Temporary Receiver Peter E. Keith, Esq., appointed by the United States District Court for the District of Maryland, provides the information on this web site as a service to the public. Mr. Keith serves the Court. He does not represent the Federal Trade Commission. The material presented in this site is intended for informational purposes only and does not offer legal advice. Should you have questions or concerns about your legal status, obligations, or risk, Mr. Keith recommends that you seek the advice of a lawyer. Nothing in this web site is intended to or does create an attorney-client, fiduciary, or other relationship. Mr. Keith will continue to update this site, to provide the public with information on material developments in this matter. We appreciate your review of this site and encourage any feedback you may wish to offer.
Entry of Temporary Restraining Order and Appointment of Temporary Receiver
On December 7, the Federal Trade Commission filed a lawsuit in federal court in Baltimore, Maryland against RagingBull.com LLC, Sherwood Ventures, Jason Bond LLC, MFA Holdings, Winston Corp, Winston Research, Jeff Bishop, Jason Bond, and Kyle Dennis. On February 4, 2021, the Federal Trade Commission amended its complaint [ECF 164], dismissing MFA Holdings Corp. as a defendant in the action and deleting relevant references to that entity. The case is styled Federal Trade Commission v. RagingBull.com, et al., Case No. 20:cv-3538, pending in the United States District Court for the District of Maryland. All pleadings and filings in the case are available on the Court’s PACER web site, available here, and selected documents are available here. Documents filed in the case are referred to on this site by their Electronic Case Filing (“ECF”) number.
The Federal Trade Commission alleges that RagingBull.com used deception to sell its services and did not provide a simple mechanism for consumers to cancel their subscriptions. The Federal Trade Commission asks the Court to stop what the Federal Trade Commission alleges are the defendants’ unlawful practices. The Federal Trade Commission seeks injunctive relief and an award of money to compensate consumers.
On January 13th, RagingBull.com and the other defendants filed their opposition to the FTC’s motion to show cause as to why a preliminary injunction should not be issued. Among other things, RagingBull.com’s opposition asserts that the company did not use deception to sell its services, did offer valuable services to its customers, did not target the elderly, immigrants or other disadvantaged groups, and does not constitute a business permeated with fraud. For documents filed by all parties, please see Court Documents.
The Temporary Restraining Order
With its complaint, the Federal Trade Commission filed an emergency motion for injunctive relief and appointment of a temporary receiver [ECF 2]. On December 8, 2020 the Honorable George L. Russell, III, of the United States District Court for the District of Maryland, granted the Federal Trade Commission’s motion and issued a temporary restraining order [ECF 21]. The temporary restraining order orders that the defendants make no misrepresentations to consumers and that they provide consumers a simple mechanism to cancel their subscriptions. The temporary restraining order also freezes the assets of the corporate defendants (except MFA Holdings) and imposes restrictions to preserve assets of the individual defendants.
On December 11, 2020, several defendants filed a motion to modify the temporary restraining order or stay its enforcement [ECF 34 & 35]. On December 15, 2020, the Honorable George L. Russell, III denied this motion [ECF 56].
On December 17, 2020, the Honorable George L. Russell, III issued a modified temporary restraining order [ECF 64]. A copy of the temporary restraining order, as modified on December 17, is available here. Pursuant to the Court’s February 4, 2021 Order [ECF 165] the Temporary Restraining Order remains in full force and affect unless otherwise ordered by the Court.
The Temporary Receiver
The temporary restraining order appoints a temporary receiver. A receiver is an officer of the court who is authorized to exercise certain powers on behalf of the court. The Honorable George L. Russell, III appointed Peter E. Keith, Esq. as Temporary Receiver. Mr. Keith has substantial experience as receiver in federal equity receiverships and similar public service court appointments. [move up sentence below to this paragraph]Mr. Keith has retained legal counsel and an accounting firm to assist him in fulfilling his obligations to the court.
On February 1, 2021, the Temporary Receiver filed his Initial Report. The Report is currently under seal and restricted from public access. The Temporary Receiver expects that a public version of the report will be made available later this month.
The Temporary Restraining Order binds the following entities and individuals:
- RagingBull.com, LLC f/k/a Lighthouse Media, LLC
- Jeffrey M. Bishop
- Jason Bond f/k/a Jason P. Kowalik
- Jason Bond, LLC
- Kyle W. Dennis
- Pursuant to 12/17/2020 Order
- Sherwood Ventures, LLC
- Winston Corp.
- Winston Research Inc.
Other entities and people may be bound by the terms of the order. Please review the temporary restraining order (available here) to understand its full scope and effect.
As this site previously reported, a hearing on the Federal Trade Commission’s motion for a preliminary injunction had been scheduled for February 5, 2021. On February 3, 2021, the Court held a teleconference with the parties, and on February 4, 2021, the Court issued an order memorializing the results of the teleconference [ECF 165]. The Court ordered RagingBull.com, LLC “to submit its brief describing its proposed business plan.” The Court directed the FTC and the Temporary Receiver to file responses to Raging Bull’s plan, and Raging Bull to file a reply. The Court vacated the February 5 hearing and directed that it be rescheduled to a date after at least one week after all briefing on the business plan has been submitted.
On February 12, 2021, the Court issued an order [ECF 169] memorializing the following schedule:
- Defendant RagingBull.com, LLC shall file its brief describing its business plan on or before February 19, 2021;
- The FTC and the Temporary Receiver shall file their responses on or before March 2, 2021;
- Defendant RagingBull.com, LLC shall file its reply on or before March 9, 2021.
The Court further ordered that the Preliminary Injunction hearing be rescheduled for Friday, March 19, 2021. The hearing will likely take place virtually, as a result of court-imposed COVID-19 restrictions.
All parties will have the opportunity at the hearing to present their case to the Honorable George L. Russell, III, of the United States District Court.
Judge Russell may issue a ruling at the conclusion of the hearing, or he may elect to take the motion under advisement and issue a ruling at a later date.
We will continue to update this site as more information becomes available. We appreciate your patience as the Court, the parties, and the Temporary Receiver continue to work through this matter as expeditiously as possible.