clements goes on to trash the story and the MLM-unfriendly sources used in the story.

    The roadmap to professional reporting about MLM as provided by Clements in his “open Response Letter” includes at least 10 footnotes. It was submitted to the newspaper in the form of a link to a  PDF that contains multiple link’s to Clements’ website. The document is unctuously titled “OberbeckResponse” and asserts that Oberbeck’s reporting “seem[s] to betray any objective research and analysis of the subject.”

    Clements, who started out by lecturing Oberbeck on what constitutes professional journalism, eventually positions himself as the sincere cure for what purportedly had dragged down the quality of the reporter’s work.

    “Should you ever need assistance in researching any topic related to the field of multilevel marketing I sincerely hope you will contact me,” Clements un-vomits to Oberbeck at the conclusion of the “open Response Letter,” after earlier coming out of the gate with embedded slime, a lecture on professionalism and an attack on sources used by the reporter as “remarkably ignorant” people and the purveyors of “flimflam.”

    At least Clements didn’t summon his advertised IQ of 155 to call them “roaches” or to declare that Oberbeck was “broke.” He merely relied on his unctuousness. In doing so, he demonstrated once again that MLM often is its own worst enemy.

    A five-page, de facto letter to the editor — one filled with slime reimagined as a sincere effort to be helpful and 10 footnotes? This is supposed to beneficial to the trade?

    Little wonder that MLM finds itself the topic of constant criticism.

    Access the Tribune’s MLM series at this gateway page.

  • SPECIAL REPORT: U.S. Counter-Terrorism Unit Intercepted Communication From Person With AdSurfDaily Ties In 2009; Intended Recipient Was Imprisoned Felon Associated With Scheme In Which Prospects Were Told They Could Rip Off Government’s Medicaid Program

    EDITOR’S NOTE: Lower in this story, the names of AdSurfDaily President Andy Bowdoin and other individuals appear. They are NOT the individuals referenced in the government communiqué described below.

    UPDATED 12:50 P.M. ET (U.S.A.) The name of a person known to have used at least two names and to have AdSurfDaily ties appears in a law-enforcement communiqué issued in 2009 by the counter-terrorism arm of a U.S. government agency that employs a method of monitoring both domestic extremists and individuals with known links to international terror groups, the PP Blog has learned.

    At least one communication from the person was intercepted by the government and used as part of a raw intelligence report that includes summaries on the actions of dozens of individuals with alleged ties to al-Qaida, Hezbollah or homegrown extremist groups in the United States. The communication does not reference ASD, but includes a reference to a second person known to have an ASD tie.

    The sender of the communication was described as a provider of fraudulent documents typically associated with tax schemes operated by antigovernment extremists. Meanwhile, the intended recipient was an individual known to have promoted various forms of financial fraud, including a scheme in which prospects were told they could qualify for Medicaid by hiding assets and making themselves artificially poor.

    Medicaid is a federal health-services program for low-income Americans. It is administered by the states.

    The PP Blog established the identities of both individuals with ASD ties by examining a variety of public records and other documents.

    ASD's Andy Bowdoin

    Neither person is in state or federal custody, but it is clear that both the federal and state governments are aware of their activities and have worked to disrupt them. The intended recipient of the communication is in federal custody for a crime unrelated to ASD.

    Both individuals with ASD ties have a tie to a third person with ASD links, according to the Blog’s analysis of records.

    Owing to the sensitive nature of the communiqué, the Blog is declining to identify the individuals with ASD links and the agency. It also is declining to publish specific details such as quoted material, dates, times, telephone numbers and addresses. The communiqué demonstrates that the United States has identified particular areas in which it believes terrorism could fester and is monitoring oral, electronic and printed communications in a specific context.

    The communiqué devotes more than a full page to the topic of the communication intercepted from the individual with ASD ties.

    Based on its research, the Blog is reporting today that the person with ASD ties whose communication was intercepted is an American believed to have ties to a network of domestic extremists immersed in a sea of organized corruption. The person has an arrest record for a nonviolent crime, but also has been associated with bids to intimidate people and cause them financial harm. Records show that the person has used at least two names.

    News of the disturbing developments comes even as some ASD members are blindly asserting that ASD was a wholesome enterprise and making broad claims that any ties to terrorism have been ruled out. ASD has been implicated in an alleged international Ponzi scheme that gathered at least $110 million.

    Despite an alleged concession by ASD President Andy Bowdoin that the company was operating illegally and a new assertion by the government that Bowdoin and unnamed “others” ventured to Costa Rica in the spring to 2008 to get the lay of the land for an upstart “autosurf” enterprise, some members are soliciting funds to challenge a U.S. Secret Service affidavit that led to the seizure of tens of millions of dollars from Bowdoin’s personal bank accounts in August 2008.

    Bowdoin’s own bid to challenge the affidavit failed in November 2008, more than two years ago.

    In December 2010, federal prosecutors asserted that ASD had the ability to accept money from e-Bullion, a shuttered California payment processor whose operator — James Fayed — has been charged with arranging the contract murder of his wife.

    Pamela Fayed, who was stabbed to death in a parking garage, was a potential witness against her husband. James Fayed is believed to have used e-Bullion to facilitate multiple Ponzi schemes, including a scheme hatched by a New York man — Abdul Tawala Ibn Ali Alishtari — who later pleaded guilty to financing terrorism.

    Like ASD’s Bowdoin, Ali Alishtari claimed to have received an important award for his business acumen. And Ali Alishtari’s scheme, known as FEDI, was pushed by an individual convicted in a separate Ponzi scheme and sentenced to federal prison. Payments from the scheme were called “rebates,” the same terminology adopted by ASD to describe payments to members.

    “In enriching himself, Alishtari displayed a deliberate disregard for the financial and personal security of others,” U.S. Attorney Preet Bharara of the Southern District of New York said in September 2009.

    e-Bullion’s name also is referenced in court filings in the Gold Quest International (GQI) Ponzi scheme, which gathered up to $29 million, according to U.S. and Canadian regulators. GQI, which operated from Las Vegas, falsely claimed to be immune to U.S. law and to enjoy purported “sovereignty” extended by a North Dakota  “Indian” tribe.

    One of the unusual elements of the GQI case was a claim that the purported sovereignty was portable, shielding the purveyors from prosecution anywhere.

    A New Plan To Do Battle With The Government

    ASD member Todd Disner, one of dozens of unsuccessful pro se litigants in the civil portion of the ASD case in U.S. District Court for the District of Columbia, now wants ASD members to come up with money to fund a lawsuit in Florida that would challenge the U.S. Secret Service affidavit in the District of Columbia that led to the seizure of $80 million in the ASD case, according to a recording of a Feb. 22 conference call.

    “We were dragged down the river by our government agents, and the rest is history,” Disner told listeners.

    “There might be an opportunity for us to throw a few punches of our own,” Disner said. “We’ve been on the ropes for three years now, and we’d like to start swinging back if we could.”

    The opportunity to battle back after a fatiguing and demoralizing three years on the ropes would cost ASD members a combined total of about $10,000, according to people who listened to the call.

    After the call, some ASD members received an email that purported that an ASD “terrorism connection has been ruled out.” The email, sent by an ASD member who did not use a full name, did not describe who within the government had ruled out a terrorism link.

    Disner, who claimed he was “excited” about the prospect of suing the government to overturn the ASD forfeiture, also claimed he’d been advised on the complex legal issues by Dwight Schwetizer, whom he described as a fellow ASD member, friend and “very accomplished attorney” who is “not practicing law now.”

    “They’re just going to try and try to keep that money,” Disner asserted. “They seized the money improperly, and if they release it then everybody’s included.”

    The government, however, already has put in place a restitution program that would compensate crime victims from seized funds. An apparent linchpin of the new strategy outlined by Disner is a theory that the government restitution program somehow opens the door for ASD members not only to reverse the judicially declared forfeiture, but also to receive damages for an unwarranted government intrusion. Schweitzer also provided commentary on the call.

    For its part, the government says ASD was engaging in felonious wire fraud and securities fraud by disguising itself as an “advertising” business while operating a $110 million Ponzi scheme from Florida that had affected tens of thousands of people globally. Just last week prosecutors advised a federal judge that Bowdoin, who was arrested in December, had ventured to Costa Rica in the spring of 2008 to look for a way to start an offshore Ponzi scheme.

    Disner’s conference call was held just a few days after the latest damaging claims against ASD became public. The government filed the new claims against ASD on Feb. 18, the same day it announced a major prosecution against an alleged Costa Rican money-laundering operation that was accused of engaging in international securities fraud and siphoning millions of dollars in penny-stock schemes.

    The U.S. government, using its individual agencies and the Financial Fraud Enforcement Task Force created by President Obama in 2009, has been targeting various forms of fraud, including HYIPs, penny-stock capers, Forex schemes, tax schemes and domestic and offshore crime targeted at U.S. citizens.

    In some cases, victims have been counted by the tens of thousands — enough to fill the nation’s largest sports stadiums. ASD was purported to have 120,000 members.

    Some ASD members have called for a “militia” to storm Washington, D.C. Others have called for a federal prosecutor to be placed in a medieval torture rack. Still others have called for prosecutors and investigators to be charged criminally and sued civilly for their efforts to disrupt what the government has described as a classic Ponzi scheme operated by Bowdoin, a recidivist felon.

  • PROSECUTION BOMBSHELL: Accused Ponzi Schemer Andy Bowdoin Traveled To Costa Rica In 2008 To Explore Option For Offshore ‘Autosurf’ Firm; AdSurfDaily’s Internal Software System Identified Member Payouts As ‘ROI,’ Despite ASD Claim It Was Not Offering Investments

    Andy Bowdoin

    BULLETIN: UPDATED 9:29 P.M. ET (U.S.A.) Prosecutors have advised a federal judge that AdSurfDaily President Andy Bowdoin and unnamed “others” traveled to Costa Rica in the spring of 2008 to get the lay of the land for an offshore autosurf that would be “another version” of ASD.

    The alleged trip occurred less than two years after the SEC accused 12DailyPro, an autosurf based in North Carolina, of selling unregistered securities in the form of investment contracts, prosecutors said.

    The explosive claim Bowdoin ventured offshore to pursue the creation of an ASD satellite may signal that the government views ASD not only as a Ponzi scheme, but as a business that deliberately sought to dial up its efforts to circumvent U.S. laws and create an even greater Ponzi war chest by establishing a footprint outside the United States.

    Since at least February 2006, the SEC has described the autosurf business model as anathema and a form of obvious securities fraud. Bowdoin was well aware of the SEC lawsuits and scrutiny domestic autosurfs such as 12DailyPro, PhoenixSurf and CEP had sparked in 2006 and 2007, prosecutors said.

    Meanwhile, investigators have evidence that shows ASD’s internal software system described payments to members as “ROI,” an acronym that that means “return on investment,” prosecutors said.

    The assertions by prosecutors — if proven true — may undermine ASD’s defense strategy of arguing it was an “advertising” program, not an “investment” program.

    Prosecutors did not identify by name the surf allegedly contemplated for Costa Rica. In late 2008 and early 2009, a surf with close ASD ties known as AdViewGlobal (AVG) debuted. The launch occurred about four to five months after the U.S. Secret Service seized $65.8 million from the personal bank accounts of Bowdoin in August 2008.

    Bowdoin’s trip to Costa Rica occurred before the ASD seizure, prosecutors said. If true, the claim could be used to prove ASD was seeking an exit plan even before the Secret Service raid. In 2008, prosecutors asserted that Bowdoin had moved millions of dollars offshore and talked about purchasing a home in another country.

    AVG purported to operate from Uruguay, but had servers that resolved to Panama. Some ASD members have said Bowdoin was a silent partner in AVG.

    Prosecutors described the “ROI” development as just another ASD incongruity, advising U.S. District Judge Rosemary Collyer that Bowdoin was well aware that a serious securities challenge could be made against his firm and chose to ignore the risk and misinform members.

    Beginning as early as January 2007, “[O]thers warned Bowdoin that ASD was nothing more than an investment scheme and that the program needed to be changed if it were to operate legally,” prosecutors argued in a brief to Collyer. “Bowdoin did not heed that advice and continued unabated in offering members higher returns than banks or brokerage firms. Moreover, based on his prior criminal experience, Bowdoin was well aware of the securities regulations and knew he was offering a security.”

    Any argument that ASD was not offering “investment contracts” as defined under the Howey Test should be dismissed, prosecutors said, arguing that ASD meets all three prongs of the Howey Test.

    Bowdoin sought about three weeks ago to have the criminal charges filed against him dismissed, arguing that ASD met none of the three Howey prongs.

    Nonsense, prosecutors said.

    ASD’s advertising was “merely a cover for Bowdoin’s sale of a get rich quick scheme,” prosecutors said.

    And prosecutors also cited other alleged proof that ASD was running an investment program — namely that some employees were being paid in ASD “ad packs.”

    “Bowdoin and the employees of ASD treated the ‘ad packages’ as shares from which they could expect to earn returns,” prosecutors argued.

    Prosecutors also pointed out a section of ASD’s Terms of Service that stated the firm “will” pay members 125 percent of the money they paid in. At the same time, prosecutors quoted video evidence of Bowdoin wooing members by focusing on ASD as a money-making opportunity.

    Bowdoin, prosecutors said, eventually limited the amount of money investors could pay ASD “because he did not want any one member dominating the return pool.”

    The prosecution’s assertions occurred against the backdrop of dozens of competing claims by ASD members who filed pro-se pleadings in the civil portion of the case that asserted the government had no “EVIDENCE.”

    Members made the claim despite the fact that some of the evidence against ASD had been part of the public record for more than a year at the time the claims were made in 2009.

    In a footnote to Collyer, prosecutors said they’d be happy to present the actual video of Bowdoin making various claims instead of simply quoting from a transcript.

    “[T]he government’s review of ASD’s bank records revealed that of the approximately $31 million ASD paid out to early members, more than 98% of that money came from monies paid to ASD by other members,” prosecutors said.

    Although ASD claimed to have funding sources beyond advertising payments made by members  — things such as banner ad sales and ebooks  — those outlets provided only de minimis revenue, prosecutors argued.

    “Each night, there was nothing more than new members funds to divide among existing members,” prosecutors argued. “Moreover, Bowdoin himself admitted, on video, that members funds are pooled and they will share in the profits and losses equally.

    “Specifically, Bowdoin, in the ‘New Member Success Video,’ claimed that “[w]hen sales increase, the rebates increase. When sales decrease the rebates decrease . . .”

    “Clearly Bowdoin, through ASD, was pooling all of the member’s funds which allowed him to make the requisite return payments,” prosecutors said.

    Prosecutors also argued that the ASD case should remain in Collyer’s courtroom in the District of Columbia. Bowdoin argued that the case should be transferred to Florida, in part because he and many witness live there.

    Although prosecutors agreed that many prospective witnesses live in Florida, they argued that witnesses reside in multiple jurisdictions because of the national and international scope of the case.

    In addition to Floridians, witnesses the government may present hail from the District of Columbia, North Carolina, Nevada, Oklahoma, Iowa and  elsewhere, prosecutors asserted.

    ASD also had members from at least 18 countries, and conducted “rallies”  in Illinois and Minnesota, among other states, prosecutors said.

    Read Bowdoin’s claims that the charges against him should be dismissed and that ASD did not meet any of the three Howey Test prongs.

  • TalkGold Ponzi And Criminals’ Forum Deletes ‘Sticky’ Thread On InstaForex; Firm Named Defendant In CFTC Sweep Used Payment Processor Whose Contact Person Is Referenced In International Money-Laundering And Narcotics Case

    The TalkGold Ponzi scheme and criminals’ forum has deleted a “sticky” thread reportedly paid for by InstaForex, a dubious company named a defendant in a registration sweep conducted by the U.S. Commodity Futures Trading Commission last month.

    The PP Blog reported two days ago that InstaForex was using TalkGold to promote a scheme by which participants who sent InstaForex at least 1,000  U.S. dollars could qualify to win a Lotus Elise valued at more than $50,000. Although sweepstakes that require a purchase are illegal in the United States, InstaForex bizarrely instructed investors that they could improve their odds of winning the car by opening up to 100 accounts each.

    Some of the InstaForex promoters used photographs of attractive women to promote the scheme. It was unclear whether the photos were actual pictures of the promoters or whether they were stage props designed to lure skeptical investors.

    Why any investor from any country would open a single account — let alone 100 accounts — with a firm that advertises on TalkGold was left to the imagination. TalkGold and similar sites such as MoneyMakerGroup are referenced in multiple filings in U.S. federal courts as places from which international Ponzi and fraud schemes are pushed.

    A separate ad for which InstaForex apparently paid TalkGold $95 remains operational on the forum. The ad shows an image of a red Lotus and claims the company is “THE BEST BROKER IN ASIA.” Directly below the ad is an ad for a company that claims to provide a return of 525 percent “After 1 Minute” and 9,860 percent “After 6 Hours.”

    Just four of the thousands of schemes pushed on TalkGold — Imperia Invest IBC, EMG/Finanzas Forex, Legisi and Pathway to Prosperity — created tens of thousands of victims globally while gathering hundreds of millions of dollars, according to court records.

    The precise time at which TalkGold deleted the paid “sticky” thread on InstaForex and the precise reason why the thread of at least 109 pages was deleted were unclear. Records suggest the thread was deleted in the past 24 hours. The once-massive thread now returns a “No Thread specified” error.

    Among other things, InstaForex advertised that it accepted payments through Perfect Money, a murky money-services business purportedly operating from Panama. Imperia Invest, which the SEC accused in October of stealing millions of dollars from thousands of participants, also used Perfect Money, according to court filings.

    Included among the Imperia Invest victims were thousands of Americans with hearing impairments, according to the SEC.

    Meanwhile, the name of Roger Alberto Santamaria del Cid — the purported contact person of Perfect Money — appears in federal court filings in the EMG/Finanzas Forex forfeiture case.

    A Florida-based task force that specializes in detecting and uncovering massive fraud schemes brought the EMG/Finanzas Forex case last year. Del Cid, Perfect Money’s purported contact person in Panama, is listed as EMG’s “Secretary” in court filings that allege that tens of millions of dollars seized in the probe were tied to the international narcotics trade.

    EMG/Finanzas Forex was so corrupt that some participants were told the only way they could get their money out was to recruit new investors, have the new investors pay them directly — and use the proceeds from the new investors to recover their initial outlays, according to court filings.

    The very first EMG post on the now-shuttered ASA Monitor Ponzi and criminals’ forum referenced yet-another widely promoted Ponzi scheme: 12DailyPro. The 12DailyPro case, brought by the SEC in February 2006, also is cited in the AdSurfDaily Ponzi prosecution brought by the U.S. Secret Service in August 2008. ASD also was promoted on TalkGold.

    Writing on ASA Monitor, an EMG/Finanzas Forex aficionado claimed to have learned the ropes from 12DailyPro.

    “I have been in internet business for 3 years now and in autosurf industry from 12dailypro,” the ASA poster began. He (or she) then proceeded to tell readers about how they could earn commissions by recruiting for EMG/Finanzas, which the Feds later described as an international menace with tentacles in Central America, South America and Europe.

    Court filings in the EMG/Finanzas case paint a picture of an incredibly elaborate maze of companies and bank accounts set up to confuse both investors and law enforcement. At least 59 bank accounts, 294 bars of gold and nine luxury vehicles were seized.

    The EMG allegations were explosive because they showcased the undeniable fact that people who promote programs such as HYIPs and autosurfs because such programs may pay “commissions” to recruit new members may be operating as fronts or conduits for international drug dealers and money-launderers.