[gonzo]

Originally Posted by sudden

If you had a clue, you'd realize I was talking about YOU and the others at Oprano, not myself, when referring to the 100k/year. Then if you had math skills, you could figure out more in what region I'm in - although my figures above weren't talking yearly income but rather liquid/invested cash.

I can help with all this a year later Daniel.

Defendant Daniel Sundin is, or has been, an officer and/or director of Innovative Marketing. Individually or in concert with others, he has formulated, directed, controlled, or participated in the acts and practices of the IMI Enterprise alleged in this complaint, and has done so at all times pertinent to this action. Defendant Sundin does or has done business as Vantage Software and Winsoftware, Ltd. Defendant Sundin resides or has resided in London, England, and transacts or
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has transacted business in this District.

The Role of Daniel Sundin
54.
Daniel Sundin is the former Chief Operating Officer and current Chief Technology Officer of Innovative Marketing. Sundin incorporated Innovative Marketing in Belize and is the company's sole shareholder.
55.
Sundin set up Innovative Marketing's headquarters in Kiev, Ukraine and also opened facilities in Argentina and India.
56.
Through his now-defunct company, Vantage Software, Sundin registered and paid for many of the Defendants' primary websites, including WinFixer.com, DriveCleaner.com, ErrorProtector.com, WinAntivirus.com, and SystemDoctor.com.
57.
Sundin controls foreign bank accounts, including an account in Sweden, that are used to fund the Defendants' activities, including the account used to pay for the false and misleading advertisements placed by defendant Ross on the MyGeek network. Sundin has also used multiple personal credit cards and bank accounts to fund the Defendants' activities.

DEFENDANTS' BUSINESS PRACTICES
Overview
15.
The Defendants operate a massive, Internet-based scheme that tricks consumers into purchasing computer security software. Known in Internet parlance as "scareware," Defendants' softwareand
the misleading Internet advertising used to promote it -exploits consumers' legitimate concerns about Internet-based threats like spyware and viruses by issuing false security or privacy warnings to consumers for the sole purpose of selling software to fix the imagined problem.
16.
The Defendants' scareware scheme relies on elaborate and technologically sophisticated Internet advertisements that Defendants place with advertising networks and many popular commercial websites. These exploitive ads display to consumers a "system scan" that invariably detects on consumers' computers a host of malicious or otherwise dangerous files and programs, including viruses, spyware, or "illegal" pornography.
17.
Once the scan is complete, the Defendants urge consumers to download and install their software to resolve the security or privacy problems detected by the scanner. In many instances, consumers who agree to install the software are then presented with another scan initiated by the Defendants' software.
18.
This second, software-based, scan repeats many of the same warnings from the initial scan and urges consumers to purchase the Defendants' software at a cost of $39.95 or more to resolve the security or privacy issues found by the scanner.
19.
In reality, the scans displayed in the Defendants' Internet advertisements and by the Defendants'
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software are an elaborate ruse created to dupe consumers into purchasing the Defendants'
security software products. Although the Defendants go to great lengths to make the scans
appear legitimate, no actual computer scans take place and the purported virus, spyware, or
illegal pornography purportedly detected by the Defendants' scanners does not exist on
consumers' computers.
20.
Unaware of the Defendants' trickery, more than one million consumers have purchased the Defendants' software products to cure their computers of the non-existent problems "detected" by the Defendants' fake scans.
21.
Although some consumers later realize they have been defrauded by Defendants and attempt to seek refunds, Defendants routinely delay, obstruct and refuse to honor such requests.
The Defendants' False and Misleading Representations
22.
Since 2003 or earlier, the Defendants have conspired to market a wide array of computer security software via deceptive advertising. These software products include, but are not limited to, "WinFixer," "WinAntivirus," "DriveCleaner," "WinAntispyware," "ErrorProtector," "ErrorSafe," "SystemDoctor," "AdvancedCleaner," "Antivirus XP," and "XP Antivirus 2008."
23.
Regardless of the product being pitched, Defendants employ the same modus operandi -bogus scans that falsely detect the presence of dangerous or illegal files or programs on consumers' computers.
24.
For instance, when marketing their AdvancedCleaner program, Defendants disseminate exploitive advertisements that redirect consumers from the website they are viewing to the AdvancedCleaner website. Defendants then display a "system scan" that purports to search
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REDACTED
consumers' computers for "privacy violations." As the scan unfolds, Defendants display a series
of hard-core pornographic pictures, which the Defendants falsely claim reside on consumers'
computers. The Defendants then offer consumers the opportunity to rid their computers of these
images by downloading and installing AdvancedCleaner.
A screenshot of the Defendants' AdvancedCleaner scan appears below:
IThreats observed I
r---Illegal pom content found on your PC!
A
I
Scan Progress
Details Scan Results
Values analyzed: 2688 A.dult cookies: 204 Keys analyzed: 384 '!'.dull pictures' 99 Invalid entries: 2 Internet History Tracl's: 226 Ignored entries: o A.dull registry files: 95 Threads: o Porn Movies: 23 Method: Manual .A.dult shortcuts: 5
Commit Charge (K) Kernel Memory (K) Total: 383284 Total: 87812 Limit 1735832 Paged: 71296 Peak: 635288 Nonpaged: 16516
l [RemoveAD I y
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25. Once consumers download and install AdvancedCleaner, Defendants present consumers with
another bogus scan, which is initiated by the Defendants' software. This second scan, which is
displayed below, repeats many of the same misrepresentations made in the original
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advertisement, including this dire warning:
216 Adult Content Detected [sic]
Your PC has stored 216 items that are dangerous to your reputation ...
To protect your family/career/property and get rid of these compromising contents,
you need to hide them completely by means of AdvancedCleaner. For software
registration, please click the "Register Now!" button.
A screenshot of the software-initiated warning appears below:
WARNING! 216 pieces of compromising content have been detected in your computer!
that are dangerous to your leputalion. You can never your awareness ."nd get nd of these comprom~sing contents, .Y'JU e Repair Now! Your PC has stored 216 ~ems 100% sure that your internet activities are private when others can access your computer at work or at home d eVidence may cause: @ Monitoring and investigation of your computer without be The founo Accidental or purposeful disclosure of adult materials stored in your PC o Strong disapproval of your addiction to XXX sites o High risk to your career and marriage f3 Other embarrassinq consequences T0 pro~ect !)our famil.y/career/proper~!) need to hide them completel!) t~1 means ot AdvancedCleaner. For software registration. plea$e click the "Register Now'" b\IUOn be~)w
found! "ate c1ean·up
lean Now
26. The representations in Paragraphs 24 and 25 are wholly false. Defendants have not scanned
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consumers' computers and have not found "illegal porn" or "adult files" on consumers'
27.
28.
29.
computers. Many consumers exposed to the Defendants' fake scans proceed to purchase AdvancedCleaner at a cost of $39.95, or more, to remove from their computers the files purportedly detected by the Defendants' fake scans. Defendants use similar "fake scan" tactics to sell their various other software products, including WinAntivirus and DriveCleaner. For example, in the advertisement below for WinAntivirus, Defendants represent that an "infection" identified as "W32.Z0TOB.C@mh" has been detected on, and that a "remote computer" has gained access to, the computer on which the ad is displayed. Both of these representations are false.
, .". " --,---- lQj Security Center ' _
~c::r....~ .\.,~ 1I1...~:c;t'JGf-= W""rnAnbVtnJs ~ help wo'ect {Cd f~C I
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'0 Re ·0 Get tlle latest security and virus : VOlIlP ad:7ess iS~. Usn) tis ad,h" • remo~ COI1"4l " oc!ectJlg m." ••Iion t t!1e ~te< '.0. '."IS1t.!d and 1tle files CO!1!o"ed " tile l~y Doa.r.1ents' folder,
mmmY~n i
C1ick here to inslaD tlle virus removal tool
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o Check for tlle latest anlivinn
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Infection detected: W32.l0TOB.C@mh
0 Get support lor security,related I (o.s lP .~o I
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MdfJOfMi o Gel help about 5ealrity Center I
• Change t!le way 5ealnty Center n-teat stJQJS:
alerts me
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~ The Solution
WinAntiVirus
~"\y comput!f ern ":l~out c'! r~ab:e antrli.rus PfottCQOrl:5 l.:nder a risk of ':ir!l.,~ction. Wll'lAntlWUS ',o;as d~';'eloped to stop harwftJ 'KJStS. sPj"J."are. 3lh.(''!$~'! aj-NaN~, ~Jac'.;t:-~. ~OJO"l~. keyboard I'OQef'S, UliW3nted coo:d!$. and oth~ fas:"9'O'.....I"IQ IrtfmH trr~ats.
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30. Similarly, in the advertisement below for DriveCleaner, Defendants represent that they have scanned the computer on which the ad is displayed and detected 948 "COMPROMISING & INTERNET TRACK FILES." These representations are false. Defendants have not scanned the computer, and have not detected 948 "COMPROMISING & INTERNET TRACK FILES."
Erase all compromising evidence
Scan your system now and find ont what trash flies your PC Is sto'In9
31. Many consumers exposed to the false representations in Defendants' WinAntivirus and DriveCleaner advertising proceed to purchase the programs at a cost of $39.95, or more, in order to resolve the imagined security problems "detected" in the ads.
The Defendants' Deceptive Marketing Efforts from 2004·2007
32. In 2004 or earlier, the Defendants began placing false and misleading advertisements for their software products with major Internet advertising networks, including the MyGeek network (now known as the AdOn network). Advertising networks like MyGeek serve as advertising
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brokers, distributing advertisements to their website partners across the Internet.
33.
Defendant Ross placed more than $3.3 million dollars worth of ads for the Defendants' products with the MyGeek network between October 2004 and November 2006. Ross used a variety of methods to pay for these advertisements, including international wires from an account identified as "Innovative Marketing, Inc.," and credit cards belonging to Defendants Marc D'Souza and Daniel Sundin.


Guess the FTC is stupid too
http://www.ftc.gov/os/caselist/07231...mrktgcmplt.pdf