Picower’s Madoff Take Now Estimated to Be $7.2 Billion

by Jake Bernstein, ProPublica

As a man who cherishes his privacy, the attention Jeffry Picower received on Thursday must have made him wince. On the same day that Forbes revealed he had earned a coveted spot in the magazine’s list of the 400 wealthiest Americans, a new court filing added $2.1 billion to the $5.1 billion he is alleged to have earned from his participation in Bernard Madoff’s Ponzi scheme.

Forbes, which listed Picower at No. 371, placed his net worth at $1 billion, although the magazine acknowledged that the former lawyer and accountant is "likely worth billions more." Irving Picard, the court-appointed trustee charged with recovering cash from Madoff’s scheme, wants to claw back Picower’s Ponzi profits. Picard contends that Picower is one of a select group that benefited from the Ponzi scheme and knew or should have known that they were participating in a fraud.

The trustee’s latest filing states categorically what ProPublica first reported in June ― Picower made more money than anyone else from the Madoff Ponzi. Picower was "the biggest beneficiary of Madoff’s scheme, having withdrawn either directly or through the entities he controlled more than $7.2 billion of other investors’ money," the filing said.

If Forbes had included all of Picower’s alleged Ponzi profits in this year’s total, it would have had to bump him up to the 32nd richest American. Instead, the media-shy investor is making his first appearance on the Forbes list. One reason for this may be that calculating Picower’s net worth has proven extremely difficult. In 2002, Forbes itself put Picower’s wealth at a little more than $300 million. That same year, according to court filings, Picower’s quarterly withdrawals from Madoff alone totaled $895 million.

The trustee’s latest judicial move is a response to a July 31 filing by Picower which urged the court to dismiss the Trustee’s complaint. (See, our "Picower: Charges of Complicity with Madoff 'Baseless."") In that filing, Picower argued that he himself was a victim of Madoff’s crime. He asserted that it would have been illogical for Madoff to have "compensated" Picower with such exorbitant sums because that would have undermined the scheme. Picower also noted that he still had half a billion dollars invested with Madoff when the now-convicted fraudster first confessed.

Although the trustee’s brief is heavy on legal citations, it nonetheless marshals plenty of outrage at Picower’s arguments. "Given that Picower withdrew more of other investors’ money than any other customer" of Madoff, "Picower’s repeated references to himself as a 'victim' ring hollow," the brief states. "Picower’s premise that making billions of dollars from a Ponzi scheme is a badge of innocence is dubious at best."

The trustee notes that Picower’s largest withdrawals were quarterly, allowing Madoff to plan ahead for them. The trustee also adds a new detail to the story. As early as 2003, Madoff was having trouble paying Picower the full amount the investor was demanding every quarter.

Madoff’s "failure to pay Picower sums that purportedly were in his accounts or otherwise available to him is further evidence that Picower knew or should have known of Madoff’s fraud," states the brief. "This evidence becomes more compelling given Picower’s apparent lack of complaint about his inability to access billions of dollars reported" on Madoff's account statements.

Picard summarizes his objection to the motion to dismiss with a flourish: "Picower’s motion is a concoction of irrelevant counter-facts, arguments that ignore both the allegations in the Complaint and the relevant legal standards, and factual challenges that are not properly before the Court on a motion to dismiss."

Not surprisingly, a statement from Picower's lawyer William Zabel takes issue with Picard’s latest brief: "Trustee continues to make false and outrageous claims about Mr. Picower based on a misreading of the purported 'facts.' When the true facts are known, the Court will see that Mr.
Picower was deceived by Bernard L. Madoff like the SEC and thousands of other investors, as many as half of whom took out more money than they put in."

In the statement, Zabel also leaves open the possibility that a settlement can be reached.

"The Picowers in good faith have initiated discussions with the Trustee to reach a settlement in order to avoid years of extensive litigation," Zabel said.

A hearing on the motion to dismiss before Judge Burton R. Lifland of U.S. Bankruptcy Court for the Southern District of New York has been scheduled for Oct. 27.

ProPublica is an independent, non-profit newsroom that produces investigative journalism in the public interest.

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Military Contractor Faces Jail Time For Fraud

The president and owner of Jacobi Industries Inc., a Medford, N.Y. company, has pleaded guilty to conspiring to rig bids on U.S. Department of Defense (DOD) contracts for military tie-down equipment and cargo securing systems, the U.S. Department of Justice says.

Jacobi Industries provided military tie-down equipment and cargo securing systems to DOD. These products are used to secure vehicles, aircraft, munitions, shipping containers and other
specialized military cargo requirements for land, sea, and air transportation.

Roger Jacobi pleaded guilty in the U.S. District Court in Islip, N.Y., to a felony charge of bid rigging. Under the plea agreement, Jacobi has agreed to pay a criminal fine of $20,000, and to cooperate with the Justice Department's ongoing investigation. Jacobi could also serve up to six
months in prison. The terms of the plea agreement are subject to court approval.

Jacobi participated in the bid-rigging conspiracy from November 2001 to January 2005, during which time he and co-conspirators discussed and agreed among themselves not to compete by agreeing not to submit prices or bids against each other on certain contracts.

"Today's charges demonstrate our ongoing commitment to prosecute those who deprive the U.S. military of the benefits of competitive bidding on taxpayer funded contracts," says Thomas Barnett, assistant attorney general in charge of the Justice Department's Antitrust Division.

Jacobi is charged with carrying out the conspiracy with co-conspirators by:

-- Attending meetings and engaging in discussions regarding the sale of
military tie-down equipment and cargo securing systems;
-- Agreeing during those meetings and discussions not to compete on
certain contracts with the DOD by not submitting prices or bids on those
contracts;
-- Submitting bids in accordance with the agreements reached;
-- Selling military tie-down equipment and cargo securing systems to
the DOD under those agreements at collusive and non-competitive prices; and
-- Accepting payment for military tie-down equipment and cargo securing
systems sold at the collusive and non-competitive prices.

Jacobi is charged with bid rigging in violation of the Sherman Act, which carries a maximum sentence of 10 years of imprisonment, and a fine of $1 million for individuals and $100 million for corporations. The maximum fine may be increased to twice the gain derived from the crime or twice the loss suffered by the victims of the crime, if either of those amounts is greater than the statutory maximum fine.

The charge against Jacobi represents the fourth case to arise from an ongoing investigation into the military restraints industry, the Justice Department says.

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Study: Executive Stock Options Tied to Higher Fraud Rates

Management incentives consisting mainly of stock options strongly increase the likelihood of financial misrepresentation, according to a new study in a publication of the Institute for Operations Research and the Management Sciences (INFORMS).

“Incentives to Cheat: The Influence of Executive Compensation and Firm Performance on Financial Misrepresentation,” by Jared Harris, the Darden Graduate School of Business Administration, University of Virginia, and Philip Bromiley, Merage School of Business, University of California, Irvine, appears in the current issue of Organization Science, an INFORMS publication.

According to the authors, “Our results demonstrate two factors substantially increase the likelihood of financial misrepresentation: extremely low performance relative to average performance in the firm’s industry, and high percentages of CEO compensation in stock options.”

The study also determined that approximately 1 in 10 of the financial restatements examined by the authors was linked to fraud and illegal practices. Over five years, there was a 9% likelihood that a company misrepresents its finances and is discovered. The actual frequency of misrepresentation is almost certainly higher.

Stock options offer a strong incentive to raise the stock price above the strike price; indeed, the stock price must rise above the strike price for executives to profit from their options. This incentive motivates some executives to misrepresent financial outcomes to raise the stock price.

“Millions and sometimes tens of millions of dollars worth of CEO compensation ride on these stock options,” says Bromiley. “That’s enough to motivate some executives to deliberately fudge the books so that stock prices go up.”

The authors found bonuses had little influence on misrepresentation. “Unlike with stock options,” they write, “we found no significant influence of bonuses on financial misrepresentation.” They note that options and bonuses offer different incentives and that options offer massively greater financial returns to CEO’s than bonuses do.

In addition to firms with high levels of stock options, firms with massive losses relative to their assets also tended to misrepresent their financials.

The authors examined financial restatements prompted by accounting irregularities identified by the U.S. Government Accountability Office (GAO). The GAO identified 919 such restatements announced between January 1997 and June 2002. According to the GAO, these particular restatements resulted from “aggressive accounting practices, misuse of facts, oversight or misinterpretation of accounting rules, and fraud.”

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Federal Auditors Uncover Millions in Katrina, Rita Fraud

U.S. government auditors have identified millions of wasteful and fraudulent dollars paid by FEMA for relief in the wake of hurricanes Katrina and Rita.

The Federal Emergency Management Agency (FEMA) continues to respond to hurricanes Katrina and Rita, two storms which laid waste to the U.S. Gulf Coast in 2005.

In one case, FEMA provided free housing to 10 individuals in apartments in Plano, Texas, while at the same time it sent these individuals $46,000 to cover out-of-pocket housing expenses. In addition, several of these individuals certified to FEMA that they needed rental assistance, according to a recent report by the Government Accountability Office (GAO).

GAO is the nonpartisan watchdog agency of Congress.

FEMA made nearly $20 million in duplicate payments to thousands of individuals who claimed damages to the same property from both hurricanes Katrina and Rita. FEMA also made millions in potentially improper and/or fraudulent payments to nonqualified aliens who were not eligible for FEMA’s Individuals and Households Program (IHP).

For example, FEMA paid at least $3 million to more than 500 ineligible foreign students at four universities in the affected areas. This amount likely understates the total payments to ineligible foreign students because it does not cover all colleges and universities in the area. FEMA also provided potentially improper and/or fraudulent IHP assistance to other ineligible non-U.S. residents, despite having documentation indicating their ineligibility.

Finally, FEMA’s difficulties in identifying and collecting improper payments further emphasized the importance of implementing an effective fraud, waste, and abuse prevention system, GAO says. For example, GAO previously estimated improper and potentially fraudulent payments related to the IHP application process to be $1 billion through February 2006. As of November 2006, FEMA identified about $290 million in overpayments and collected about $7 million.

GAO recommends that DHS direct FEMA to take six actions, including establishing controls to prevent duplicate housing benefits to FEMA trailer and apartment residents and duplicate benefit payments for the same damages. GAO is also recommending that FEMA establish controls to prevent benefits to nonqualified aliens.

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Former Telecom Owner Convicted for E-Rate Scheme

A federal jury in McAllen, Texas, convicted the former president and owner of ATE TelSolutions Inc., which does business as ATE Telecom Solutions Inc. (ATETel), on seven of nine counts of wire fraud in a scheme to defraud the federal E-Rate program, the Department of Justice announced.

Rafael Adame was convicted of submitting fraudulent applications for payment onbehalf of ATE Tel to the Federal Communications Commission's (FCC) Universal Service Administrative Company (USAC). The indictment against Adame was returned on Dec. 6, 2006.

Adame was convicted of submitting fraudulent invoices for payment to the Schools and Libraries Division of USAC from December 2001 to May 2003. As a result of the scheme to defraud the E-Rate program, Adame fraudulently obtained $106,514 in payments from USAC.

"Committing fraud upon the E-Rate program harms underprivileged school districts," says Thomas Barnett, assistant attorney general in charge ofthe Justice Department's Antitrust Division. "The Antitrust Division will continue to vigorously pursue those who cheat the competitive process and steal money from this federal program."

The E-Rate program subsidizes the provision of Internet access andtelecommunications services, as well as internal computer andcommunications networks, to economically disadvantaged schools andlibraries. The program was created by Congress in the Telecommunications Act of 1996 and is administered by USAC, a non-profit corporation, under the auspices of the FCC.

Adame owned and operated ATE Tel, a vendor that provided computer-related goods and services through the E-Rate program to various school districts, including Weslaco Independent School District in South Texas. Adame devised a scheme to defraud the E-Rate program through illegitimate invoices, which were transmitted via wire communications to USAC. On these invoices Adame entered fabricated data, such as false customer bill dates and false amounts for reimbursement. USAC then relied on this illegitimate information to transmit wire transfers for theindicated amount into ATE Tel's bank account. By making false representations on invoices filed with USAC, Adame received payments in excess of what was authorized and for work that was not actually performed.

The wire fraud conviction carries a maximumpenalty per count of 20 years in jail, and a $250,000 fine. Adame has not yet been sentenced.

The conviction resulted from an ongoing national investigation offraud in the E-Rate program. The trial and prosecution of this case wasconducted by the Antitrust Division's Dallas Field Office and the Federal Communications Commission's Office of Inspector General.

The Antitrust Division's ongoing investigation into fraud and anti-competitive conduct in the E-Rate program has yielded charges being filedagainst 14 individuals and 12 companies. Six companies and four individuals have either been found guilty at trial, pleaded guilty, agreed to pleadguilty, or have entered civil settlements. The defendants have collectively agreed to pay criminal fines and restitution totaling more than $40 million. Two of the individuals have each been sentenced to serve six years in prison.

Anyone with information concerning fraud or anticompetitive conduct inthe E-Rate program should contact the Dallas Field Office of the AntitrustDivision at +1-214-661-8600.

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Brother, Sister Sentenced In ID Theft Scheme

A brother and sister from Dorchester, Mass., were sentenced in federal court for bank fraud, identity theft and witness tampering.

United States Attorney Michael Sullivan and Peter Zegarac, postal inspector in charge of the U.S. Postal Inspection Service, announced that Alvin Reeves, 29, and his sister, Alvenia Reeves, 44, were sentenced by U.S. District Judge Joseph Tauro as a result of their August 14, 2006, guilty pleas to charges of bank fraud, identity theft and witness tampering.

Alvin Reeves also pleaded guilty to aggravated identity theft and committing a crime while on pretrial release. Alvin Reeves was sentenced to five years in prison; and Alvenia Reeves to one year and three months in prison.

At the earlier plea hearing, the prosecutor told the court that had the case proceeded to trial, the government's evidence would have proven that from November 7, 2003 (the date that Alvin Reeves was released from federal prison after a prior conviction) through September 15, 2004, Alvin Reeves obtained the names, Social Security numbers, dates of birth, mothers' maiden names, credit card number and/or bank account information of numerous people.

The defendants then used this information to create fake licenses with the victims' identity information and the photographs of co-conspirators. The defendants directed the co-conspirators to enter banks and withdraw money or otherwise conduct banking activity in the victims' names. In addition, the defendants stole checks and had co-conspirators cash these stolen checks and withdraw the proceeds from area banks. After Alvin Reeves was arrested in connection with this scheme, the defendants contacted some of the co-conspirators and attempted to convince them to testify that a person other than Alvin Reeves was the leader of the bank fraud andidentity fraud scheme. In total, this scheme resulted in a loss or intended loss of more than $200,000.

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Former DOD Contractor Sentenced in Bribery, Fraud, Money Laundering Scheme in Iraq

A former US Department of Defense (DOD) contractor was sentenced to nine years in prison and ordered to forfeit $3.6 million for his role in a bribery and fraud scheme involving contracts in the reconstruction of Iraq, Assistant Attorney General Alice Fisher of the U.S. Justice Department Criminal Division announced today.

Robert Stein, 52, of Fayetteville, N.C., was sentenced today in U.S. District Court for the District of Columbia by Judge Colleen Kollar-Kotelly. The judge also sentenced Stein to three years of supervised release.

Stein was arrested in Fayetteville on Nov. 14, 2005, and pleaded guilty on February 2, 2006, to being a felon in possession of a firearm, possession of machine guns, bribery, money laundering, and conspiracy in connection with a scheme to defraud the Coalition Provisional Authority --South Central Region (CPA-SC) in al-Hillah, Iraq.

"Robert Stein will now spend nine years in jail for exploiting hispublic position and accepting bribes for contracts during the rebuilding ofIraq," says Fisher. "The Department of Justice will protect the integrity of the federal contracting process byaggressively prosecuting fraud, bribery and other crimes that taint missions as critical as the reconstruction of Iraq."

Stein admitted to participating in a complex bribery, fraud and money-laundering scheme while serving as the comptroller and funding officer forthe CPA-SC. From December 2003 through December 2005, Philip Bloom, a U.S. citizen who owned and operated several companies in Iraq and Romania, Bruce Hopfengardner, a lieutenant colonel in the U.S. Army Reserves, and numerous public officials, including several high-ranking U.S. Army officers, conspired to rig the bids on contracts being awarded by the CPA-SC so that all of the contracts were awarded to Bloom. In return, Bloom provided the public officials with over $1 million in cash, SUVs, sportscars, a motorcycle, jewelry, computers, business class airline tickets, liquor, future employment with Bloom, and other items of value.

In addition, Bloom laundered over $2 million in currency that Stein and his co-conspirators stole from the CPA-SC that had been designated to be used for the reconstruction of Iraq. Bloom then used his foreign bankaccounts in Iraq, Romania and Switzerland to send the stolen money to Stein, Hopfengardner and other public officials in return for the awarded contracts. In total, Bloom received over $8.6 million in rigged contracts.

During the course of the conspiracy, Stein and other co-conspiratorsstole U.S. currency and funneled those funds to Bloom in order to purchase illegal controlled weapons which they converted to their own personal use in the United States, including assault rifles, silencers, and grenade launchers.

Stein has cooperated with the government's ongoing investigation.

On March 10, 2006, co-conspirator Bloom, pleaded guilty to relatedcharges of conspiracy, bribery and money laundering in connection with thesame scheme as Stein. Bloom is scheduled to be sentenced on February 16,2007.

On August 25, 2006, co-conspirator Hopfengardner pleaded guilty to related charges of conspiracy to commit wire fraud and money laundering inconnection with the same scheme as Bloom and Stein.


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Survey: 2 of 5 Identity Theft Victims Know Source of Crime

Two out of five identity theft victims surveyed by the Identity Theft Assistance Center (ITAC) know how their personal data was stolen, providing valuable insight about how identity theft occurs.

"This information is important because the more we know about the sources of identity theft the more successful we all will be in fighting this crime," says ITAC Executive Director Anne Wallace. "These documented cases provide real world perspective on identity theft."

ITAC surveyed 275 identity theft victims who used the ITAC's free service over a one-month period. Of the 275 cases, 160 consumers (58%) did not know the source of their identity theft. Another 115 consumers (42%) did know how their information was compromised. The 115 consumers attributed their identity theft to the following sources:

-- Friends, relatives, in-home employees 26 cases 22.61%
-- Computer hacker/virus/phishing 25 cases 21.74%
-- Mail (stolen or fraudulent address change) 24 cases 20.87%
-- Lost/stolen wallet, checkbook or credit card 15 cases 13.04%
-- Corrupt business or employee 12 cases 10.43%
-- Data breach 8 cases 6.96%
-- House burglarized 4 cases 3.48%
-- Instant credit 1 case 0.87%

Getting accurate information about the sources of identity theft is difficult because identity theft -- the opening of a fraudulent new account or account takeover -- is often confused with other types of fraud, like the unauthorized use of a credit card, accoding to ITAC.

ITAC says it is in a unique position to gatherdata about identity theft because it deals in verified cases of identity theft. The companies that belong to ITAC refer customers to ITAC once thefraud is resolved at the member company. ITAC then helps the customer identify other fraudulent accounts and assists in restoring their financial identity.


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Alabama Woman Sentenced to More Than Six Years in Prison for Katrina Fraud

Lawanda T. Williams, also known as Lawanda Johnson, was sentenced to more than six years in prison for defrauding the Federal Emergency Management Agency (FEMA) of more than $267,000 and for aggravated identity theft following Hurricane Katrina, U.S. Attorney Deborah Rhodes of the Southern District of Alabama announced.

Williams was sentenced to 75 months in prison, and was ordered to pay full restitution to FEMA in the amount of $267,377. In addition, Williams was ordered to forfeit all of the property she purchased with the proceeds of her Katrina fraud, including four automobiles, real estate, televisions and other electronics.

Williams pled guilty in September 2006 to making false claims to the government, wire fraud, and aggravated identity theft in connection with 28 fraudulent claims for disaster assistance she made to FEMA after Hurricane Katrina. Williams admitted that her residence in Jackson, Ala. was not damaged by the hurricane and that she filed 28 fraudulent claims for Katrina assistance, falsely claiming to have lived at various addresses in Alabama, Mississippi, Louisiana and Florida. In those applications, Williams admitted using Social Security numbers of other people and providing FEMA with fraudulent and fictitious documents that purported to prove her ownership of property she did not own.

"Ms. Williams used Hurricane Katrina and the relief efforts as an opportunity to make hundreds of thousands of dollars by lying and by stealing other people's identities," says Rhodes. "The Hurricane Katrina Fraud Task Force is actively working to bring to justice those who took advantage of the recovery efforts to enrich themselves."

Hurricane Katrina was the costliest and one of the deadliest hurricanes in the history of the United States. It made landfall along the Gulf Coast in late August 2005, laying waste to New Orleans and the surrounding region. The government response, particularly from FEMA, was widely criticized.

In September 2005, Attorney General Alberto Gonzales created the national Hurricane Katrina Fraud Task Force, designed to deter, investigate and prosecute disaster-related federal crimes such as charity fraud, identity theft, procurement fraud and insurance fraud. The Hurricane Katrina Fraud Task Force, chaired by Assistant Attorney General for the Criminal Division, Alice Fisher, includes members from the FBI, the Federal Trade Commission, the Department of Labor Office of Inspector General, the Postal Inspector's Office and the Executive Office of United States Attorneys, among others.

The case was investigated by the Department of Homeland Security, Office of the Inspector General, the FBI, and the United States Postal Inspection Service. The case was prosecuted by Assistant U.S. Attorney Sean Costello.


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Mississippi Man Arrested For Hurricane Katrina Fraud

Paul Ladner, of Pass Christian, Miss., waived arraignment yesterday on charges of making false statements to Federal Emergency Management Agency (FEMA) for Hurricane Katrina disaster assistance funds, as well as wire fraud, U.S. Attorney Dunn Lampton of the Southern District of Mississippi announced.

Ladner was indicted on Dec. 5, 2006 for receiving over $14,000 from Federal Emergency
Management Agency by providing a false address in Pass Christian, Miss., and claiming hurricane damage at that address.

The case has been set for trial on March 5, before U.S. District Judge Louis Guirola, Jr. If convicted, Ladner faces up to 60 years in prison and up to $1,250,000 in fines.

In September 2005, U.S. Attorney General Alberto Gonzales created the national Hurricane Katrina Fraud Task Force, designed to deter, investigate and prosecute disaster-related federal crimes such as charity fraud, identity theft, procurement fraud and insurance fraud. The Hurricane Katrina Fraud Task Force, chaired by Assistant Attorney General Alice Fisher, includes members from the FBI, the Federal Trade Commission, the Department of Labor Office of Inspector General, the Postal Inspector's Office and the Executive Office of United States Attorneys, among others.

Hurricane laid waste to the city of New Orleans, areas of Mississippi and other regions of the Gulf Coast in 2005. The government response to Katrina was much criticized. The head of FEMA was forced to step aside after the storm.

Pursuant to the Justice Department initiative, a local Katrina Fraud Task Force, consisting of over 20 federal and state law enforcement agencies, was formed in the Southern District of Mississippi to pursue and prosecute individuals who engage in fraud associated with the hurricanes.

If anyone has information concerning possible fraud being committed during the post-Katrina recovery effort, please call either the Department of Homeland Security Office of the Inspector General Fraud Hotline at 1-866-720-5721 or the FBI Fraud Hotline at 1-800-225-5324.


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DaimlerChrysler Warns of Lottery Fraud

Consumers across the United States have received fraudulent letters from the so-called Ontario Lottery and Gaming Commission in Canada claiming they've won $170,000, according to phony documents obtained by DaimlerChrysler Financial Services Americas.

The letters contain counterfeit checks allegedly issued by "DaimlerChrysler Services" and "DaimlerChrysler Services Truck Finance" in the amount of $2,260. The company on January 1, 2006, changed the names of those units to DaimlerChrysler Financial Services and DaimlerChrysler Truck Financial.

"We care about the well-being and financial health of consumers," says Andreas Hinrichs, vice president global projects and chief compliance officer for DaimlerChrysler Financial Services Americas. "Therefore, we felt strongly about alerting the public to this ongoing criminal activity, especially when con artists victimize consumers by pretending to be associated with us."

Hinrichs also serves as chairman of the American Financial Services
Association's newly-formed Identity Theft and Fraud Control Committee.

As part of the con, recipients of the letters are asked to deposit the
check to cover a service charge of the same amount in order to receive
their winnings. However, before the check clears, recipients are requested
to call a representative of the phony lottery and gaming commission who
instructs the recipient to send a personal check via electronic transfer
for $2,260 to "finalize the payment process." Not surprisingly, the
original phony check never clears and the promised payout of $170,000 never
arrives. In the meantime, the recipient's funds in the amount of $2,260
have disappeared.

DaimlerChrysler Financial Services Americas posted fraud alerts on its
corporate Web sites. The automotive finance company encourages victims to file a consumer fraud complaint with the Federal Trade Commission (FTC) either by calling the FTC's Consumer Response Center toll free at 877-FTC HELP (382-4357) or by downloading and submitting a complaint form online.



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