Dun & Bradstreet, Inc.

Text (OCR of the scan at left; may contain errors)

IN THE MATTER OF DUN & BRADSTREET, INC.

D/B/A D&B CONSENT ORDER, ETC. IN REGARD TO ALLEGED VIOLATIONS OF SECTION 5 OF THE FEDERAL TRADE COMMISSION ACT Docket No. C-4761; File No. 172 3196 Complaint, April 6, 2022 – Decision, April 6, 2022 This consent order addresses Dun & Bradstreet, Inc.’s sale of paid CreditBuilder and related products. The complaint alleges that several of D&B’s CreditBuilder sales and renewal practices are deceptive, and that certain conduct was unfair in violation of Section 5(a) of the Federal Trade Commission Act. The consent order prohibits D&B from misrepresenting: (1) that using D&B’s product is likely to allow a business to have its previously unreported commercial payment experiences added to its credit report; (2) that D&B will actively assist a business in adding its unreported commercial payment experiences to its credit report; (3) that using D&B’s product is likely to help a business build or improve its credit report; (4) the ease with which information or payment experiences can be added to a business’s credit report; and (5) that D&B’s product is needed when it is not, and that a product will enable a prospective customer to have a “complete” file.

Participants For the Commission: Dana C. Barragate, and Harris A. Senturia. For the Respondents: Rachel Mossman, Richard Schwed, and Christina Urhausen, Shearman & Sterling LLP.

COMPLAINT The Federal Trade Commission, having reason to believe that Dun & Bradstreet, Inc., a corporation, has violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the public interest, alleges: 1. Respondent Dun & Bradstreet, Inc. (“D&B”), also doing business as D&B, is a Delaware corporation with its principal office or place of business at 101 John F. Kennedy Parkway, Short Hills, NJ 07078. D&B is a wholly owned subsidiary of The Dun & Bradstreet Corporation.

2. From at least May 2015, Respondent has advertised, marketed, offered for sale, sold, and distributed products to small and mid-sized business consumers, including products Respondent claims will help a business monitor, manage, and build its business credit report. Respondent claims that the products offer a business an easy way to provide D&B with positive payment history, otherwise unreported by D&B, to improve the business’s credit report. In fact, Respondent rejects a majority of the submissions, and thousands of businesses that have paid for these products cannot get even a single payment experience added to their credit reports. DUN & BRADSTREET, INC. 563 Complaint 3. The acts and practices of Respondent alleged in this complaint have been in or affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act.

Respondent’s Business Practices Overview 4. Respondent is involved in the commercial credit reporting business. Respondent maintains files containing information on over 300 million businesses and other entities, including nonprofits, cities, counties, municipalities, and other governmental entities (hereinafter, collectively referred to as “affected businesses”) worldwide. 5. Among other things, Respondent creates and maintains commercial credit reports on affected businesses. These commercial credit reports contain a variety of information about affected businesses, as well as proprietary scores and ratings that Respondent generates and assigns.

6. Respondent makes its credit reports available to entities, including an affected business’s potential suppliers and vendors, for a fee. Respondent has represented that a strong credit report may improve an affected business’s chances to qualify for loans, attract new customers, increase cash flow, lower interest rates, and negotiate better payment terms. 7. In many instances, Respondent’s credit reports on small and mid-sized affected businesses reflect incorrect or incomplete information, including incorrect information about the affected business itself or incomplete information about an affected business’s payment experiences with other entities and its overall financial health. 8. Unlike an individual credit report, a D&B credit report does not identify by name the entities that have provided payment information about an affected business. Nor does a D&B credit report list the specific amount and specific date of any transaction reflected in the report. Moreover, even when an affected business questions the accuracy of the payment information appearing on the report, Respondent will not tell affected businesses the specific sources of Respondent’s information about the affected business except when the source permits such disclosure.

9. If Respondent’s credit report reflects incorrect or incomplete information about an affected business, the affected business’s only recourse is to deal directly with Respondent to seek to correct or supplement the report.

10. If an affected business contacts Respondent to dispute a payment experience appearing on its credit report, Respondent’s policy is to contact the entity that reported the information to Respondent and ask it to recheck the payment experience. Respondent provides no new or additional information to the source about the reported payment experience. Thus, in some instances, affected businesses cannot obtain changes through this process, or on their own by reaching out directly to the reporting entity. VOLUME 173 Complaint 11. Affected businesses have suffered negative consequences as a result of incomplete and inaccurate information appearing on their credit report, including denial of credit, less favorable contract terms, and loss of contracts with other businesses. 12. Respondent also offers various paid products to small and mid-sized affected businesses, purportedly to help them monitor, manage, and improve their own credit reports. Respondent uses the term “credit-on-self” to describe these products, as they purportedly allow an affected business to monitor, and have information added to, its own credit report, including information that would correct or supplement the information reported by Respondent. 13. Respondent’s “credit-on-self” products have included products called CreditBuilder, CreditBuilder Plus, and CreditBuilder Premium and related products or services, including Credit Essentials, a product that includes CreditBuilder features. Collectively, these “credit-on-self” products are referred to herein as “CreditBuilder Line products.” 14. Respondent has generated sales of CreditBuilder Line products through multiple deceptive acts and practices.

15. For affected businesses dissatisfied with the accuracy or completeness of the information Respondent reports about them, Respondent has routinely deceptively claimed that purchasing a CreditBuilder Line product is the path by which an affected business can add payment history and improve its scores and ratings. 16. Respondent has routinely deceptively claimed that if an affected business would simply purchase a CreditBuilder Line product and provide information to Respondent, Respondent would verify that information and add it to the credit report. For example, in pitching CreditBuilder Line products, Respondent’s telemarketers have made specific deceptive claims including, “we will contact those companies that you add … [and] verify that payment history going back a full 12 months,” and “[i]t’s a really easy process[,] I just need a little bit of information from you and we basically take over the rest from there.” 17. In addition, in numerous instances Respondent’s telemarketers have deceptively pitched CreditBuilder Line products to new businesses, and to businesses unfamiliar with Respondent, through misleading claims that the affected business needs to purchase a CreditBuilder Line product in order to “complete” its credit file. 18. Respondent has also employed deceptive practices to enable it to collect payments from CreditBuilder Line product customers for products different from the ones to which they agreed to subscribe. Moreover, Respondent has deceptively collected credit card information from CreditBuilder Line product customers without adequately disclosing material aspects of its charging practices, including, in many instances, failing to disclose that at the end of the product’s subscription term, Respondent will automatically charge the customer’s credit card again for a subscription to a CreditBuilder Line product. DUN & BRADSTREET, INC. 565 Complaint Background on Respondent’s Credit Reporting Business 19. To establish a credit file on an affected business, Respondent gathers information from sources including public records, payment information supplied to D&B by an affected business’s vendors and creditors, and information supplied to D&B by the affected business itself.

20. At the time it establishes an affected business’s credit file, Respondent also assigns the affected business a DUNS number, a unique, nine-digit identifier of a single affected business that ties directly to an affected business’s D&B credit file, and which D&B is solely responsible for issuing. In numerous instances, Respondent opens a credit file and assigns a DUNS number on its own initiative. In other instances, Respondent does so after an affected business contacts D&B to request a DUNS number. The request for a DUNS number and the creation of a credit file and report are free.

21. Affected businesses often need a DUNS number, because certain entities require an affected business to obtain a DUNS number before they will work with the affected business, and the federal government has required an affected business to have a DUNS number in order to apply for certain federal government contracts or grants. 22. Although an affected business should only receive a single DUNS number, in some instances, Respondent has assigned a single affected business multiple DUNS numbers attached to multiple credit files, and has included different information about the affected business in each credit file.

23. An affected business’s D&B credit report includes basic information about the affected business, such as its name, address, and principals, and public information on any judgments or liens. In numerous instances, Respondent reports incorrect or incomplete basic and public information about an affected business. 24. An affected business’s D&B credit report may include information relating to how the affected business pays its bills, such as whether the affected business pays its bills on time, is late, or is delinquent. Respondent bases this element of its business credit reports on commercial payment information that it receives from other entities. 25. Respondent sometimes refers to the sources that supply commercial payment information to D&B as “Trade References,” and other times uses the term “Trade References” to refer to the payment information these entities provide to D&B. 26. According to Respondent, only a small number of entities have agreements with D&B to automatically report commercial payment information or “payment experiences” to D&B on a regular basis about affected businesses with which the entities do business. Respondent sometimes refers to these entities as “Trade Tape Providers.” The Trade Tape Providers have varied over time.

VOLUME 173 Complaint 27. Of the tens of millions of businesses in the United States, at any given time only approximately 3,000-5,000 companies are Trade Tape Providers. 28. In numerous instances, an affected business’s payment experiences will go unreported by D&B. First, an affected business’s suppliers, vendors, and other entities the affected business works with often are not Trade Tape Providers and therefore do not automatically report an affected business’s payment experiences to D&B. Second, even if the affected business has a relationship with a Trade Tape Provider, in some instances, D&B fails to report the payment experiences because the Trade Tape Provider may not have provided the particular affected business’s payment experiences to D&B, and/or D&B fails to match the reported payment experiences to the affected business. 29. Even when Respondent reports payment experiences, in some instances, such payment experiences may be incorrect. Because Respondent reports what Trade Tape Providers send to Respondent, any errors in the Trade Tape Provider’s data are inherently reflected in what Respondent reports on an affected business’s credit report. 30. If Respondent contacts a Trade Tape Provider about a dispute from an affected business, and receives no response at all from the Trade Tape Provider, Respondent’s practice is to delete the disputed payment experience. However, if the same Trade Tape Provider later provides another file to Respondent that contains the same disputed payment experience, Respondent will again report it. Thus, an affected business may believe that it has effectively disputed erroneous payment experience data only to later see it reappear. 31. In addition to reporting on an affected business’s payment experiences, Respondent assigns an affected business various scores and ratings, which appear on the affected business’s credit report. These scores and ratings purportedly reflect the creditworthiness of the affected business, including predicting the likelihood that the affected business will experience financial distress or cease operations over the next year.

32. Respondent calculates many of the scores and ratings by using payment experience information that it receives from Trade References regarding how an affected business pays its bills. As Respondent often receives limited or no payment experience information about an affected business, and as data provided from Trade Tape Providers may contain errors, in many instances the scores and ratings that Respondent assigns, particularly as to small and mid-sized businesses, may not accurately reflect how the affected business has performed in the past and/or how it will perform in the future.

33. The manner in which Respondent gathers and maintains data can result in it reporting errors and incomplete information. Even in the course of producing CreditBuilder Line product information to the Commission during the investigation of this matter, Respondent produced data containing errors such as incorrect basic information about Respondent’s customers.

DUN & BRADSTREET, INC. 567 Complaint Background on Respondent’s CreditBuilder Line Products 34. Respondent has represented that CreditBuilder Line products allow an affected business to submit the names of the entities it does business with—its own Trade Reference information—to Respondent so that Respondent can add the affected business’s payment experiences with these entities to the affected business’s credit report. 35. The number of Trade References that Respondent permits a subscriber to add to its credit report differs depending on the CreditBuilder Line product. The basic CreditBuilder product allows subscribers to add up to four Trade References per year, CreditBuilder Plus allows subscribers to add a maximum of 12 Trade References per year, and CreditBuilder Premium allows subscribers to add an unlimited number of Trade References. 36. Most of Respondent’s CreditBuilder Line products are sold as annual subscriptions and are generally non-refundable during their term. Respondent typically collects subscribers’ credit card information and collects full payment for the term up-front. Respondent then automatically renews and charges for CreditBuilder Line products at the beginning of each succeeding term unless the subscriber notifies D&B before the end of the term that it does not want to renew.

37. For annual subscriptions, the current list price for the basic CreditBuilder product is $899, for CreditBuilder Plus it is $1,499, and for CreditBuilder Premium it is $1,999. Respondent sometimes charges an additional $149 one-time activation fee at the time of purchase.

38. In approximately August 2017, Respondent introduced Credit Essentials for $1,599 per year. Credit Essentials included access to two products, the basic CreditBuilder product and Respondent’s Credit Reporter product, which, among other things, allowed a subscriber to monitor the reports of five other companies.

39. In approximately April 2018, Respondent stopped selling the Credit Essentials product described in Paragraph 38 above and began offering a new Credit Essentials product (sometimes referred to as Credit Essentials Plus) for $2,499 per year. This new Credit Essentials product combined features of CreditBuilder Premium and Credit Reporter. How Respondent Introduces CreditBuilder Line Products to Potential Subscribers 40. In numerous instances, after learning about what they believe to be incomplete or inaccurate payment-related information and/or inaccurate scores and ratings appearing on their D&B credit reports, affected businesses have contacted Respondent to complain. Respondent has routinely offered these affected businesses a CreditBuilder Line product as a way to improve their reports. Respondent’s telemarketers have routinely told such affected businesses that purchasing a CreditBuilder Line product is the only way to improve their D&B credit reports. 41. Respondent has also offered CreditBuilder Line products when an affected business calls after receiving one or more of Respondent’s “business credit notification” mailers. These VOLUME 173 Complaint mailers represent, for instance, that the affected business’s scores have declined and urge the affected business to call a D&B “Credit Advisor” or “Account Manager” to learn how to “safeguard” the affected business.

42. For example, one mailer claims that a D&B customer has purchased the affected business’s file, and the file contains the affected business’s “Delinquency Predictor Score, which has declined.” It warns, “a low Delinquency Predictor Score may mean that you have an increased risk of delinquent payments.” The mailer advises: Affected businesses are urged to call Respondent to learn more about the inquiry and how D&B may help the affected business impact its score.

43. Respondent also has marketed CreditBuilder Line products directly to affected businesses through outbound calls and emails. In many instances, Respondent initiates these marketing calls and emails after an affected business has submitted a request for a free DUNS number or free credit report, or after Respondent has sent the affected business one or more business credit notification mailers as described in Paragraphs 41 and 42, above. Respondent’s Telemarketers Tell Potential Subscribers that it Is Easy to Add Trade References and that Respondent Will Actively Help Them 44. Respondent’s telemarketers have routinely begun their sales pitch for CreditBuilder Line products by representing that the affected business’s credit report contains limited and/or negative payment information, that the vast majority of companies do not report payment experiences automatically to D&B, and that therefore, it is up to the affected business to manage, report, and update its own D&B credit report.

45. Respondent has claimed that CreditBuilder Line products allow an affected business to manually submit or self-report to D&B its Trade References, and/or add the names of its vendors and suppliers to increase the positive payment experiences in its credit report. Respondent has claimed that once an affected business submits its Trade References using the CreditBuilder Line product, Respondent contacts the Trade References to verify the payment history and then adds the payment information to the affected business’s credit report. 46. Respondent has claimed that CreditBuilder Line products will improve, build, and/or establish an affected business’s credit report, and move its credit scores and ratings in a positive direction.

DUN & BRADSTREET, INC. 569 Complaint 47. Respondent has represented that it will actively assist the affected business in getting its payment experiences added to the credit report. 48. Specifically, Respondent’s telemarketers have represented: • [T]here’s only a small percentage of companies that actually automatically record [sic] payment history to Dun & Bradstreet…. So when you’re in a niche type of line of business, then it’s even harder to get payment history on here…. If you want to build the report up, you can actually self-report some of the expenses that aren’t being captured on here where you provide … the contact information for the vendor. We’ll go to that vendor to get the payment history to verify and add to your credit report. [Ex. A, Sales Call Tr. 8:20-10:1] • [T]o have an impact on your scores and your ratings, you are going to need to add more references in here – more payment references to help improve your payment summary.… So that’s where the service comes in. So that’s done through the CreditBuilder. So that’s a service that you pay for, and that allows you to add the payment history to help improve your status on Dun & Bradstreet.

[Ex. B, Sales Call Tr. 14:2-14:11] • [T]here’s only a handful of companies that report to Dun & Bradstreet…. We make it so we give you full access to your files so you can give us all that – those companies that you pay out to operate your business, and we put them – we help you get that on the report…. So basically you give us the names and the address of those companies and then we go and help them get all that financial date [sic] on the report for you. [Ex. C, Sales Call Tr. 9:7-9:16] • [I]t’s up to you to self-report…. So what I would actually do is set you guys up with a service called CreditBuilder Premium that allows you guys to selfreport your operating expenses by giving us the names of the companies that you guys are doing business with so that we can reach out to them and gather all your payment history to get the information updated for you on the file ….

[Ex. D, Sales Call Tr. 7:22, 9:14-9:20] • So usually a company will pay for the service fee, they’ll log in, they’ll add their top 25 vendors. It takes about 20, 25 minutes. And then we do the rest of the work. We contact them; verify the credit limits and terms; and they mainly input that information on your report for you. That way, when you have customers or vendors and banks and whoever is pulling the report, they’re more likely to see that financial strength. [Ex. E, Sales Call Tr. 7:16-7:24] VOLUME 173 Complaint 49. Respondent listened to the stored recordings of the calls described in Paragraph 48, above, after businesses filed complaints against it with the Better Business Bureau. Although Respondent occasionally cited some of the telemarketers for violating company policies, such as “using fear to sell product,” Respondent did not cite any of the telemarketers for violating company policy regarding their presentation of and their statements made about CreditBuilder Line products.

50. Despite notice of complaints from business customers concerning the sale of CreditBuilder Line products, Respondent has continued to make claims similar to those in Paragraph 48. For instance:

• [T]he way that a credit report works in the business world is once you get a number assigned, there are scores and ratings that are going to showcase how you’re operating and how you pay your bills…. So we do not get that information automatically usually. So what you’re going to need to do is, you know, the 30 vendors that you had mentioned that you have…we’re going to need to physically submit and add them on to your credit report. [Ex. F, Sales Call Tr. 13:12-24] • [Y]ou simply give us the names and the contact detail of the company that you pay bills to. Even if you’re paying up-front using your own debit card right now, paying in cash, it doesn’t matter. However you’re paying, you log in here, you give us the names and contact detail, we will contact those companies that you add. We verify that payment history going back a full 12 months and we manually (recording malfunction) that payment history on the report….Now, this DUNS number is free. The credit report for the business is free. Again, there’s only a cost involved in you submitting the bills because, again, we’re not a reporting company, we don’t know who you’re paying. You’re essentially hiring us to work for you. [Ex. G, Sales Call Tr. 17:4-12, 19:13-18] • Just email me the contact information of who you’re going to be making payments to and then our trade department is going to do the rest of the work from there by calling those companies to verify how much you spent with them, the percentage that was paid on time, and if you have any terms with them. And then once we verify that information, then that gets added into the report. It’s a really easy process. I just need a little bit of information from you and we basically take over the rest from there. [Ex. H, Sales Call Tr. 7:18-8:2] Subscribers Find that it Is Not Easy to Get Trade References Accepted and Payments Added, and Respondent Does Not Actively Help Them 51. Although Respondent has represented to affected businesses that it is easy to have their Trade References accepted and unreported payment experiences added to their credit DUN & BRADSTREET, INC. 571 Complaint reports, in numerous instances and for various reasons, Respondent has rejected Trade References added by CreditBuilder Line customers and declined to include the information on their credit report.

52. For example, if a CreditBuilder Line customer submits a company that is a Trade Tape Provider, Respondent rejects that submission regardless of whether the entity has actually reported on the customer; if the Trade Tape Provider has not reported on the customer, Respondent will not bother to contact the entity to let it know it should be doing so. 53. Respondent also rejects submissions of entities that appear on its no-contact list. In numerous instances, these companies are precisely the types of large and well-known vendors and suppliers that an affected business may seek to have added to its credit report. While the companies on the no-contact list have varied over time, examples have included prominent vendors such as Fortune 500 computer companies, internet and telecommunications companies, a very large and well-known shipping company, a supplier of paints, coatings and related products, a hardware company, and a construction rental company. 54. On the other end of the spectrum, when affected businesses submit smaller vendors or suppliers as Trade References, Respondent rejects any entity that itself does not have a DUNS number and a credit file that is complete, active, and in good standing. Respondent has claimed that basic information missing from the potential Trade Reference’s D&B file renders the file incomplete, and has caused Respondent to reject the submission. In the past, that has included minor gaps such as a missing telephone number or address. 55. Contrary to its telemarketing pitch, Respondent does not help subscribers in their efforts to have payment experiences added to their credit report. For example, Respondent does not tell affected businesses why it rejects specific submitted Trade References. Individual CreditBuilder Line subscribers have submitted the same proposed Trade References multiple times, unaware that Respondent is automatically rejecting the proposed Trade Reference because it is a Trade Tape Provider or on a no-contact list. 56. Moreover, in prior years, if a submitted Trade Reference simply asked Respondent for confirmation that the CreditBuilder Line customer had authorized the Trade Reference to disclose payment information, D&B rejected the submission outright. If Trade Reference contact information provided to D&B by an affected business was not accurate, Respondent did not request corrected or updated contact information from the submitter, nor did it check its own database or public records to see if it had or could locate current contact information for the Trade Reference. Instead, Respondent just rejected the Trade Reference. 57. Respondent knows CreditBuilder Line product subscribers often cannot get their Trade References accepted. In fact, when customers attempt to cancel their CreditBuilder Line product because their Trade References are being declined, Respondent has trained its telemarketers to pitch higher-priced, upgraded products that purportedly provide subscribers with a dedicated D&B employee to help get Trade References added. Contrary to Respondent’s previous claims about the ease of getting their Trade Reference information added, Respondent has instructed its telemarketers to explain to customers who complain that their CreditBuilder VOLUME 173 Complaint Line product was a waste of money that submitting Trade References is not really an easy process, and that the higher-priced product would allow a dedicated D&B employee to use a variety of “tips” and “tricks” to help get the payment experiences added. 58. For thousands of affected businesses that have purchased and attempted to use a CreditBuilder Line product, Respondent has not accepted even a single submitted Trade Reference, which means that using a CreditBuilder Line product did not allow these affected businesses to have any unreported payment experiences added to their D&B credit reports. Overall, Respondent has rejected more than half of the total number of Trade References its customers have submitted through the CreditBuilder, CreditBuilder Plus, and CreditBuilder Premium products.

Respondent Tells Potential Subscribers they Need a CreditBuilder Line Product to Complete their Report, for Scores and Ratings, or for their Background Check 59. In addition to making the Trade Reference claims described above, Respondent has represented to potential subscribers, typically those that have applied for a free DUNS number and/or are newer businesses, that the D&B credit file will not be useful without a CreditBuilder Line product. In numerous instances, Respondent has claimed that a CreditBuilder Line product is needed to complete the credit file and enable the potential subscriber to become eligible for D&B scores and ratings. Respondent has also represented that a CreditBuilder Line product is necessary for D&B to conduct a background check that is required to establish the affected business’s file.

60. For instance, in the course of making CreditBuilder Line product sales pitches, Respondent’s telemarketers have represented:

• [T]he application you submitted, typically, it would take 30 business days. But, again, it does leave your file incomplete. So you wouldn’t even yet qualify for the full set of ratings. So we will initiate a background check so that way you have that completed report. That will only take … three to five business days. And then once that is completed, we typically start your scores and ratings in the mid-range. That way, you’re not showing poor ratings right from the beginning.… In order for us to initiate the background check and to get the links and logins so that way you’ll have the full access to self-report. That would be through a Credit Builder basic platform. We just roll this out to newer companies or companies who don’t have the DUNS number just yet.

[Ex H, Sales Call Tr. 10:10-20, 11:5-10] • [T]he application that you submitted, typically it would take up to 30 business days to receive, but what happens is it does leave the file incomplete. So you wouldn’t yet qualify for all seven scores and ratings that are attached to the DUNS number. So since you’re using this for commercial purposes -- and that’s one reason, we want to make sure at the very minimum you do have that completed report. So we will initiate a DUN & BRADSTREET, INC. 573 Complaint background check. We don’t need any legal documents from you. We’ll get all of that squared away over here. And then within three to five business days, once you confirm the company was registered and if there’s been any lawsuits or bankruptcies, we complete your file for the lifetime of the company…. In order for us to initiate the background check and to get the links and logins so that way you have the full access to the report, that is through a Credit Builder Basic platform. We just roll this out to newer companies.

[Ex I, Sales Call Tr. 11:19-12:9, 14:25-15:4] • So you actually already have the DUNS number. It’s just that it’s attached to an incomplete credit file…. So what we need to do is get you set up so that you get a completed report. That’s just going to mean that we confirm operations, make sure there are no lawsuits, liens, judgments … bankruptcies…. and then we’ll set you up so that you can add in the names of those suppliers so we can help you start to build the credit…. So what we’ll do is we’ll set you up on the entry-level service. It’s only $1,499, and it’s going to complete your report for the life of the business.” [Ex J, Sales Call Tr. 15:13-16:5, 17:12-15] 61. In fact, an affected business does not need to purchase a CreditBuilder Line product in order for Respondent to conduct a background check or to verify background information for a credit file.

62. A CreditBuilder Line product also is not needed to “complete” an affected business’s credit file. In the context of determining whether a Trade Reference is qualified, Respondent has represented that a “complete” file means it includes all basic information, such as name and contact information. However, affected businesses can use one of Respondent’s free online platforms to add or update their basic information and submit financial statements. Affected businesses also can, and often do, provide much of this information to Respondent over the telephone.

63. Moreover, a CreditBuilder Line product cannot “complete” a business’s credit file in terms of ensuring that the file contains all relevant credit information, since, in numerous instances, payment experience information will still be missing or incomplete. For instance, as described above, Respondent often does not add payment experience information to an affected business’s credit file automatically or manually. 64. An affected business with a DUNS number and credit file is eligible to receive its D&B scores and ratings without a CreditBuilder Line product. At the same time, a CreditBuilder Line product cannot ensure that an affected business will in fact receive them all. For instance, Respondent requires an affected business to have three payment experiences for a score that Respondent refers to as a PAYDEX score. In numerous instances, an affected business that purchases a CreditBuilder Line product will not be able to add sufficient payment experiences to generate this score.

VOLUME 173 Complaint 65. Respondent has used its claim that an affected business’s credit file is or will be incomplete in a marketing campaign to “drive customer traffic” and “maximize” its CreditBuilder Line sales opportunities. Respondent has referred to this marketing campaign as its “incomplete file campaign.”

66. Information produced by Respondent to the Commission during the investigation of this matter shows that thousands of CreditBuilder Line customers have never submitted even a single Trade Reference and never once logged in to their CreditBuilder Line accounts on D&B’s online portal. This evidence supports a strong inference that Respondent’s deceptive claims that an affected business must purchase a CreditBuilder Line product to avoid having an “incomplete” D&B file have been material and effective. Respondent’s Deceptive Product Renewal Practices 67. Many times, Respondent’s telemarketers have failed to tell affected businesses that, at the end of the subscription term, D&B will automatically charge the affected business again for a subscription to the CreditBuilder Line product being purchased, and that the charge will be in the amount of the product’s “then current price.” 68. In the instances when Respondent’s telemarketers have made this auto-renewal disclosure, or something similar, Respondent’s telemarketers have typically buried it in a statement after the affected business has already agreed to the purchase and provided its payment information. At the time of the initial purchase, Respondent’s telemarketers have not informed subscribers that D&B may later substitute a different CreditBuilder Line product for the one that the customer is purchasing.

69. In numerous instances, Respondent has automatically renewed an affected business’s CreditBuilder Line subscription at a materially higher price than the price the subscriber agreed to at the time of the purchase, without notice or adequate notice to the customer in advance of the price increase. Respondent has done this by routinely increasing the list price of CreditBuilder Line products and charging the higher price at the time of the automatic renewal. Respondent has also done this by eliminating certain CreditBuilder Line products and moving existing subscribers into different and higher-priced CreditBuilder Line products, a practice Respondent has referred to as “product migration.” 70. As an example of an automatic renewal at a materially higher price, in November 2015, Respondent increased the annual list price of CreditBuilder Plus from $1,099 to $1,399, and increased it again in July 2016 to $1,599. By 2016, subscribers that purchased CreditBuilder Plus at $1,099 were automatically renewed at the “then current price” of $1,599. Despite the 45% price increase, there was no change to the CreditBuilder Plus features. In numerous instances, Respondent did not provide affected businesses with notice or adequate notice of the price increase before automatically renewing the product. 71. Two examples of Respondent’s product migration and price increase practices involve the basic CreditBuilder product and a product called “Credit Monitor.” In Spring 2015, Respondent temporarily stopped making the basic CreditBuilder product available. At that time, DUN & BRADSTREET, INC. 575 Complaint the basic CreditBuilder product had a list price of $949. At the time of automatic renewal, instead of renewing the product to which the affected business had subscribed, Respondent moved numerous basic subscribers into a higher-priced CreditBuilder Plus product that, by July 2016, cost $1,599 per year, a price increase of more than 65% for a product the subscriber did not order. Also in July 2016, Respondent stopped offering its $499 Credit Monitor product and moved those subscribers to Respondent’s $1,599 CreditBuilder Plus at the time of their automatic renewal. In numerous instances, Respondent did not provide affected businesses with notice or adequate notice before the product migration. 72. Although Respondent has used its “then current price” disclosure to justify charging an affected business more for a product than it agreed to pay for its initial subscription, when Respondent has reduced the list price of a CreditBuilder Line product, Respondent has continued automatically renewing existing CreditBuilder Line customers at the former higher list price rather than the new, reduced, “then current price.” 73. Nor has Respondent applied its product migration practices and automatic renewal “at the then current price” in a way that would restore subscribers’ original purchases and reduce the amount Respondent charges. Not long after Respondent eliminated the basic CreditBuilder and Credit Monitor products in 2015 and 2016, respectively, it reintroduced both in early 2018. However, Respondent did not move any of the subscribers it had previously moved from these products to the materially higher-priced CreditBuilder Plus through product migration back to the lower-priced products they had originally agreed to purchase. 74. In addition to the automatic renewal and product migration practices described above, in numerous instances, Respondent has affirmatively misrepresented to affected businesses the CreditBuilder Line product that Respondent is attempting to renew, allowing Respondent to move subscribers from one CreditBuilder Line product to another product or into higher-priced products without notice to subscribers. 75. For instance, beginning in approximately August 2017, when Respondent attempted to auto-renew a CreditBuilder Plus subscription for a customer whose payment method on file was no longer valid, Respondent’s telemarketers would call the subscriber to get updated payment information. In some of those instances, Respondent’s telemarketers moved CreditBuilder Plus subscribers to Respondent’s new, $1,599 Credit Essentials product by falsely representing to the CreditBuilder Plus subscribers that Respondent was calling to renew their current subscription, the subscriber needed to provide updated payment information for the renewal, and the CreditBuilder Plus product had been renamed Credit Essentials but was the same as the subscriber’s current product.

76. Although Respondent represented to these CreditBuilder Plus subscribers that CreditBuilder Plus and Credit Essentials were the same product, they were not. For instance, among other material changes in features, Credit Essentials allowed subscribers to add only four Trade References per year, while CreditBuilder Plus allowed subscribers to add 12 Trade References per year.

VOLUME 173 Complaint 77. As another example, in approximately April 2018, Respondent stopped offering the Credit Essentials product described in Paragraphs 75 and 76, above, and began offering a new $2,499 Credit Essentials product (sometimes referred to as Credit Essentials Plus), which allowed the subscriber to add an unlimited number of Trade References. If the affected business’s payment method on file was not valid and did not allow for an automatic renewal of the $1,599 Credit Essentials product, Respondent called the subscriber and represented that the subscriber’s service was set to renew and that Respondent needed to collect updated payment information. In fact, Respondent was not calling to renew the affected business’s current $1,599 Credit Essentials product, but instead, to move the affected business into the different, higherpriced Credit Essentials Plus product.

78. Respondent has routinely moved affected businesses from one product to another, told affected businesses that they have one product when in fact they have a different product, and has sold additional related products and add-on products. As a result, affected businesses often experience confusion about what product or products they are paying for and what the current features of those products are.

Count I False or Misleading Claims Regarding CreditBuilder Line Products: Trade References 79. In numerous instances in connection with the advertising, promotion, offering for sale or sale of CreditBuilder Line products, Respondent has represented, directly or indirectly, expressly or by implication, that:

a. Using a CreditBuilder Line product allows an affected business to have its previously unreported commercial payment experiences added to the affected business’s credit report.

b. Respondent will actively assist CreditBuilder Line product subscribers in adding such unreported commercial payment experience information to the affected business’s credit report.

80. In fact, in numerous instances in which Respondent has made the representations set forth in Paragraph 79, using a CreditBuilder Line product does not allow an affected business to have its previously unreported commercial payment experiences added to the affected business’s credit report, and Respondent does not actively assist CreditBuilder Line product subscribers in adding unreported commercial payment experience information to the affected business’s credit report. Therefore, the representations set forth in Paragraph 79 are false or misleading.

DUN & BRADSTREET, INC. 577 Complaint Count II False or Misleading Claims Regarding CreditBuilder Line Products: Status of Report 81. In numerous instances, in connection with the advertising, promotion, offering for sale, or sale of its CreditBuilder Line products, Respondent has represented, directly or indirectly, expressly or by implication, that CreditBuilder Line products are required for Respondent to conduct a background check on the affected business or will provide an affected business with a complete report including a full set of scores and ratings. 82. In fact, CreditBuilder Line products are not required for Respondent to conduct a background check on the affected business, and will not always provide an affected business with a complete report including a full set of scores and ratings. Therefore, the representations set forth in Paragraph 81 are false or misleading. Count III False or Misleading Claims Regarding CreditBuilder Line Products: Collection and Renewal 83. In numerous instances in connection with collecting updated payment information for CreditBuilder Line products that are scheduled to renew, Respondent has represented, directly or indirectly, expressly or by implication, that Respondent is collecting payment for and is renewing the product that the affected business purchased the prior term. 84. In fact, in numerous instances in which Respondent has made the representation set forth in Paragraph 83, Respondent is not collecting payment for and is not renewing the product that the affected business purchased the prior term. Therefore, the representation set forth in Paragraph 83 is false or misleading.

Count IV Failure to Disclose: Renewal Practices 85. In numerous instances in connection with the advertising, promotion, offering for sale, or sale of its CreditBuilder Line products, Respondent has represented that it collects customer credit card data for payment so that the customer may subscribe to a CreditBuilder Line product for a designated period (e.g., 12 months). 86. In fact, in numerous instances in which Respondent has made the representation set forth in Paragraph 85, Respondent has failed to disclose or disclose adequately, that: a. At the end of the designated period, and at the end of each succeeding designated period until cancelled, Respondent will automatically charge the customer’s credit card again for a subscription to a CreditBuilder Line product.

VOLUME 173 Complaint b. At Respondent’s unilateral choice, the CreditBuilder Line product for which Respondent will charge the customer at the end of the designated period, or any succeeding designated period, may be materially different from the CreditBuilder Line product to which the customer originally subscribed. c. If the list price of the CreditBuilder Line product to which the customer is subscribing increases, Respondent will charge the customer the increased price, but if the list price of the CreditBuilder Line product to which the customer is subscribing is reduced, Respondent will not give the customer the benefit of the price reduction and will charge the customer at the higher previous price.

d. If at any time Respondent unilaterally moves the customer into a different CreditBuilder Line product from the one to which the customer is subscribing, Respondent will not unilaterally move the customer back to the product to which the customer originally subscribed. 87. These facts would be material to affected businesses in their purchase decisions regarding CreditBuilder Line products.

88. Respondent’s failure to disclose or disclose adequately the material information described in Paragraph 86, in light of the representation set forth in Paragraph 85, is a deceptive act or practice.

Count V Unfair Dispute Investigation and Resolution Practices 89. As described in Paragraphs 7-11, 22, 23, 29-33 and 40, in numerous instances, Respondent has reported incorrect information on affected businesses’ D&B credit reports, yet has not provided affected businesses with a reasonable means to dispute such information. 90. This practice has caused or is likely to cause substantial injury to consumers that is not outweighed by countervailing benefits to consumers or competition and is not reasonably avoidable by consumers themselves. This practice is an unfair act or practice. Violations of Section 5 91. The acts and practices of Respondent as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

THEREFORE, the Federal Trade Commission this 6th day of April, 2022, has issued this Complaint against Respondent.

By the Commission.

DUN & BRADSTREET, INC. 579 Complaint Exhibit A In the Matter of:

Dun & Bradstreet February 12, 2019 FTC-00008796 Condensed Transcript with Word Index For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit A VOLUME 173 Complaint DUN & BRADSTREET, INC.

Complaint FTC-00008796 Dun & Bradstreet 2/12/2019 5 7 1 RACHEL: Okay. And what's going on? You said 1 STEVE: Okay. 2 that you went to a new laboratory? Like, what exactly is 2 RACHEL: Recently reported last month with a 3 it that your company does? 3 high credit of $1,000 and now owes $1,000, low by up to 4 STEVE: Drug testing. 4 30 day:. And a miscellaneous busmess service industry 5 RACHEL: Oh, okay, okay. So you're wang 2 new 5 for $250. And then something pretty big that looks like 6 fealty. Is this for expansion or —- 6 it went to some type ofa collection service for $20,000. 7 STEVE: We wanted to use a new laboratory 7 Tt doesn’t give an actual company name or industry. 8 because of some of the services they offer. Yeah, 8 The way that busmess credit works is the 9 they've got some — you know, some advanced equipment and 9 industies get listed on the credit report imshally. 10 stuff that does a better job. But they said our Dun & And if there's a slow payment, you can put if im for ll Bradstreet is kind of a mmck. dispute with us and we'll go back to the company that 12 RACHEL: Yeah. So your scores and ratings are reported rt on your behalf to comfinm the detals of the 13 all curently im the high-nsk range. payment and then ack for a name release to come back to 14 STEVE: Okay. you and say, well, itwas ABC Company and have you check 15 RACHEL: And the scores and ratings are built your record, 16 off of two different types of information. They're built 5o the first thing that we want to do 1s pat 17 off of basic demographic info hke where you're located, these payments im for dispute so that you can get am idea 18 what your line of busmess is, how long you've been in of where it's commg from. 19 business, how large the company 15, stuff like that. And STEVE: Okay. 20 then financial infommation, which for your entity 15 RACHEL: Thus one in particular is a pretty 21 going to be payment history. That's — hefty payment and it is listed 2s an unfavorable comment 22 STEVE: Right. on your credit file, which probably doesn’t mean anything 23 RACHEL: — reported to us from your vendors. to you because you don't quite know what that means. It 2 Because of the niche type of hme of business that you're basteally just means that it was like a company that -- 3 in, you don't have a lot of vendors that you pay who some type of payment or line of credit or expense was 6 8 1 actually report payment history to ws. So the first 1 sent to a third party collection. 2 issue is there's not really 2 lot of mformation m here 2 STEVE: And I don’t know who that would have 3 to build strong reportme — 3 been.

4 STEVE: That's what they said There's just no 4 RACHEL: Yeah. I mean, you're not gone to 3 information m there. 3 have a ton of expenses as -- you know, with your line of 6 RACHEL: Yeah. 6 busmess. So I'm not quite sure where these payments are 7 STEVE: They said it was like — it was like t comung from. § almost we don't exist. 5 STEVE: We have like Office Depot and our 9 RACHEL: Yeah Can you give me an idea of what 9 phone, our rent, but that’s about it, you know, other 10 -- lke, what your annual sales are as an orgamization? 10 than lab fees. ll STEVE: $104,000 last year. ll RACHEL: Yeah. So what I’m going to recommend 12 RACHEL: Okay. Allnght So nght now 12 you dois work with our customer support department. 13 there's only a couple of payment: on file. Of the 14 payments that are cwrentiy on file, there have recently 15 been a few that have been reported as paid slow. And 13 They can put these payments m (maudible) to help you 14 get to the bottom of where they're coming from, and that 15 will help clean wp your scores.

16 they actually tank your score: quite a bit. 16 STEVE: Okay. 17 STEVE: Okay. 17 RACHEL: Okay? 18 RACHEL: Okay? So you've got — 18 STEVE: Sott's just there's — there's not 19 STEVE: Two of those? 19 much there really to work with. 20 RACHEL: Two — two mam components that you 20 RACHEL: Yeah. I mean, most companies, there's 21 need to work on here. 21 only 2 small percentage of compames that actually 22 STEVE: Okay. 22 automatically record payment history to Dun & Bradstreet. 23 RACHEL: The industnes that are listed 23 STEVE: I see. 24 associated with these payments are short-term business 25 credits.

24 RACHEL: And it’s something lke less than 5 25 percent. So when you're im a niche type of hme of 2 (Pages 5 to 8) For The Record, Inc.

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Complaint FTC-00008796 Dun & Bradstreet 2/12/2019 13 15 1 RACHEL: And you can put the disputes in to at 1 STEVE: = went out of business = 2 least start getting access and figuring out. you know. 2 RACHEL: Oh, okay. 3 what's in here and get to the bottom of that part. 3 STEVE: «a couple or three years ago. But 4 STEVE: Sure. Excellent. Okay Well, I will 4 that’s been four or five years ago that happened. I 5 take care of that. 5 think they went out of business a couple or three years 6 RACHEL: Okay? 6 ago, They were -- they did, like, home improvement type 7 STEVE: And] appreciate your help. So I'll 7 stuff, you know, remodeling and things like that 8 know what todo. Like I say. after we got the grant, T 8 RACHEL: Mim-lumm 9 didn’t really want a DUNS number because we're such a 9 STEVE: Did some concrete and custom rock work, 10 small business, 10 you know, stone work, patios and things like that, il RACHEL: Murlunm Yes. Well. and you're not 11 RACHEL: Right, yeah. Like general 12 going to need it for a lot of things. It’s just every 12 construction stuff. Gotcha. 13 once ~~ 13 STEVE: Yeah, basically.

14 STEVE: No. 14 RACHEL: Well. I mean, once you put these 15 RACHEL; - ina while, you know, you're going 15 payments in for dispute, we'll get to the bottom of them 16 to run into a situation where somebody wants to look at 16 with you. 17 it. So-- 7 STEVE: Okay.

18 STEVE: Well, and I'll tell you this: We got 18 RACHEL: And if we find that there’s a 19 -- there was another - 19 situation where the payment really doesn’t belong to your 20 RACHEL; Morhmm. 20 business. then we're going to remove it from the credit 21 STEVE: -- that we got 4 lot of mail for, It 21 report. 22 was collection stuff But it wasn’t us. They were a - 22 STEVE: Excellent. 23 some type of construction type thing. 23 RACHEL: Let me give you a phone number. too. 24 RACHEL: Okay. So that could be part of the 24 to follow up with m case you have any issues getting 25 problem as to what is showing up on your credit files. 25 into the account or if you have any problems or anything 4 16 1 STEVE; Yeah, We got some stuff and it had 1 2 another person's name on it that we didn’t recognize. 2 3 And the phone number was different. And I guess they -- 3 4 and we actually had a lady call us one time from, like, 4 5 Georgia -- 5 6 RACHEL: Marlin. A 6 id I've got everything else 7 STEVE: -- and said. you know, is as rel 7 here now that I T'm going to print all this off 8 And I said yes. And she said, w a 8 and that way I’) have all my information. And — 4 cond it iat comme. aH to | in 9 RACHEL: Perfect. Yeah, reach out to us — 10 and what did I buy ec? I ul es test? And she said no. I 4 eas: One.

= iis unak seashciabn sg: 11 RACHEL: -- if you need anything else. Okay? 3 RA ¥. a Wow. That's 12 STEVE: [ appreciate that, 14 STEVE: We do drug tests. All we do is dmg Ps RACHEL: Have a good day. : : i4 STEVE: Uh-huh 15 and alcohol testing, and DNA testing.

16 RACHEL: Yeah. 15 RACHEL: Bye-bye.

17 STEVE: And it was -- 16 (The call was concluded.) 18 RACHEL: That's so weird. 7 (The recording was concluded ) 19 STEVE: ~sconpay TE 18 20 ae actually had rana on her, 19 21 : Wow. So then itis avery goodchance | 20 22 that some of this information in the report could be 21 23 comiected with — 22 24 STEVE: Now. I think they since 23 25 RACHEL: -- this company 24 4 (Pages 13 to 16) For The Record, Inc.

(301) 870-8025 - www.ftrine.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 585 Complaint Exhibit B In the Matter of:

Dun & Bradstreet February 12, 2019 FTC-00008797 Condensed Transcript with Word Index For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit B VOLUME 173 Complaint DUN & BRADSTREET, INC. 587 Complaint FTC-00008797 Dun & Bradstreet 2/12/2019 a 1 MICKEY: Allright And then — 1 that you did for the credit signal where you see the 2 STEVE: We had a lab that we were trying to do 2 trends of your scores? 3 business with. ] know there’s not much on ours 50 -- I 3 STEVE: Yeah it’s — 4 tmed te login. It kept tryimg to charge me for stuff, 4 MICKEY: Okay. 5 Wanting me to put a credit card in and everything. And EI STEVE: — of course our email address and 6 [mlike, abbh, no. 6 a 7 MICKEY: You were probably -- yeah, the system 7 : Okay. Soit’s going to be that same 8 was probably toying to - to, like, let you purchase a g login, but give me one second while I add itm. I'm 9 copy of the report. Steve, what is your title with the 9 stil fillime out your address and everything. It makes 10 business? 0 me re-fill out everythme for your business — ll STEVE: I am — as I told her, owner and chief 1 STEVE: Sure. 12 bottle washer. 2 MICKEY: — before it will send it to you. The 13 MICKEY: Okay. So all of the above. 3 lab that you're talking about, was that like a customer 14 STEVE: All of the above, yes. 4 that you were working with or a vendor or — 15 MICKEY: Okay. 5 STEVE: It was anew vendor that we were 16 STEVE: Other duties as assigned. 6 looking at. 17 MICKEY: Right. Now, let's see. Oh, yeah, 7 MICKEY: Oh. So you were gomg to be buymg 18 there’s -- there’s a lot of issues with your report. 8 from them? 19 Have you ever actually looked at this other than today? 9 STEVE: Well, yeah, services. Just lab 20 STEVE: No. I haven't even looked at it today. 2 services. But they said in a report -- the other lady x said, yeah, there’s a lot of weird stuff on there. Some a of it is just — it’s just like there’s not been a whole 21 Just what little I saw on there. We got that im 2005. 2 We had applied for a grant from the Department of 23 Education and had to have a DUNS number. 2. lot, though. 24 MICEEY: Okay. 24 MICKEY: Yeah There’s not a whole lot. And 25 STEVE: -- to apply for the grant. And that’s 25 what is on here is not good. & how we ended up with it. And ] haven't touched it smce. MICEEY: Okay. Allnzht Soa couple of things. The person that you spoke with earlier, do you know who that was? STEVE: What it is is negative, and -- yeah.

MICKEY: Exacth. You don't have enough STEVE: I don't.

MICEEY: Okay. So what Im gomge to dois I’m fom to set you up with — it’s a quick view. Soit’sa little bit different than logging in. But there's some staff that you need to see on here that you're not goimg to have access to see unless you pay for service. So Tm just gong to set it up here for you. It’s a snapshot of ——< ight. Sa go ahead and log mito that account.

STEVE: Okay. Hangon. Okay, come on. Ob, come on Really? You gome to do this tome now? Hang on.

MICEEY: Sure.

STEVE: My ESAP is scanning. [fit sees the report. unusual activity, it kind of kicks back -- 13 STEVE: Okay. 13 MICKEY: Wants to make sure it’s safe. 14 MICEEY: Grve me a second while I'm doing that 14 STEVE: Oh, yeah. 15 in the system. Okay? 15 MICEEY: Well, that's good. 16 STEVE: Are you goimz to emaul that to me or 16 STEVE: It scans — l7 something? l7 MICKEY: It’s good and annoving at the same 18 MICKEY: It should send you an email, but zi1ve 18 time. 19 me a second 19 STEVE: Yeah, itis. Okay, here we go. Now 20 STEVE: Yeah She said there was a $20,000 20 we're coolane. Dum & Bradstreet reports; c y mame. 21 collection on us. I haven't heard of anything. 21 dl search; boom, F 2 MICEEY: Yeah. Honestly, there's a lot of 22 there T am; select. 23 problems with this report. A lot. 343 MICEEY: Let me know once it gets you m there. 24 STEVE: Okay. 24 STEVE: Here! go.

25 MICEEY: So -- okay. 50 you know the logm 35 MICEEY: Okay. And you can always just view it 2 (Pages 5 to 8) For The Record, Inc.

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Complaint FTC-00008797 Dun & Bradstreet 2/12/2019 13 15 1 twice. 1 went out of business.

2 STEVE; Hang on just a second here. 2 MICKEY: Oh, no. 3 (Brief pause.) 3 STEVE: And «yes. And so I took out some -- 4 STEVE: Yeah. it's actually $34,000 Anda 4 a couple of these advances just to kind of bridge. They 5 have an agreement -- payment agreement for $100 a month. fs] are «- the attommey general here I think is fixing to 6 ‘That's going to be reduced even further. They actually 6 file a class action lawsuit. it sounds like. Because 7 — because I have an attorney working on it. 7 some of these places are doing those daily pays. which 8 MICKEY: Mim-hrom. & they were doing with us. and it’s the way they're 9 STEVE: They are looking into that because they 9 compounding them. It looks like interest rate, which I 10 were saying we didn’t file some 1120Ss, which we did, and 160 didn't understand, 11 941s, So I had to turn all those over that I had here. li They said, you know, we're giving you this -- 12 MICKEY; Okay. 12 you kaow, this rate at 14 percent. But what it is it’s 13 STEVE: And they’re going to go back and | & 15 percent of your daily gross revenues. and so it ends 14 renegotiate that. It’s probably going to be closer to 14 up to be like 200, 300 percent interest, which is illegal 15 $14,000 is what the attomey said. 1s in the State off because the State off has a 16 MICKEY: Oh, good. So you guys should be able 16 set maximum interest rate that can be charged on loans. 17 to. pay that off. 17 MICKEY: Oh. okay. Well, as soon as you get 18 STEVE: So that's why they just did it for $100 18 that. if you do get those paid or if you want to dispute 19 a month because, I mean, you can’t owe that much money to 19 those. you can always dispute them off of the report. 20 the IRS and they're going to let you pay $100 a month. | 20 too, And that’s part of the free service. The only 2 MICKEY: Right. | 2) problem is is you're only able to dispute five items at a 2 STEVE: Yeah. And so they even deferred the | 22 time. 23 payments until March. the end of March, so they could get =| 23 STEVE: Right. 24 all this cleaned up before the payments start. | 24 MICKEY: So you can dispute the five and 2s MICKEY: Okay. So you can just view those. 25 then -- 14 16 I Like I said earlier, basic updates and disputes are done 1 STEVE: The only one I need to — the only one 2 at no charge. But to be honest with you, to have an 2 T need to fix right now, the main one, is that lien 3 impact on your scores and your tatings, you are going to 3 because that's ~ of course. the lien stays in force, but 4 need to add more references in here -- more payment | 4 we do have a agreement -- 5 references to help improve your payment summary. 5 MICKEY: Yeah. And at this point — 6 STEVE: Okay. 6 STEVE: = which I have in writing. 7 MICKEY: So that's where the service comes in. 7 MICKEY: — I mean, it looks like there's two 8 So that’s done through the CreditBuilder. So that’s a 8 that are the same lien being reported. 9 service that you pay for, and that allows you to add the 9 STEVE: Right. 10 payment history to help improve your status on Dun & 10 MICKEY: Okay. So that -- because it’s on il Bradstreet. | dt there twice. it looks like it’s two separate liens when 12 STEVE: Okay. And these — these loans that 12 you look, like, on paper. You know what I mean? 13 ane out } 13 STEVE: Right.

14 MICKEY: Theil -- | 14 MICKEY: So you're going to need to dispute 15 STEVE: . all of that, those are 15 those. And then plus that $20,000 slow payment, or the 16 probably going to be -- 16 tmifavornble comment. That also needs to be taken care 17 MICKEY: Validated? 17 of, too.

18 STEVE: No. Those are probably going to be 18 STEVE: Right. 19 wiped out. Those were «= the State Attorney General is 19 MICKEY: And then in the meantime. you"re gome 20 fixing to go after some of these companies. And I -- we 20 to need start adding in the tradelines, Now you can’t 21 took this moacy out. we were the first part of last year. 21 see this on your ead, but there have been 11 inquiries on 22 We took some big hits in our business. We do the drug 22 the report. 23 and alcohol testing. We lost about $6,000 a month in 23 STEVE: Right. 24 gross revenues, and $12,000 in bad debt invoices from oil 24 MICKEY: So those are other compatties purchased 25 and gas prodacers and oi) fill service companies that 25 a new report to run a nsk assessment on you. Other than 4 (Pages 13 to 16) For The Record, Inc.

(301) 870-8025 - www.ftrine.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 591 Complaint FTC-00008797 Dun & Bradstreet 2/12/2019 21 23 1 card processing company here in town I said. we don’t 1 2 use them: we use Intuit QuickBooks for all of our credit 2 3 card processmg. And so -- it was weird. 3 Li 4 MICKEY: That is. That is really weird. Okay 4 5 Because it’s strange that the state would even let them > MICKEY: Right. 6 register the name so close to yours, ar even the exact 6 STEVE: Okay. Oh, wow, what's this? 7 same name. 7 Professional license. We don’t really have one even 8 STEVE: Now, I use -- I don’t use my home 8 though T have them. It’s not required — 9 address on anything because of what we do for a living. 9 MICKEY: What is that? What is tt asking you? 10 We have -- we don’t give out our address. We've had our if4) STEVE: Professional license. You're not gomg il house vandalized twice. ul to have ours on here 12 MICKEY: Uhhh. really? 2 MICKEY; Yeah. Is it a requirement to put 13 STEVE: Yes. 13 something there? If not. I would just skip that 14 MICKEY: So - so what you're doing right now, l4 STEVE; I don’t think so, no. 15 it is going to make you verify that. But we're not 1S MICKEY: Okay. 16 posting it anywhere: 16 STEVE: No, it’s not.

17 STEVE: Right. 17 MICKEY: Okay.

18 MICKEY: What you're doing is you have to 18 STEVE: It does not have an asterisk or 19 authenticate jo confirm you are who you say you are in 19 anything. 20 order to have access to the disputes — 20 MICKEY; Okay. 21 STEVE: Okay. So nobody has access to this? 21 STEVE: We don't have a website. Ihave a 22 MICKEY: No. We don’t publish that or 22 Facebook, but not really. 23 anything. 23 MICKEY: That's fine 24 STEVE: Okay. That's good. Because ~ yeah. 24 STEVE: I don’t twiddle, twitter or -- I call 25 we do drag testing for the courts here. And -- 25 it tweedle and — because to me it’s useless 22 24 1 MICKEY: Ohi, I see 1 MICKEY: Yeah. [have a Facebook, but that’s 2 STEVE: Yeah. You have people lose their 2 it, Tdon't do Instagram and -- 3 children. They tend to get a little upset. 3 STEVE: I don’t do all that 4 MICKEY: Oh, yeah. Oh, yeah, Even though it's 4 MICKEY: -- Twitter and —- 5 really their fault. 5 STEVE: No. we have a Facebook page -- 6 STEVE: Well, it’s never their fault 6 MICKEY; -- Snapehat and 7 MICKEY: Oh, right. right. 7 STEVE: -- but it’s more -- it's more -- we 8 STEVE: And is no longer im the business 8 have people that get us on Facebook to ask questions. | 9 MICKEY: Okay. Yeah, I seen her listed ~ 9 had this drug test at such and such andit did this, and, 10 STEVE: ii ii 10 you know, [ was told that you guys can help me and tell 11 MICKEY: Okay. I wasn't sure if she was your 11 me what to do. And so it’s more professional. It’s a 12 or not or — 12 business Facebook page. We don’t really use it that 13 STEVE: i 13 much. It’s a question and answer thing for me. 14 MICKEY: -- business parmer, Okay 14 MICKEY: Yeah. And if youre doing it for the 15 STEVE 13 court, you really don't have to, like, market your 16 P| 16 business out. Right? Unless you - 17 MICKEY 17 STEVE: We do.

18 STEVE: 18 MICKEY: -- guys are trying to find more — 19 MICKEY: 19 STEVE: We do. But we don’t - 20 STEVE: i = aa 20 MICKEY: -- companies to reach out to, 21 arrangements. So, yeah. it’s bad. 21 STEVE: -- market much because it all comes 22 MICKEY BS ia) ha 18 fel 4 22 from cur other -- our customers. So we're loading your 23 th pes 23 information; this may take a few minutes. But, yeah, we 24 STEVE: 24 — we don’t really -- we used to have a website and. I 25 MICKEY 25 don’t know, I'm a quirky person. I’m aot -- what are the 6 (Pages 21 to 24) For The Record, Inc.

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Complaint FTC-00008797 Dun & Bradstreet 2/12/2019 29 31 1 details. Huh Licns for -- there it is. There's four 1 MICKEY: What's that? And then when you try to 2 of those. Sol could do all — 1 could do two of those. 2 call and to get it straightened out, you're spending 3 couldn't I? 3 hours on the line.

4 MICKEY: You should be able to, yeah 4 STEVE: Well. it's — you know, it’s one of 5 STEVE: Because they're all for the same 5 those things that you do stupid things when you panic 6 amount. Is that what you’re showing? 6 MICKEY: Moho 7 MICKEY: The two, the two bottom ones were for 7 STEVE: And I thought, okay, well. what I'll do & the same amount 8 is TH just hold off on paying some of these 9415 and 9 STEVE: What ts that showing, the $40,000? 9 business will pick up and I'll pay a little late fee and 10 MICKEY: Forty -- yeah, like 43 each, Let me 10 a penalty and that will be all she wrote and we'll catch il pull it back up. il up 12 STEVE: And what are the top ones for? 12 MICKEY: Yeah. It docsm*t work out that way, 13 MICKEY: Yeah, 43. 13 huh? 14 STEVE: That onc should be the 4,800. 14 STEVE: Yeah. That was stupid. 15 MICKEY: The top one is for 2.900, and then the 15 MICKEY: Well, at least now you know for the 16 second one down doesn't have a munber. 16 future. 17 STEVE: Okay. They were filed on the same day. 7 STEVE: -- 18 So it’s probably the same filing 18 vICKE AR i Te 19 MICKEY: Start with the two bottom ones because i9 Ba 20 those are the worst or the largest amounts — 20 STEVE: Yeah 21 STEVE: Okay. 21 22 MICKEY: — 1 should say. 22 23 STEVE: All right. Okay. Now. one of those = 23 24 I'm going to do both of them because that's not the 24 25 amount. That's the same filing. 25 l MICKEY: Yeah. Just put not correct amount 1 2 STEVE: Upload — it says upload 2 3 MICKEY: Oh, that’s nght. You've got to put 3 i some documents in there 4 5 STEVE: Okay. 5 6 MICKEY: I'm sorry, | forgot about that. So 6 7 you — you have the document night now, right? 7 g STEVE: So I can put that agreement -- L can 8 9 put that payment agreement in there — 9 10 MICKEY: Yeah. 10 i STEVE: — and that would — okay. il 12 MICKEY: Hopefully — hopefully it’s gomg to 2 13 remove it. T can't guarantee that it's going to remove 13 4 it, But if not. I'm hoping at least they're gome to 14 15 remove ove © that there's not the two listings on there 15 16 so it doesn’t look like you owe 90 grand. | mean, that's 16 17 a lot of money. 17 18 STEVE: Rielt. Yeah. yeah. And it's not 18 19 actually much even. So = 19 20 MICKEY: Mortum. | mean, you're — you're like 20 21 @ third of that, So if we can get it down to 30,000, 2 MICKEY: Ob, no. 22 that will protably look s lot better. 22 STEVE: Min-hmm 23 STEVE: Hang ona second, Let me get the 23 MICKEY: That’s terrible 24 phone. TRS. Yeah, that was pretty strange dealing with 24 STEVE: So Thad to go down today and take care 25 all that. Well, you sure need an atiomey, though 25 of that That was always good 8 (Pages 29 to 32) For The Record, Inc.

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Dun & Bradstreet February 12, 2019 FTC-00008800 Condensed Transcript with Word Index For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit C VOLUME 173 Complaint DUN & BRADSTREET, INC. 597 Complaint FTC-00008800 Dun & Bradstreet 2/12/2019 5 7 1 muamber when I was on your website. [t wouldn't accept 1 RONNIE: Yeah, yeah. It's -- =, the 2 the business name for some reason, 2 manufacturing company? 3 RONNIE: Okay. What's your business name? 3 PHILIP No, It'sa company 4 4 RONNIE Okay. And why would they be 5 5 purchasing your report, Phil? 6 6 PHILIP Because we're increasing the 7 RONNIE: Okay 7 amount of business we're doing with them. & PHILIP =] 8 RONNIE: Oh, nice, Okay. Let me go over this 9 RONNIE: And where 1s your business located? 9 basic demographics with you really quick. 1 want to make 10 PHILIP = 10 sure this is going out correctly ie your il RONNIE Okay, awesome, Thank il DUNS nuunber ts . That’s on the report. Your 12 you And may Ihave your name for compliance purposes? 12 phone mumber js Is that correct, Phil? 13 ra 13 tarteseoect 14 RONNIE; All right, j i4 RONNIE: Perfect, And them your address is 15 PHILIP Phil 15 BB Ginaucibic) nousana 16 RONNIE: Thanks, Pluk All right, Phil, T'm 16 six. So I've got to ask you for «= being a $9 million 17 looking at your comypany credit report right now. Your 17 company, you only have three employees? 18 DUNS oumber is It says 18 PHILIP Yeah.

19 the CEO is Matthew 19 RONNIE: And then Matthew I. sinle 20 Yes 20 location: sales is $9 million; business services is your 21 RONNIE: Is that -- is that right. Phil? 21 line of business. What is it you guys do? What is 22 PHILIP RY That is correct. 2 23 RONNEE: All night; perfect. [t shows that 23 PHILP We're in the telecommunication 24 you're a $9 inillion company. 24 industry.

23 PHLp Yep. 2s RONNIE: So | would -- like. if | want to do a 6 8 1 RONNIE: You have inquiries on your report. I 1 conference mecting. you would sect that up forme? That’s 2 auess, Phil. how familiar are you with Dun & Bradstreet, 2 how, I'm assuming? 3 sir? 3 PHILIP Yeah. mum-hm.

1 PHP Tremember talking about you 4 RONNIE: Okay. cool. How do you get your 5 guys when | was m college. 5 customers? 6 RONNIE: Okay. nice. 6 pm? They come to us.

7 re But other than that... 7 RONNIE; All night, nice, Well, you have ten 8 RONNIE: What was you talking about in college? 8 inquiries. Typically that means, like I was telling you, 9 PHILIP You know, I just remember it 9 businesses you're more than likely working with purchased 10 being mentioned it one of my college classes 10 a copy of your company credit report. They spend up to ul RONNIE: Okay. Well. you're familiar with your il 188 bucks to fook at your financial resume. 12 personal credit, Phil. how that works with TransUnion -- 2 | Yeah. Apparently something bad 13 PHILIP Yes. 13 is on there 4 RONNIE: = Equifax. Expenan, how they hold 14 RONNIE: Okay. Why do you say that? What's 15 your personal credit? So we -- Dun & Bradstreet, we hold 15 going on? 16 your business credit. That DUNS number ts like the 16 eur Well, because — because they 17 Social Security number to your business. and attached is 17 said after lookmg at our Dun & Bradstreet they wouldn't 18 your company credit report that I'm currently looking at 18 give us the credit. We have to give them cash to cover 19 right now. There is activity on the report. Typically 19 our == 20 what that meas is that activity is companies or 20 RONNIE: Okay, Okay. 21 businesses that you are currently working with, it looks 21 PHILIP I need to know what's wrong on 22 like they reached out to Dun & Bradstreet and they 22 there so I can fix it 23 purchased a copy of your company credit file 23 RONNIE: Oka 24 PHILIP Okay. Yeah, that should have 24 PHILIP And that’s why Im calling you. 25 been recently 25 2 (Pages 5 to 8) For The Record, Inc.

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Complaint FTC-00008800 Dun & Bradstreet 2/12/2019 13 15 1 partners about this, though. 1 wpdate.dndb.com. And that will get authenticated to 2 RONNIE: Okay. 2 your report. And then once you get — you'll be able to 3 pa Tean’t just -- 3s see everything.

4 RO : t— 4 PHILIP} Okay.

5 PHIL —- (inaudible) right now. 5 RONNIE: I just sent you the PDF. 6 RO : ay. How soon --] mean, how soon do 6 7 Okay. 7 you need this report fixed? 7 Ri: What Dll send you is -- well, Pil 8 PHILIP Well, Pm only giving them 8 send you that CreditSignal, Phil, so you can see an 9 $7.500 to contmue working with them. 5o -- 9 overview of your report. This just kind of grves you an 10 RONNIE: Yeah I mean, I — 10 overview of your scores and ratings. ll PHILIP (audible), 1 PHT Perfect, 13 RONNIE: Typically, I mean, we have the 12 Ri: You can see this. Typically once you 13 move forward with the service, obviously you'll hold onto 14 the receipt for tax purposes and then, azam, you have 15 full access to the file. I get you over to our 16 engagement team, which is our product specialist, and 13 (CreditBulderPlos, which is a smaller ome. That's 14 $1,599. That will give you access to put m 1? trade 15 references.

16 PHILIP Yesh 17 RONNIE: What I can do, Phil, is -- are you at V7 they -- they help you and they help navigate you through 18 your email night now? 18 your company credit report and help you get your -- they 19 PHILIP Yes, Iam. 19 chow you how to get your trade references onto the report 20 RONNIE: Here, let me — let me do this. Let 20 so itshoweases that financial strength Then they go 21 me send you over the PDF so you can see these. For 21 over the scores and ratings with you. 22 everything that you're tyme to accomplish, I mean, I 23 understand, you know, I don’t -- we're not tryme to 24 brezk the bank by no means -- 25 PHILIP Yeah. It’s just weird that — 2 PHILIP Yech.

RONNIE: 50 you know what's gomg on. Hey, 24 Philip, can you a t last name for me? it's just weird because in 1] years of domg busimess, Tve mever even come across this.

RONNIE: Yeah And you're — you know what, honestly, Phil, you're going to find it more and more and RONNIE: Okay, thank you. Okay. This is the CreditSignal I'm sending you. And then you'll get a temporary password. It takes a few mmutes to get this one. [tsa big file. Are you — are you -- are you in your report yet, or — for about a year now, and the more compamies that require busimess credit and it makes -- they look at them scores and ratings. I -- it’s crazy. 'm not kidding you. It absolutely is. And that’s why you've been in business 10 for ac long as you have and then you're hearing it for ll the first time.

12 PHILIP Yesh.

13 RONNIE: And this is — I mean, this is where 14 you want to make sure that you're — we give you the 13 opportunity to make sure you're leveraging yourself by 16 making sure you gota full file and you get that correct l7 information. Because this 15 the way commamies -- it’s 18 more than a handshake and a smile anymore, man. Again, No, Pmoot.

T haven't received it from you.

i you get the CreditSignal yet? No. I got — 45 more. I mean, it’s -- 've been with Dun & Bradstreet g — Just the first one that you sent me, which was the CreditBiulder and the — just the premium and the plus.

RONMIE: Okay. Them are the two different services that you would need to get your file to where it needs tobe. The CreditSignal, it should be there. It takes a few mumutes. It's a huge file.

S40 00 10K GA fe Go bo et So oe ee 19 you can go on -- you can — I don’t know if you -- you PH IS yr Okay. 20 obviously never logged into your report before. You can a RO? ~ Who 1s John! 21 go to the ipdate azam — 21 PHILIP Ome o! partners. 22 PHILIP Mm-boum 22 ROD : ? Okay. Did you get it? 23 RO : It’s mpdate.dndb.com. 23 PHILP Your account has been created. 4 PHILIP Okay. 4 Okay.

35 RONNIE: It’s -- yeah, the I-dot - 35 RONNIE: Okay. This ts the dashboard te the 4 (Pages 13 to 16) For The Record, Inc.

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Complaint FTC-00008800 Dun & Bradstreet SO GO “2 un de be ba ee CERTIFICATE OF TRANSCRIPTIONIST I, George Quade, do hereby certify that the foregoing proceedings andor conversations were transenbed by me via CD, videotape, audiotape or digital recording, and reduced to typewniting under my supervision: that I had no role in the recordme of this material; and that it has been transenbed to the best of my ability grven the quality and clanty of the recordme media.

I further certify that I am netther counsel for, related to, mor employed by any of the parties to the action m which these proceedings were transenbed; and further, that I am not a relative or employee of any attommey or counsel employed by the partes hereto, nor financially or otherwise interested in the outcome of the action.

DATE: 2/6/2019 s/George Quade GEORGE QUADE, CERT For The Record, Inc.

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Complaint FTC-00009300 Dun & Bradstreet Hou us he 8] D B ty cy Zi 4y s a2 ve) SOR A eb bea ho a bo is OFFICIAL TRANSCRIPT PROX FEDERAL TRADE COMMISSION MATTER NO. 1723196 TITLE DUN & BRADSTREET DATE RECORDED: DATE UNKNOWN TRANSCRIBED: FEBRUARY 7, 2019 PAGES 1 THROUGH 26 PTC -00009300 (301) 870-80 FEDERAL TRADE COWMISS1OM INDEX RECORDING:

PTC -00009300 4 ee ee ee ee a 2/13/2019 FEDERAL TRADE COMMIESS [ON In the Watter of:

Dum & Bradstreet Watter No. 1729196 The Fol low transcript was produced from a File provided to For The Record, Inc. on January PROCEEDINGS FTC 00009300) HICOLE MOORE: Dun & Bradstreet. This is How can I RHONDM. | Nicole, my mame’s Bhonda | are! hawe a a Dun & Bradstreet number, ard someone's reported that I°m $1,000 late on a bill for the assist you? month of December .

NICOLE MOORE: (Okay.

REO bilis a year KICOLE MOORE: Wn-hom RHONDA zi don"t know whe It is, [ need to Find out so we can pet It month of I pay $18 million worth of and this $1,000 bell corrected Give me onc HICQLE MOORE: Okay.

second here RHONDA = How de ] po about Finding it Al] righe HICOLE MOORE: 2 your DUNS number that’s at OYEr your accoun here. Wheat the top of noti fication RHONDA [ed One: 10 HICOLE MOORE: Your DUNS number cop, okay.

1 (Pages 1 to 4) For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (B00) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 605 Complaint FTC-00009300 Dun & Bradstreet 2/13/2019 9 11 stil looks like it’s still pending on paper. RHONDA Company Update com? RHONDA All nght. NICOLE M > Won-hmm And you're going to NICOLE MOORE: Okay? So this is what everyone 1s seeing when they re locke at your report, hke your vendors, suppliers, potential customers. And this file has actually gone out over 32 tumes already. So they're definitely lookimg at this report. Actually, 37 times. So one of the things I would definitely recommend, register to use that website if you haven't already. So you can see the report, see the things that are on it. You just can’t see any of your scores, ratings, or any of the 37 inquines. And you'll just — RONDA Oi NICOLE MOORE: -- digmuate the information. And co se sD Oo JOR un de be pe because you guys are set up for CreditSienal, which is 10 bastcally something for a startup company. It just tells ll if your scores are good (imaudible). You guys are too 12 big ofa company to do that. You need to know what your it asks you for the reason for the dispute. and it takes 10 about 7 to 14 busimess days. And the lawsuts, any ll public filmes, that can take up to 30 busimess days. but 12 we need the supporting documentation for each of those. 13 numerical scores and ratings are. Okay? 13 And that’s how you'll go to sabmut that. 14 So what I would actually do is set you guys up 14 RHONDA And how do I get the 15 with a service called CreditBuilder Premium that allows 15 supporting documentation? 16 you guys to self-report your operating expenses by giving 16 NICOLE MOORE: So you'll have to either call 17 the courthouse to get it, or if it’s for UOC filmes, the 18 Secretary of State may have it on them website listed 19 So you'll just need to get that information.

17 us the names of the companies that you guys are domg 18 business with so that we can reach out to them and gather 19 all your payment lustory to get the information updated 20 for you on the file, as well as monitoring your scores 20 Now, is there something going on that brought 21 and ratngs and being alerted to credit score changes, as 21 this to your attention? n well a5 nmmme_ reports on other companies to nutigate 22 RHONDA Well, we're applymg for an 23 your nsk in demg busmess with them, like they're doing 24 with you. So this just kind of keeps you guys proactive. 23 SBA loan, and tt stopped because this is on there. And 24 Tm bike, what the hell 25 RHONDA BY But this is all free — NICOLE MOORE: That is mot a free service, no.

To dispute the formation and to update basic company information hke name, address, phone number, officers, that’s all free. But to update this report as far as the payables and monitor your scores and ratings, which I would definitely recommend because it looks like other people are and you guys aren't, ] would definitely recommend getting into that service that allows you guys to do se.

RHONDA And how much ts that? NICOLE MOORE: That service is $1,999 for the entire year. It’s definitely -- RHONDA And where do I — NICOLE MOORE: I’m sorry, go ahead.

RHONDA) Where do I contact the -where do I contact to get these -- these disputed ones cleared up — NICOLE MOORE: So -- RHONDA I inte - NICOLE MOORE: Okay, so, what you would do for the — RHONDA -- (mandible) -- NICOLE MOORE: -- dispute is you'd have to go to the free website portal to dispute that mformaton, 25 NICOLE MOORE: Fight. I understand.

RHONDA (Inaudible) crap.

NICOLE M : _ mean, what are you guys needme the loan for? Like, what are vou attempime to do with the loan? RHONDA ‘We're -- we're expandme our usmess.

NICOLE MOORE: Okay. And how soon are you — RHONDA (nandible) basically -- NICOLE MOORE: Okay, I’m sorry. I didn’t mean to cut you off. You're expandmg the busmess? RHONDA (nandible) yes, by a substantial amet.

NICOLE MOORE: Okay.

RHONDA We've grown by about $4 NICOLE MOORE: Ob wow. Okay. And what was your — RHONDA And to have $1,000 (mandible) and a 25 aa — NICOLE MOORE: Right.

RHONDA -- 15 just — it’s like freaking payments 2) drive vou crazy.

NICOLE MOORE: Right. Now -xaos It’s basically Ginaudible) you get stupid gurls m e. I've got people at 3 (Pages 9 to 12) For The Record, Inc.

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Complaint FTC-00009300 Dun & Bradsireet 2/13/2019 17 19 kxonDs eah. 1 number? NICOLE bk: Okay. So the only thing that I 2 NICOLE MOORE: Sure, my -would be able to da — 3 RHONDA What's your direct-dial RHOND Yes, I'm here. = mumber, and I will (mandible) akay. NICOLE MOORE: -- the only thing I would be 3 NICOLE MOORE: Sure. It's (866) 257-9158. And able to dois drop it down to $10,000, and then lke I 6 moy extension 1s 6212. said, we can -- 7 RHONDA And your name? xH0ND Cnaudible). 8 NICOLE MOORE: Nicole. And the last name is NICOLE } : -- set it up on payments for 9 Moore.

you, but that would actually get someone assigned to you 10 RHONDA) Okay. So I can do the guys with 24 hours to start working on this for you to 11 Concrerge Serace for 10,000. get it all cleaned up. 12 NICOLE MOORE: Mm-hom kxonDs No. 13 RHONDA They ll clear it up in how NICOLE > And you'd only have to pay 14 many days? $2,499 today. 15 NICOLE MOORE: It’s zomg to be -- I] mean, I kxonD Nope. 16 can't give you exact tume frames, but ve seen things NICOLE : Okay. 17 done m a week, post m ory experience, and I’ve seen RHOND. That's highway robbery. 18 things done sooner than that. And I’ve seen things done That's holdimg me up. It's yust mot nght, but I guess 19 within tao weeks. you do whatever you need to do, but — 20 RHOND. Okay. And to clear up the — NICOLE MOORE: I mean, you can -- okay. So you 21 the payment disputes, dome it on the CompanyUpdate.com can do the self-service option. 22 will take two weeks? kxoND- T'll have to (inaudible). 3 NICOLE MOORE: Yezh, but they'll do all that NICOLE hk > Agam, that'll allow you to 24 for you — monitor the scores and -- but you're going to be 25 RHONDA (nauckble}. 18 20 responsible for updating the report. And, aga, like I 1 NICOLE MOORE: -- yeah, but of you go with the said, you will be im the standard time frames along with 2 Concierge Serce, oh, they're domg everything for you, everyone else So to dispute the mformation, it would 3 so-you guys don't actually have to do anything. They're be 7 to 14 busmess days, and to disynaite the public 4 doing all the updating, disputing, they're doing all of filings, it could take up to 30 business days. But, 5 that. And they're gomg to be dome all of that again, with the Concierge Service, though, everythmg 6 throughout the year for you. gets expedited, so that — it’s gomeg to cut that time m 7 RHONDA Yeah half. g MICOLE MOORE: So they're actually going to be RHONDA Yeah. 9 managing your credit report moving on for 12 months. NICOLE M > [mean, they're able to get 10 RHONDA Oh, so —- yeah. S01 go to things updated a lot faster than what you or I are able ll Company Update.com and I register to use tt. to do. 12 MICOLE MOORE: Mm-bhmm RHONDA Yeah. I'm not gome to pay 13 RHONDA And then I can dispute the four -- $10,000 to save 5 days or 15 days or whatever. 14 information and as far as the lawsuits, I have to provide NICOLE MOORE: Well, I mean, it could save a 1S supporing documentation. lot more than that, but, yeah, it could save a lot more 16 NICOLE MOORE: Correct. But I would defimtely than that. And the file would be up-to-date. And they 17 don’t need the supporting documentation to get the things 18 RHONDA MD Eversthing else I would just updated to where you guys have to go out, get the 19 supporting documentation, so that’s going to take time, 30 NICOLE MOORE: Yep, but I — I would honestly and then to subnut that formation so then you have more 21 suggest that of you're thinking about gomg with the time. 23 Concierge Service, don’t do anything. Let them handle RHONDA Tl tell you what -- 23 it NICOLE M : Dean tall you — 24 sxoND: (Inaudible). RHONDA — what's your direct-dial 35 NICOLE MW : Butif you want to — yeah. 5 (Pages 17 to 20) For The Record, Inc.

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Complaint FTC-00009300 Dun & Bradsireet int 26 oo) Gy Un fe ls be oe ee ee a fe le et CS GO =) a fe le ee MO GO J Oh ln oe be ba ee a) eee eet pet we SN On h he Se ba bo bo fun te bo RHONDA Thank you so much.

NICOLE > You re welcome.

RHONDA Uh-huh.

NICOLE : Bye-bye.

(The call was concluded) (The recording was concluded.) CERTIFICATE OF TRANSCRIPTIONIST IL, Sara J. Vance, do hereby certify that the foregome proceedings and/or conversations were transenbed by me via CD, videotape, audiotape or digital recording, and reduced to typewrtting under my supervision; that I had no role in the recordimg of this material; and that it has been transenbed to the best of roy ability given the quality and clanty of the recordmg media.

I farther certify that I am nerther counsel for, related to, nor employed by any of the parties to the action im which these proceedings were transenbed; and further, that I am not a relative or employee of any attommey or counsel employed by the partes hereto, nor financially or otherwise interested in the outcome of the action.

DATE: 2/8/2019 s/Sara J. Vance SARA J. VANCE, CERT For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 2/13/2019 7 (Pages 25 to 26) VOLUME 173 Complaint Exhibit E DUN & BRADSTREET, INC.

Complaint FTC-00008997 Dun & Bradstreet eee ee ee ee Tha bo bo ba bo bo Bw = Oo Oo ow A ba wa OFFICIAL TRANSCRIPT PROX FEDERAL TRADE ;

MATTER WO. 1723196 DUN & BRADSTREET TITLE DATE RECORDE! TRANS DATE UNKNOWN BED: FEBRUARY 7, 2019 1 THROUGH 9 PTC-0Oo0s99o7 For The Record, Inc.

www. ftrinc. net (a01) 870-8025 - (800) g21-5 RECORDING:

FTC -00008997 4 a BERSRGEGRES i iy ba MA 2/13/2019 FEDERAL TRADE COMMIESS [ON In the Watter of:

Dum & Bradstreet Watter No. 1729196 The Fol low! transcript was produced from a File provided to For The Record, Inc. on January PROCEEDINGS FTC-O0008So7 Ji: Dun & Bradstreet. All calls are | Jeff [sic], this is Mechel JIM: Just give me a second or two to pull up a the meantime, how Familiar are your report. 1 gr rreet, Like whe ee are and what we you with Dun & B Pretty much MICHAEL ay I hawe 4b.

JIM: Okay And what prompted your call today? Buys that’s san, predictor score I"m very all our bills on time without fat you" re co Like the bo ser this.

Jim:

So Int me look.

Ip with this mu that 1f anybody checks on us Ill be happy te help you with that Yeah, your payment behavior ts really poo The issu is is there's Just mot a 1 (Pages 1 to 4) For The Record, Inc.

(301) 870-8025 - www.firinc.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 613 Complaint FTC-00008997 Dun & Bradstreet 2/13/2019 1 CERTIFICATE OF TRANSCRIPTIONIST 4 I, Sara J. Vance, do hereby certify that the 5 foregoing proceedings and/or conversations were 6 transenbed by me via CD, videotape, audiotape or digital 7 recording, and reduced to typewniting under my g supervision: that I had no role in the recordme of this 9 material; and that it has been transenbed to the best of 10 my ability grven the quality and clanty of the recordme 11 media.

12 I farther certify that I am metther counsel 13 for, related to, nor employed by any of the parties to 14 the action m which these proceedings were transenbed; 15 and further, that ] am not a relative or employee of any 16 attomey or counsel employed by the parhes hereto, nor 17 financially or otherwise interested in the outcome of the 18 achon.

21 DATE: 2/8/2019 s/Sara J. Vanee 22 SARA I VANCE, CERT 3 (Page 9) For The Record, Inc.

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PTC -000097 41 DUN & BRADSTREET, INC.

Complaint FTC-00009741 OFFICIAL TRANSCRIPT PROCEEDING FEDERAL TRADE COMM] SSION 1723196 DUN & BRADSTREET RECORDED: DATE UNKNOWN TRANSCRIBED: APRIL 20, 2020 | THROUGH 21 FTC-00009741 (mm baw FEDERAL TRADE COWMISS1OM INDEX PAGE:

Ce SEGRE i ee ee BERSRGEGEE 4/20/2020 PEDERAL TRADE COMMS5 [ON In the Matter of: i Dun & Bradstreet Matter No. 172316 Date Unknown The following transcript was produced From a File provided to Por The Record, Inc. om April 9 PROCEEDINGS FTC 00009741 All right. So what are you trying ta pet done? PETES company. We have decent revenue 4 I’m trying to establish credit im the we have 30 probably vendors we pay every month, and [ realized we're not establishing any credit. So | wanted to f what's the best process to do couple companies so I'm just trying: 2 our steps are to pet our holding company to establish credit.

NIC you with th So To can definitely help which I Absolutely.

Now, ts the holding company may be looking at sone ig tetally different. But attached to your phone mumber, there ts a business by the youre referring to? 1 (Pages 1 to 4) For The Record, Inc.

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Complaint FTC-00009741 Dun & Bradstreet 4/20/2020 9 Il 1 PETER: Yeah. You know, there's no = there's 1 PETER: 250. 2 no selling -- selling up or anything like thar. 2 NICKI: Okay. So you've definitely grown over 3 NICKI: Yeah, I’m going to = I"m actually 3 the last few years. That’s amazing. 4 pulling it upon my phone, too, so that I have it when I 4 PETER: Yesh Well, that — in this company, 5 get home. That is really cool. 5 yes, with the schools 6 PETER: Yeah. yeah. 6 NICKI: Okay. 250. And— 7 NICKI: Okay. 7 PETER: And this is under not 8 PETER: We're on iTunes and Android, all the 8 9 Google Play store, everything. 9 NICKE Yeah, no, n0, no, no, yeah, under 10 NICKI: Okay, cool, Yeah, I'm going to 0 on 10 il it. All night. So. yes. we do need to get a number li PETER: Yeah, okay. 12 generated for 12 NICKE: Yep. I have to -- because there's not 13 PETER: Okay. 13 a number in this (inaudible) have to fill in all of the 14 NICKI: And it — like La ezg. 14 spaces.

15 right? 15 PETER: Okay.

16 PETER: Correct, yeah, yes 16 NICKI: Yeah.

17 NICKI: 0} 17 PETER: Okay.

18 PETER: oR 18 NICKI: And thea what are your — your revenue 19 NICKI: Okay. And then what I'm doing now is 19 per year? Your revenue? 20 I'm loading your other business, So I'm going to pull up 20 PETER: Let me see. We added some new schools, 21 that credit information. This way, we can compare and 21 so let me (inaudible). 4,8 million 22 see like if the address is going to be the same and I can 22 NICKI: Okay. Oh, yeah, we definitely need to 23 just copy and paste a lot of it. Which is it - is this 2. start showeasing some credit history for your business 24 business at Road? 24 And then I'm sure once you use - you said that you were 25 PETER: No, that's old. yeah. 25 opening some new schools, nght? 10 12 1 NICKE: Oh. okay. 1 PETER: Yes, uh-iioh 2 PETER: Yeah. 2 NICKI: Okay. Are you projecting that 3 NICKLE So what's your new address or current? 3 that what's going to make you hit the 4 - 4 million, 4 PETER: Our address -- our current address is 4 4.8? 5 ii -- L PETER: Well, we're currently doing 4.8. 6 NICKI: Okay 6 NICKI: Okay, okay. So once you open those new 7 PETER: And it's -- 7 locations, then it’s going to grow quite s bit more? 8 NICKI: 8 PETER: Yes, yeah, exactly G PETER: 9 WICK]: Okay. Now, as far as Dun & Bradstreet 10 NICKEL Oka: 10 18 concerned, you know, I'm going to help you build this 11 PETER: — re" just an NW — iB credit report and showcase the financial stability of the 12 NICKLE Uh-huh. 12 business, Are you planning on using this number for any 13 PETER: -- and then suite 13 purpose. you know, a bank loan, new vendor accounts, 14 NICKI; Okay. 14 customers? 15 PETER: And it’s 15 PETER: Nothing -- yeah, but T've had some, you 16 NICKLE: Okay, 9 - you sai 16 know, vendors ask us, you know. fora Dun & Bradstreet 17 PETER: Yeah, 7 mumnber. We acquired these two} schools and. 18 NICKI: Okay. perfeet. All right. And you are 18 you know, they were schools that are 15 years old. So 19 100 percent owner or do you have business partners? 19 they have a lot of history. 20 PETER: [havea partner. mf 20 NICKI; Wow, Mm-hmm, Yeah, and that could be 21 NICKI: Okay. So we list your partner, too, or 21 concering because some of the vendors amd suppliers that 22 is it okay just to have your name for now? 22 they're already dealing with because - not saying that 23 PETER: Yeah, mine for now because he’s silent. 23 your business is going to fail or anything, but a lot of 24 NICKI: Okay. okay. perfect. And how many 24 times when people buy companies, the percentages of that 25 employees do you have? 25 business succeeding goes down quite a bit. especially new 3 (Pages 9 to 12) For The Record, Inc.

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Complaint FTC-00009741 Dun & Bradstreet MO 6d 1 OR Wa ele bo ee information with them. What they really do 1s — I guess it’s a platfonm where if, for some reason, they see like your business information or your email on the dark web, they'll send you alerts and notifications so that you ean, you know, change your passwords or something hke that to help prevent you from getting hacked.

PETER: Okay.

NICEI: And then the service 1s set for autorenewal each year at the cwrent price -- at the then current price.

PETER: Okay.

NICET- So] submitted everything Let's schedule a call sometime next week, Peter. Once you get the mamber, I would hke to show you where to submut your payment history and kind of walk you through it so that you know what you're domg because it can be a little confusing at first. But once you get the hang of it -- PETER: Okay.

NICEI: -- it's pretty simple.

PETER: Okay.

NICKEI: So you should have your number in three to five days. How about this? Let me email you my contact and if you get it sooner, then you can call me. If mot, then we can schedule for ike next Fnday. Would that work for you? PETER: Yeah, that would work.

NICK: Okay. But ifyou get it sooner, then I want you to call me.

PETER: Okay. Yeah, I just got all the stuff that you just — NICKI: Okay, cool. And you can actually log in now and reset your passwords and everything.

PETER: Okay.

NICKI- Let me — PETER: Yeah, I'm (inaudible).

NICKI: Where’s my email? (Pause.) NICKI: Hold on one second I don’t know where — my ema was closed out for some reason.

(Pause.

NICK: So how did you come up with that program? i , PETER: Ob, it’s just years of previous stuff that we were dog (audible).

NICKI: Thatis so cool, And it’s such a nice website, toa.

PETER: Ob, yeah, there's — it’s very coal.

There’s lke a thousand employees out in| that actually do all the — the animation and g Em and all that.

Sa ww el be 4/20/2020 NICEI: Yeah PETER: (Inaudible).

NICEI: They did such a good job on it.

PETER: Yeah, it’s -- it’s really -- there's over six mullion kids using it. So it’s pretty cool. NICEI: Thatis so awesome. And actually you said that there is an app, night? PETER: Yeah, there's apps and you cam just log m once you get a subseripion. Send me your stuff. Tl send you a code next week so you can use it.

NICEI: Okay.

PETER: I'll give you a free year.

NICEI: Yeah, coal.

PETER: Okay. That way -- I'll send it to you next week. All my staff's leaving nght now.

NICE: Okay, okay, awesome. Like just my Gmail email and staff hke that? PETER: Yeah, send that to me and then I'll send you a code that wall give you a free subsenption for a year.

NICE: Okay.

PETER: And it’s up — it's good for up to three kids.

NICEI: Awesome. Thatis so exciting. Okay.

And I just sent you an email with my contact mformation, too. So, yeah, let's schedule some time next week and Tl give you the walk through and show you how to do it And lke I said, I mean, [know that you are a growing business and openmg and mmning, you know, seven schools 1s probably not the easiest.

PETER: I have — yeah, I have a whole staff, though 5o] -- NICEI: Okay.

PETER: --T'll have my operations person, her name is Brittany.

NICEI: Okay.

PETER: And Pll introduce you — Tl introduce her to you Friday. And then you cam show her and she can do everything.

NICEI: Yeah, okay, perfect. Sounds good.

PETER: Allnght. Okay, sounds good. Thanks alot.

NICEI: Okay, you're welcome.

PETER: All nght. all nght, see ya, bye.

NICEI: Bye. Have a good weekend.

PETER: You, too.

PETER: See ya, bye.

(The call was concluded} (The recording was concluded} 5 (Pages 17 to 20) For The Record, Inc.

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Dun & Bradstreet April 20, 2020 ron Condensed Transcript with Word Index For The Record, Inc.

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Complaint FTC-0000978 | Es Dun & Bradstreet Co -) R L e le he i te publish -- you publish bhe my business name, correct? JONATHAN: Yeah, go ahead JOSEPH: And I understand it will be categorized so people know how to get to me and theyll be able to see how big the busmess 15, you know, that kind of the, correct? JONATHAN: Yeah, that’s -- let me just kind of cover the bases just to be safe, okay? JOSEPH: Sure. Certamly.

JONATHAN: Dun & Bradstreet, kind of ike how Equifax or Transunion hold our personal credit, we're the ones who house the credit reports for companies worldwide, stnctly busmess. 5o to put this into perspective, ckay, your legal structure, the LLC, 1 assume you set it up to help protect yourself from tax and lability purposes, nght? JOSEPH: Yes, correct.

JONATHAN: So let's just say, for example, you go out there and you open a credit card for the business and you end up puting down your Social Secwity number to secure the card, which ts oftentimes what these banks may ty and get you to do, regardless of the legal structure that you have. If you use your Social Secunty number, you end up puting that hability back on yourself. You're still responsible.

JOSEPH: Ah I see.

JONATHAN: That's where we come into play.

JOSEPH: I see.

JONATHAN: Drm & Bradstreet, we're gome to assign to you what's called a DUNS momber. You're going to have a DUNS number throughout the life of the business, whether you want it, need tt, or know it. It's still mine digits. So any time you're setting up any type of credit accounts moving forward, it’s umportant that you are proactively using this DUNS oumber alongside that tax ID number or the EIN number to help you build real credit for the busimess or, more importantly, use it m place of your own Social Security number. So you're helping to separate yourself fmancially. You're helping to protect your personal credit and your assets and you're letime the company stand on its own.

JOSEPH: Yeah.

JONATHAN: Does that make more sense? JOSEPH: Yes, of course.

JONATHAN: Okay. So my job, Joseph, 15 to make sure the information Legal7oom is sending us is accurate and make sure the report is set up correctly for what you're trying to accomplish because -- JOSEPH: Excuse me.

JONATHAN: No, no wornes, man. Make sure the SOOO = GA dae at et 4/20/2020 report is set up correctly for what you're trying to accomplish because busmess credit 1s reported a lot differently than personal credit.

JOSEPH: Yeah.

JONATHAN: $e I'm just goime to run through what we have. Furst, if there's anything that you need changed or updated, you let me know so I can subumt the changes for you, okay? JOSEPH: Okay.

JONATHAN: Okay. So, Joseph, almost -- we have you currently hsted as the owner of the company. Is there any other titles that you want to be hsted as? Principal, president? JOSEPH: Um, yeah.

JONATHAN: CEO? JOSEPH: President. Yes, president probably, okay? JONATHAN: Yeah.

JOSEPH: CEO, that would be fine, too. It's just -- basically, rt’s yust me at this point.

JONATHAN: Okay. 1 ya. Address that I show sons - correct, yes.

JONATHAN: Is that also gome to be the maine address? JOSEPH: Yes.

JONATHAN: Perfect. The show for the business 15 JOSEPH: Yes, correct.

JONATHAN: And any other phone number or fax one number that I mumber that you need listed? JOSEPH: Yeah, fax number Baer JONATHAN: Okay. And do you have a site that you would like listed? JOSEPH: I don’t at the moment.

JONATHAN: Okay.

JOSEPH: I do nat.

JONATHAN: Now, is there anybody else that you need listed on the report besides yourself? JOSEPH: Nope, just me.

JONATHAN: Perfect. You're the only one that’s going to be able te use this DUNS oumber m place of your Social. You started the busimess this year, 2019. Congratulatons, agam. Do you have any employees or JOSEPH: No, it’s just myself at the moment.

JONATHAN: Allnght. How about the estumated sales? What are you projecting for the first year? What's your goal? 2 (Pages 5 to 8) For The Record, Inc.

(301) 870-8025 - www-ftrinc.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 625 Complaint FTC-00009781 Dun & Bradsireet on ee ee JOSEPH: Mm-hmm.

JONATHAN: — buge opportunity there, nght? JOSEPH: Sure. Sure. I may go doit.

JONATHAN: So it’s -- exactly. If Starbucks wants to make sure that you can deliver a5 many tappers as they need, that’s typically where they pull the report, Make sure you're financially stable yourself. There's no lawsuits, liens, judgments, bankruptcies, things of that nature.

Have you — have you set up any type of credit accounts with like vendors, suppliers, sheet metal company? JOSEPH: Not yet, but that’s another step.

That's comme up.

JONATHAN: Okay. That's also where the report may come into play. When they're negotiatme giving you terms of even credit lines, a lot of tumes they pull the report, again, just to make sure you're financially stable yourself. It’s a common busmess practice.

Where do you see the -- that prodect m the next, let’s say, 6 to 1? months? JOSEPH: Well, it should be — it should be in full production by then and -- yeah. Amd tt should be -after I’ve done all the research of getting — you know, you got to get to the nght people — JONATHAN: Yeah.

JOSEPH: -- obviously trade shows that do all this as well — JONATHAN: Mm-bmm JOSEPH: — and to many of those. You know, just exposure is probably gomez to be a big -- you know, petine that first exposure out there is my big push. JONATHAN: Absolutely. What about the — you said something about a product that youre developme for a patrol car? JOSEPH: Yeah. It’s a -- you've seen — you've seen the way there's patrol cars with a push bumper in the front? JONATHAN: Yes.

JOSEPH: Yeah, yeah. Well, one of the thimgs that P've known — [ve seen and watched many times when the police pull somebody over, they usually -- they actually detam that person. They usually make them sit on the ground.

JONATHAN: Mm-bmm JOSEPH: I'm developmg — I'm developing a fold-down seat that mounts nght in that front bumper so they sit there instead of the ground — JONATHAN: ‘Got it.

JOSEPH: — facing the policy, so they can oo =) OW Un ee le poo 4/20/2020 contact them and talk to them -- JONATHAN: Okay.

JOSEPH: -- and secure them. Once that police officer puts cuffs on him, he’s there responsibility to (imandible) — JONATHAN: Oh, yeah, absolutely.

JOSEPH: -- and walks out into traffic, he’s dead and it’s his fault.

JONATHAN: Yeah, I got ya.

JOSEPH: It’s a -- it’s basically a very simple fold-down seat -- I’m surpnsed nobody's dome it before —- to sitis basically what it comes down to. And I'm in the process of building a prototype of that at the moment as well.

JONATHAN: Where are you in the development stage? JOSEPH: We've got ome piece that is -- we're wattng for a latch. Everything else is done. We should have it up and running here in the mext couple of months. JONATHAN: Okay.

JOSEPH: And, again, it will have to be -- you know, we'll get it mm front of the people that cam give us feedback and we can go from there.

JONATHAN: Absolutely. So oftentimes -- ch, so you're going to be dealing worth like the state, the city and things of that nature, law enforcement? JOSEPH: Yeah, nght.

JONATHAN: Okay. So the city, the state, they will primarily use this DUNS oumber so they can pay you on the products they purchase from you, okay? JOSEPH: Min-bmm.

JONATHAN: They use -- JOSEPH: Yeah, nght.

JONATHAN: -- they use the DUNS number hke a tacking system between you two. Now, same concept. If they want to make sure if you're -- you know, that aspect alone, just having a DUNS mumber ts for -- just so they can pay you. But m the same -- im the same respect, if they want to make sure you can deliver goods as promised, they want to make sure you're financially stable, that’s within your best mterest to start reporting the bills. Business credit, it’s not like our personal credit. Like my personal credit, for example, my mortgage company, credit card payments, car payments, these things report on nse automatically. As an imdividual, all I really have to do is pay oxy bills on time.

Now -- JOSEPH: Mim-bmm.

JONATHAN: -- im the busmess world, it’s really more about the cash flow. Where are you going to 4 (Pages 13 to 16) For The Record, Inc.

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Complaint FTC-0000978 | as Dun & Bradstreet Md 2 OR a ele bo ee everything listed as pending for the next three to five business days. So we have the DUNS number imked to the legal structure.

Now, I'm assuming your termtory is going to be all of the U.S., nght? JOSEPH: That’s correct, yes.

JONATHAN: Canada as well or -- JOSEPH: Yeah. I'm sure Canada would be -they dank coffee JONATHAN: Yeah. I don't know anybody that doem’t. Oh, that’s fimny. So what made you —- JOSEPH: Well. actually the world.

JONATHAN: — take a stab? JOSEPH: I mean, just watching — I’ve been drinking coffee the same way all my life and I just realized that] get a better cup of cappuccino -- ] mean, they compact that coffee really ight. You've seen -they have a specific tapper there as well.

JONATHAN: Yeah.

JOSEPH: This is — this is — this is slightly different, but rt’s on the same le, same concept. And so they're missing — they "re missing one mportant step to makme the best coffee.

JONATHAN: Okay. How did you discover it, though? That's my question.

JOSEPH: Watching videos of people makme the best coffee -- pour-over coffee and thinking -- JONATHAN: Okay.

JOSEPH: -- well -- JONATHAN: I got ya.

JOSEPH: -- well they want -- put (inaudible) and they weigh it. They weigh the water. They have the water at a particular temperature.

JONATHAN: Mm-bmm.

JOSEPH: But they don't — they don’t compress the coffee. You need -- you need te compress 1 You need to tap it down and compress it. And they also talk about making sure you pour that coffee directly m the center of that pile of —- JONATHAN: Mm-hmm.

JOSEPH: -- you know, coffee. Well, I puta title spot there so that's lke a target. It’s hke a little pit.

JONATHAN: Yeah JOSEPH: The name of the product is (Gnaudible). It’s called| JONATHAN: Yeah. Nice. | love at. [ love rt.

JOSEPH: It takes seconds, but I’m tellmge you, you ll see a different cup of coffee.

JONATHAN: I got ya. Okay. You'll zet the a ee 4/20/2020 links and passwords here shortly. It’s the Credit Builder Program. We're spliting it up into three payments, 899. The first payment is going to be 799.67. ‘What's the method of payment you want to use? JOSEPH: It would be a credit card.

JONATHAN: Visa, Mastercard, Amex or Discover? JOSEPH: Ob, let's -- let's say — hold on Let me — let me get to that.

Okay. It would be Visa.

JONATHAN: Okay. Go ahead with the number whenever you're ready.

JOSEPH: Okay.

JONATHAN: Same billing address, nghi? The JOSEPH: That's correct, yes.

JONATHAN: Okay.

JOSEPH: It is [REDACTED] JONATHAN: And the expiration date? JOSEPH: [REDACTED].

JONATHAN: You're gettmg the Credit Builder Program. Let me just reiterate this for -- just for comphance purposes. Agam. you're getting the Credit Builder Program, $899 with the Legal7oom discount, spliting it wp into three payments, 299.67 for the first payment. You have a second payment due 30 days from today. Fimal payment, 60 days. That will give you full aecess for the next 12 months. We do have your permission to process that Visa endime in im the amount of 299.67 for the Credit Builder Program? JOSEPH: Yes.

JONATHAN: Perfect. You'll get the recerpt there shortly. Make sure that you save that for tax purposes because you can possibly wiite it off asa business expense. You're also going to be getting a Busimess Advantage Plus from Legal7oom Now, this is absolutely free. They're zomg to prowide you with a co sive calendar that’s going to alert you to any key filimgs that might be essential for the busmess and you'll also have access to the legal library, which you can use for busimess or personal use throughout the course of the Credit Builder Program.

Lastly, the program 1s typically set up to automatically renew same tome next year at the thencurrent price. What I would recommend that you do is just set yourself up a time reminder for about nine, ten months down the road. The payment history that we capture and verify and put m the report mow, it (audio malfunction) in the report for up to 24 months.

So if you're going to be dog busimess with the same (audio malfunction) year after year, you may 6 (Pages 21 to 24) For The Record, Inc.

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(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit H VOLUME 173 Complaint DUN & BRADSTREET, INC.

Complaint FTC-00009825 iE Dun & Bradstreet 4/20/2020 5 7 1 with that. So do-you have hke a prospective customer 1 services that you're paying for. 2 who may be lookimg into your report or are you gomez to 2 IGOR: Okay. Yeah, I can provide it, sure. 3 be applying for any sort of like credit or financimg in 3 CHELSEA: Do you have lke a rough estumate of 4 the future? s how mmch that would be? 5 IGOR: Mo, we're planming to deal the — have 5 IGOR: An estimate, it should — for the past 6 a business with government agencies and — especially 6 12 months? 7 (GSA and (mandible) asking for a record -—- to have a 7 CHELSEA: Mm-bmom § rating -- a credible -- to have -- to be credible and 8 IGOR: Something about 300- to 350,000. 9 having a rating and record -- 9 CHELSEA: Wow, that’s huge. So especially if 10 CHELSEA: Sure. 10 you're gomez to be anticipatme to have customers looking ll IGOR: -- fom your company. ll at your report, we want to make sure that you're 13 CHELSEA: Perfect, yep. (Inaudible) the free 12 showcasing that so that way they can see the size of the 13 DUNS mumber so that makes sense. So what is the hme of 13 company, the financial stability and the credibility of 14 busmess? What do you do exactly? 14 your business. So what we'll dois we'll get inks and 15 IGOR: Architect. Architectural company. 15 logins sent to your email once the DUNS number ts 16 CHELSEA: Okay, great. 50 do you typically 16 assigmed to you. 17 only deal with government or do you have like commercial ly IGOR: Mm-bmom 18 chents as well? 18 CHELSEA: Just email me the contact information 19 IGOR: No, we deal with commercial and private 20 chents and now we would like to reonent our company 21 toward the public sector.

2 CHELSEA: Okay, great. Yeah, so especially 23 when you're dealing with commercial chents, they will 24 typically come to us to look at your mfommation as well. 5 They want to make sure, of course, you're safe to deal 19 of who you're gomg to be making payments to and then our 20 trade department is gomg to do the rest of the work from 21 there by calling those compames to verify how much you 22 spent with them, the percentage that was paid on time, a3 and if you have any tens with them. And then once we 24 verify that nfonmation, then that gets added mto the 25 report. It’s a really easy process. I just need a 6 8 1 with, you're financially stable and see the credibility 1 little bit of mformation from you and we basically take 2 of your company. So the way you submitted the 2 over the rest from there. 3 application, it leaves your file meomplete, which means 3 What is your projection for revenue for this 4 you don’t yet qualify for all seven scores and rahngs 4 year? Do you have an idea of what that would be? 5 that are attached to the DUNS mumber. 5 IGOR: It’s tough With today’s market, I 6 So what we'll dois we will inthate a 6 cannot really tell. But -- 7 background check. It only takes three to five business 7 CHELSEA: Sure. g days. We don’t need any legal documents from you. We g IGOR: -— we hope that it’s gomg to meet — I 9 just simply —- 9 don't know. I mean, m the same -- I cannot really tell 10 IGOR: Mm-bmm. 10 you I don’t know.

ll CHELSEA: -- just confirm that the company is ll CHELSEA: Okay. We can leave that blank. 12 registered, verify if there's been any lawsuits, liens, 12 IGOR: (Inaudible). 13 judgments, bankruptetes, things of that nature, and then 13 CHELSEA: Yeah, no, that’s fine. 14 once completed, you'll be qualified for the full set of 14 IGOR: We're hopimg between 3- to 400. 13 scores and ratings for the hfetime of your business. 15 CHELSEA: You said 2- to 4007 16 IGOR: So your ratings are mainly driven off of 16 IGOR: In between 3- to 400. It’s vanous. l7 your payment history. Do you have any idea how much l7 CHELSEA: Okay, allnght. Great. So how much 18 you've spent within the last 12 months? We can go back a 18 is ome customer usually worth? Is it different for each 19 year im payment history and capture those expenses you 19 one or are they roughly the same? 20 had and get that added into the report to help you build 20 IGOR: It’s -- we're dealing with a different 21 up your file. 21 -- with private sector customers through developers. 72 IGOR: Is that -- is that spending including 22 (CHELSEA: Sure. 23 the employees’ salanes, office expenses, those type of 343 IGOR: So we're working with the different 24 expenses? 24 types of projects. So they could be $5 million to $30 25 CHELSEA: Yep. Any -- yeah Any prochocts or 35 nullion projects. 2 (Pages 5 to 8) For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (B00) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC.

Complaint FTC-00009825 iE Dun & Bradstreet (Pause.} IGOR: Okay, go ahead.

4/20/2020 1 CHELSEA: Yeah. So the total would be £99, but 1 for the 799.67, plus any tax today. Hang on to your 2 if you want to break it wp Into payments, it would onky 2 racerpt because it would be a potential tax wniteoff at 3 be 299.67 and then plus any applicable tax. 5 the end of the year. 4 IGOR: Okay. 4 And we do have a partnerslup with Legal7oom. 5 CHELSEA: All nght. 5 They're going to send you an email. You have additional 6 IGOR: Is ot 899 for the year or 1s it just for 6 benefits with them at no extra cost to -you. 7 one? 7 IGOR: Mm-hmm.

8 CHELSEA: It’s all -- soit’s gome to cover 8 CHELSEA: And then you already have the DUNS 9 you for 12 months. You can choose to renew it at the end 9 number, so you're set with that. Grve me three to five 10 of the year 1f you would like after the 12 months 1s 10 busmess days for the background check to be completed. ll done. So ultimately up to you. ll And. agam, once that’s completed, 1t completes 1t for 12 IGOR: All mght. Okay. 12 the lifetime of the business. So you'll be all set with 13 CHELSEA: Okay. 13 that. You won't have to worry about that moving forward. 14 IGOR: Okay. I'm gommg to -- okay. You zomg 14 Do Ihave your authonzation te run your 15 to take the card or call me back? 15 American Express ending in [REDACTED]? 1é CHELSEA: Yep. I take method of payment over 16 IGOR: I guess you're going to send me an email 17 the phone. I can get everythimg processed on my end, and l7 of this, no? Can you do that? 18 then once that’s completed, you'll recerve the recerpt 18 CHELSEA: Yep. So you'll have the confirmation 19 and the links and logins to your email. 19 with that once I] process the payment. 20 IGOR: Okay. 20 IGOR: Okay.

21 CHELSEA: All nght. 21 CHELSEA: So let’s see here. And then I have 22 IGOR: Hold on one ser. a your authonzation to process that, correct? 23 CHELSEA: Okay. 23 IGOR: Okay, yeah.

CHELSEA: Yep, okay, perfect. All mzht So you'll recerve that receipt here im just a moment. And 14 16 1 CHELSEA: Okay. then I will be back m contact with you as soon as we 2 IGOR: American — American Express. have the report completed to let you know that everything 3 CHELSEA: All nght 1s squared away with that and then, of course, just feel 4 IGOR: And the card number [REDACTED]. free to eve out the DUNS number any time you're being 45 CHELSEA: Okay. asked for it, okay? 6 IGOR: [REDACTED]. IGOR: Okay. Sounds good.

7 CHELSEA: Okay. CHELSEA: All night.

g IGOR: [REDACTED]. IGOR: Thank you very much 9 CHELSEA: And the expiration? 9 CHELSEA: You're weleome. You have a great 10 IGOR: [REDACTED] 10 rest of your day.

11 CHELSEA: [REDACTED]. 11 IGOR: You, too. Bye-bye. 2 IGOR: [REDACTED]. 12 CHELSEA: Thank you. Bye.

13 CHELSEA: [REDACTED], okay, perfect. And then 13 (The call was concluded.) 14 the billing address attached to the card, ts 1 the 14 (The recording was comeluded) 15 updated address? 15 16 IGOR: No, it's the previous address, 16 eee :

18 : ry, ndo you want 18 19 to have it pard im full or do you want to break it up 19 20 inte three payments? 20 21 IGOR: I'd like to break it up into three al 22 payments. 22 24 CHELSEA: Okay, perfect, So I'll get you set 343 24 up with your Credit Builder Basie for the total of the 24 3 899, but we're just gome to process the Amencan Express 4 (Pages 13 to 16) For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (B00) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 635 Complaint Exhibit I In the Matter of:

Dun & Bradstreet April 20, 2020 Frc-000) an Condensed Transcript with Word Index For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit | VOLUME 173 Complaint a ee ee ee bh eee ee ee RS 81.6 6 me toe be a a bh ba bot tan te ba bs WO 68 J OR LA de lo boo DUN & BRADSTREET, INC. 637 Complaint FTC-00009660 ay Dun & Bradstreet a MARE -- it's just me.

CHELSEA: All nght, sounds good. So before I go any further into the application, what was the reason for requesting the DUNS number? MARE Because most of my potential customers, they require a DUNS number.

CHELSEA: Sure.

aKk That's one.

CHEL: 2 ay.

MARK BBE find that’s on the commercial side. And then I’m also an Apple software developer. CHELSEA: Got it.

MARK J You know, I can — and then Apple requires that for enterprises.

CHELSEA: Okay.

MARK BBB And then, also, I'd like to go after government contracts, so they require a Don & Bradstreet number as well.

CHELSEA: Yeah, absolutely. So you're dog everything, nh? Yeah, you're absolutely nght, whereas as Apple and government, they do require the free DUNS number that we're getting you set up with now. Have you had a DUNS number before? MARE) No, ma‘am.

CHEL!' : No! ay, perfect.

MARE) No.

CHELSEA: make sure we get you set up properly, so that way you're able to do the things that you're looking to for the company. So what do you do specifically with this company or like whatis the -whatis the desenption that should be listed here? MARE Yeah. So this is a -- the name of the company, you know, ends with CHELSEA: Okay.

MARE) And essentially it’s a laboratory for ideas and mnovaton for technology applications focused on supply chain.

CHELSEA: Okay, wonderful, all nght. And then so] have supply chai and logistics technology consultants. So -- MARE) Correct.

CHELSEA: -- basically that sounds (imaudible) what you just (inaudible).

MARK SY It’s kind of broad, but I kind --it refers to -- (CHELSEA: Yeah.

MARE — the industnes ['m going after, yeah.

CHELSEA: It’s easier that way, for sure.

Yeah, that was going to be my next question is, who MO oO de et 4/20/2020 exactly would your customers be on the commercial side? MARE Like consumer package goods companies, distibutors, you know. When I say CPG, lke Kellogg, Peps -- CHELSEA: Oh MARE -- and then those kinds of companies. om the -- on the other side, it would be retailers like, you know, Walmart, Target, grocery stores. So amyone that kind of, you know, receives products, anyone that ships products, and everything that's m between.

CHELSEA: Gotcha. Okay, perfect. Yeah. So Walmart, they require the free DUNS number as well. So if you ever are tryme to do business with them, then you'll be all squared away with that, too. But it definitely makes sense as to why they may be asking for the DUNS manber or if you're anticipating them to ask. Usually if you're going to be dealing with larger companies lke that, they're zomg to come to us to review your information, make sure you're safe to deal with, you're financially stable, things of that nature. MARE) Correct.

CHELSEA: So you have a set of seven scores and ratings attached to the DUNS number. That’s usually what they're looking at. Those scores and ratings are mamly driven off of your payment history. Have you mvested money into the c yoo far? Thnow vou're fairly new. MARE) Just -- past -- it's very mew. | wvested just to buy nay first asset, which wai — CHELSEA: Okay.

MARE — you know, a computer for myself.

CHELSEA: (nandible) MARE So that's all I've done.

CHELSEA: All nght.

MARE And so if you were to do a bank account check, you Il see the money that’s im there, which is my $3,000.

CHELSEA: Okay.

MARE) CHELSEA: All nght.

MARE) -- to put inte the bank.

C : sure, of course.

MARE) But the -- but the bank that Twe been wimg, [ve been with this bank for, you know, since 1994, CHELSEA: Mm-bmm_ MARE) And they have oy lostory.

c: :

That's about all I had -- 2 (Pages 5 to 8) For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (B00) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC.

Complaint FTc-00009660 iy Dun & Bradstreet nt S46 60 ~) oO un bo bo ee ha bo eee eet ee i el bo SG oo) on he ei ne a i ig MARE) Oh, okay.

CHELSEA: It's not hke you receive the DUNS number and then we mitiate the background check. It all gets done atonce. 50 that way -- MARE) Okay, got it.

CHELSEA: -- you're not having to mn into situations bike that. Yeah. So it makes it a lot easter. And, again, that only needs to be dome once. So you'll be all squared away and then they'll be able to see that we have confirmed your background, your operations, you'll have the full set of scores, and then they can evaluate your company based off of that data. MARE) Okay.

CHELSEA: So obviously, the more information you report, the better off you're going to be. So we will get the links and logins sent to your email, so that way we can self-report the expenses that you're going to have for the busimess. So the money that you've already spent -- and I would even try gettmg your accountant to add it m here if'you're going to be having that indtvidual help you with the busimess, too. That would be 2 good expense to have submitted into the report. MARE) Yep.

CHELSEA: So checks, your payment history and, of course, whatewer expenses you're going to have moving forward, send me that information so I can log it into your report and our trade team can begin calling those companies to build up the report as time goes on. In onder -- MARE So post this call -- after this call, will you s 22 littl email so I know what I need to send you? CHELSEA: Absolutely, of course. And I was assigned your application, so I'll be with you every step of the way. So what Ill dois Pll send you a list of trade references. We can go through that list together and see what you do have, get that information added in there first. And then, also, it pust gives me an idea of what types of companies or mdusiries to get set up with in the future. that will have a good impact to your report.

And you don’t even have to have a credit account set up, but at least salvage some sort of relationship, make payments, whether it be lke Office Max or Staples, something like that. So that way we're continuing to build up the report. And when your chents are lookme at it, you're showcasing your company in the best light. So ll get all of that sent to the email address that we have listed here.

In order for us to inttiate the background SOOO = GA dae at et wo 4/20/2020 check and to get the imk: and logins so that way you have the full access to the report, that 1s through a Credit Builder Basic platfonm. We just roll this out to newer companies. This does retail at $899 and then we do take debut, credit or e-check with the account number, rowing number, whichever you prefer.

MARE) Tl do the credit.

CHELSEA: Okay.

MARE) T'll do the credit card.

CHEL : Okay. And then is ita Visa, Master, Dascover, American E:

MARE) second Let me -- CHELSEA: Okay. Take your time.

MARE) Let's see, I just got rt.

ress! Tt isa Visa. Hold on one Okay. It’s a -- at's a Visa.

CHELSEA: Okay.

MARE CHEL, : Te MARE You ready for the number? It's [REDACTED].

CHEL : ay.

MARE) [REDACTED].

CHELSEA: Okay. And the expwaton? MARE) [REDACTED].

CHEL : ay, perfect. And the bilime address attached to the card, 15 it zomg to be the same one that’s on the application? MARE Correct.

CHELSEA: Okay, perfect. Allnght So we'll get you set up with the Credit Builder Basic. So the total amount’s gomeg to be the 899, no tax m your area, so you're all good with that. Hang on to your receipt because it could be a potential tax wiiteoff at the end of the year. And then we do have a partnerslup with LegalZoom and Redact-It, so you'll have addihonal benefits with those co: 165 at no extra cost te you. MARE Got it.

CHELSEA: And then do I have your authonzation to mm the Visa m DACTED]? MARE Yes.

CHELSEA: Okay. 50 you'll receive that recempt here m just amoment. And I will be back im contact with you a5 s000 as we get everythimeg set up. ll walk you through the report of you would like me to and, in a htile bit, I'll send you the list of references. So that way, whenever you get a free moment or over the weekend, you can get a list together and then do some research, And once everythmeg's assigned to you and you get the mks and logins, you can just send that over to me. All nght? 4 (Pages 13 to 16) For The Record, Inc.

(301) 870-8025 - www-ftrinc.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 641 Complaint Exhibit J In the Matter of:

Dun & Bradstreet February 13, 2019 FTC-00009577 Condensed Transcript with Word Index For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 FTC Exhibit J VOLUME 173 Complaint DUN & BRADSTREET, INC. 643 Complaint FTC-00009577 Dun & Bradstreet 2/13/2019 5 7 1 our product aow. And we're getting set up with some 1 now because I would have needed to doit at some point 2 new accounts, for instance, like Neiman Marcus last 2 or another anyway. 3 call. and we're in the process of getting everything 3 PETREA DICKINSON: Absolutely. Absolutely. 4 set up ‘oa purposes 4 So we'll mske sure that we pet you set up the right 5 PETREA DICKINSON: Mim-hm. 5 way 90 that Neiman Marcus and anybody else who looks 6 DAN And one of their requests 6 sees that you're a credible company and, you know, 7 was -- [ just recerved an email earlier from the 7 safe to do business with 8 implementation team over ee py amd they 8 > Absolutely, 9 were asking that, you know, we can complete your setup 9 P ¥ SON: So let me just do a quick 10 once we receive the following information from you, 10 search to make sure you don't already have a DUNS BI which is basically your DUNS number. | don’t believe 11 number, Dan. What's the name of the company? 12 we ever set one up. so know a little bit about DUNS. 12 DAN Okay. So che IRS name is 13 I just — we never set it up. I didn’t know if it was 13 -- so basically irs with auf 14 standard or needed to be done for every single. you 14 m front of it, he 15 know, corporation or company in the world, but maybe 15 PETREA DICKINSON; (Inausdible). 16 you can better assist me. 16 eas eee 17 PETREA DICKINSON: Absolutely. I can 7 PETREA DICKINSON: y. And what state are 18 definitely help you with that, Dan, How familiar are 18 you located in? 19 you with your DUNS number and how other companies 19 D. We are in and we're a 2 usually use if? 20 registered commpenty in the State o! 21 DAN T know it's pretty much a 21 PETREA All right, perfect, Are 22 unique ninedigit nw identifies your 22 you in 23 businesses. That's pretty much -- I think it’s got 23 A? That's — no. that was = 2 something to do with your credit file as well, but 24 are you finding the old address. 25 that’s about all I know for DUNS. 25 PETREA DICKINSON: mie just try = 6 8 I PETREA DICKINSON: That’s exactly right, 1 DAN We're a 2 Dan. So it’s attached to your company’s credit, We moved into that office in 3 report, and this is usually where other companies are 3 May a going to come when they want to do either a background 4 PETREA DICKINSON: Okay, so this one is on 5 or a credit check on the business. 5 6 DANG 00. okay. So it's a credit 6 DAN Yeali, that’s -- that’s no 7 — 80 You cai -- so you can actually nin credit 7 longer -- that's -- that's not the correct one 8 reports if you're looking to work with somebody? 8 anymere, Do you have the capability of changing that? 9 PETREA DICKINSON: Exactly, yep, and do a 9 PETREA DICKINSON: Absolutely. We'll get 10 risk assessment, make sure that theyre paying their 10 everything all up-to-date and make sure that we get ll bills on time, that there’s nothing risky about doing ll the report completed. It looks like you've already 12 business with them, like a bankruptcy or a lien or 12 had eight inquiries. so other companies. you know. 13 something, like that. 13 that have already requested a copy of the report from 14 oN Oh, imteresting. Okay, all l4 us 15 right, That makes sense 15 DAN Hmm, okay.

16 PETREA DICKINSON: So if you're trying to 16 PETREA DICKINSON: So it’s definitely good 7 set up with -- are these customers that you're 7 timing that you reached out to ns today so that we can 18 trying to do that with? 18 make sure we get it completed and everything is 19 DAN Yeah. they're customers. 19 accurate and up-to-date 20 This is all --I mean, so we're — we're in retail. 20 | For sure. 21 We're nationwide im a few stores. However. we did. 21 PE SON: So I know you said we 22 you know. paper hase orders. and just now they're 22 need to update the address, And, then, what year did 23 finally requesting and then we just picked up a 23 the company start? 24 new customer, Nenmman Marcus. They"re requesting 24 So the company was 25 So, you know, this is probably good that it happene: 25 established in 2015, but we came to market fast 2 (Pages 5 to 8) For The Record, Inc.

(301) 870-8025 - www.ftrine.net - (800) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC.

Complaint FTC-00009577 Dun & Bradstreet 2/13/2019 13 15 1 PETREA DICKINSON: = but what we do need to 1 DAN No. ne. Like for instance, 2 do is get some payment history updated here — 2 we're in nationwide, and they paid us, 3 DAN Min-haum. 3 1 think it was $114,000 in the last six months for our 4 PETREA DICKINSON: -- because that's one of 4 goods that we delivered to them. So, I mean, we -- we 5 the main driving forces behind your scores and 5 have payment history, for sure. I mean, country 6 ratings. 6 clubs, yacht clubs. other vendors, et cetera. 7 || Sure 7 So, | mean, it’s just a matter of how do I 8 PETREA DICKINSON: (Inaudible) bills you pay 8 show that and how do we strengthen this. and then 9 and how well you pay them. 9 also, how do I get the Dun & Bradstreet -- you know, 10 DAN Sure LO how do I get a DUNS number expedited? I guess I have 11 PETREA DICKINSON: About how much would you 11 to go through this entire process in order to get that 12 say that you're spending in operating costs, just ball 12 done first? 13 park, in a given month? 13 PETREA DICKINSON: So you actually already 14 pan Ball park in 4 given month, 14 have the DUNS number. It's just that it’s attached to 15 burn rate. is -- and I have this pulled up -- we are 15 an incemplete credit file. 16 somewhere around $20-, $25,000, 16 DAN Okay.

7 PETREA DICKINSON: Okay, So the problem 17 PETREA DICKINSON: So what we need to do is 18 Tight now. Den. with your report is with business 18 get you set up so that you get a completed report 19 credit. those companies, theyre not required by law 19 That's just going to ean that we confinn operations, 20 to automaticall rt that information + 20 make sure there are no lawsuits, hens, judgments — 2 DAN Mm-hmm. 21 DANG Y-p. yep 22 PETREA DICKINSON: = and they usually 22 PETREA DICKINSON: -- banknuptcies. And you 23 don't. 23 don’t have anything ra DANE on 24 | Men bene 25 PETREA DICKINSON: So we don’t have that 25 P ; ~ like that. right? 14 16 1 payment history, that financial strength -- 1 DAN eel No, nothing like that. nope. 2 . >a Sure. 2 FETREA DICKINSON: Okay, So and then we'll 3 PETREA DICKINSON; - in your file. 3 set you up so that you can add in the naines of those a AN Sure, 4 suppliers so we can help you start to build the 5 PETRE- SON: So what we need to do is 5 credit, 6 set you up so that you can start reporting the names 6 DAN Baa} Okay. How soon can I get my 4 of those companies. and then what we do on our part -- 7 DUNS number? 8 DAN Okay. 8 PETREA DICKINSON; So I'm going to give you 9 PETREA DICKINSON: - is reach out to them, 9 your DUNS number here. and — 10 contact them. confinm that payment history going back 10 a tt Okay 11 one full year if we can -- il PETREA DICKINSON; -- I'm also going to send 2 > Okay, okay 12 you out the links and logins so that you'll -- 13 PE SON; -- so we cat start to 13 a Great 14 move the scores and ratings in a positive direction 14 FETREA DICKINSON: = be able to log in to 15 DAN eee Okay, So T imagine -- am T 15s your profile, monitor all your scores. 16 going to have te create an onlime profile? 16 DAN Corea Perfect. Awesome. 17 PETREA DICKINSON: So we're going to send 17 FETREA DICKINSON: You'll beable to see by 18 you the links and logins -- 18 industry who looks at the report. So you'll be able 19 DAN Okay. 19 to control all of that moving forward 20 PETREA DICKINSON; -- along with your 2 DAN All right, perfect, I am 21 receipt. Now, about -- 21 ready for that when you are, I'll write it down and 22 > Okay. 2 then you can send me an email like you said. That -- 23 PE ‘ SON: -- how many vendors is 23 that's great, too 24 that 20- to 25,000 spread out between? Is it 5, 25, 2 PETREA DICKINSON: Absolutely, So your DUNS 25 105? 25 munber is going to | Ey 4 (Pages 13 to 16) For The Record, Inc.

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Complaint FTIC-00009577 Dun & Bradstreet it S66 ~~ ta bt ba ee bho eee ete ete SP S66 os m&un kh to ba =] a hob bot tan te ha bs Se That We Seo hel he =I bho bo boo bo la bh bo tan PE IN: -- so you're goimg to pay for -- from now until mext year -- DAN Mm-bmm.

PE IN: -- to add in those vendors and suppliers, and then we're going to contact them and confirm all of that. Then —- DAN Mm-bmm. 50 I can’t -- 50 you guys don't have an ophon of where -- 50 I pay the $1,500 one time today: we go ahead and get this set up; and then it’s up to me what] want to do. So technically I don't have to pay $1,500 every year, correct? PETREA DICKINSON: Conect. So, yeah, 1 can go ahead and put m a ticket for you so it will not automatically renew so that they reach out to you every year to find out what you want to do.

a Yeah, let's do that. Let's do that. I mean, yitsa while away, and -and, you know, next year, I’m sure when I talk to them, I'll say, yeah, go ahead and just auto, but -but for now, just keep it for -- let's -- let’s da this, let’s get it set up.

The 149 fee, are you -- are you -- I mean, I wish I would have asked about that or it was mentioned as well. Do you have the capability of warving that for first-time customers and something along those lines? PETREA DICKINSON: No, wnforhmately, I don't.

DN 149 setup fee. All mght.

And you're basically 2 me there's no way -okay, I understand how this works. So, really, technically, with the number that I have, I can just give them the number but there’s no information they can pull on us. So it’s to our benefit to have this filled out and get this taken care of.

PETREA DICKINSON: Absolutely.

DN I understand that, but I don’t want it renewed every year just -- at least for the first year we'll go — you know, we'll go — you know, we'll take it from here and we'll see exactly how many people are looking atit, how often they use it, et cetera. So — PETREA DICKINSON: Yep. And Tl send you over all my contact formation, Dan, so you'll know -- if you have any questions, if you want to Teach out to me I’m here to help.

DAN Okay. so 1,649. Andi really -— I haven't even talked to any of my — my i ee ee a ee ee se ee es ee ee Jhb bobo la bo bas atl 2/13/2019 other colleagues about this. I post figured I'd call right away and see, hey, how dol -- how do I go about PETREA DICKINSON: Absolutely, especially if your customers are asking for it.

DN Let me do this. Yezh, no, I get it, I get it.

PETREA DICKINSON: So log in with them -oa Do you -- yep, yep. Okay, let me see here. nent, 20 it looks like you guys already charged that, okay, even though I] didn’t give you the verbal yes. Okay. Hmm. trying to zet those sales in, huh? PETREA DICKINSON: Ob, I'm sony. I thought you did give me the go-ahead I apologize.

DAN No, no, ] newer gave you the verbal, and -- and if I didn’t, I would have said let me talk to my partner and what's your contact mformation. | understand how umportant tt 15 to get sales when you have them nght at the fingertips. You also billed me to the wrong address as well, and I thought that was corrected. I still see the ae here billed to.

DICKINSON: Correct. So I’m goimg to -- PEI IN: -- put ma ticket -- no, no, no. T° to put im a ticket -- PEI IN: -- so that we can get your address updated.

PEI SUN: When I send you my contact information, I'll give you a ticket mumber so you know — PEI IN: -- what that — DAN okay, and also do it — go ahead and put ma teket for the renewal. I don’t want this to be renewed unless I verbally agree to that.

PETREA DICKINSON: Absolutely, and our billing team will call you to confirm that.

a Allright. So, basically, what, it’s 1 today? PETREA DICKINSON: Correct.

DAN Okay. Okey-doke. All night, so I just got three emails from you obviously. I got the order confirmation; I got the CreditBuilder. So the CreditBuilder 1s what I'm gome to follow to go 6 (Pages 21 to 24) For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (B00) 921-5555 VOLUME 173 Complaint DUN & BRADSTREET, INC. 649 Decision and Order DECISION The Federal Trade Commission (“Commission”) initiated an investigation of certain acts and practices of the Respondent named in the caption. The Commission’s Bureau of Consumer Protection (“BCP”) prepared and furnished to Respondent a draft Complaint. BCP proposed to present the draft Complaint to the Commission for its consideration. If issued by the Commission, the draft Complaint would charge the Respondent with violations of the Federal Trade Commission Act.

Respondent and BCP thereafter executed an Agreement Containing Consent Order (“Consent Agreement”). The Consent Agreement includes: 1) statements by Respondent that, only for purposes of this action, it admits the facts necessary to establish jurisdiction; and 2) waivers and other provisions as required by the Commission’s Rules. The Commission considered the matter and determined that it had reason to believe that Respondent has violated the Federal Trade Commission Act, and that a Complaint should issue stating its charges in that respect. The Commission accepted the executed Consent Agreement and placed it on the public record for a period of 30 days for the receipt and consideration of public comments. The Commission duly considered any comments received from interested persons pursuant to Section 2.34 of its Rules, 16 C.F.R. § 2.34. Now, in further conformity with the procedure prescribed in Rule 2.34, the Commission issues its Complaint, makes the following Findings, and issues the following Order:

Findings 1. The Respondent is Dun & Bradstreet, Inc., also doing business as D&B, a Delaware corporation with its principal office or place of business at 101 John F. Kennedy Parkway, Short Hills, NJ 07078.

2. The Commission has jurisdiction over the subject matter of this proceeding and over the Respondent, and the proceeding is in the public interest. ORDER Definitions For purposes of this Order, the following definitions apply: A. “Billing Information” means any data that enables any person to access a customer's account, such as a credit card, checking, savings, share or similar account, or debit card.

B. “Business” means any business or other entity, including nonprofits, cities, counties, municipalities, and other governmental entities. VOLUME 173 Decision and Order C. “Charge,” “Charged,” or “Charging” means any attempt to collect money or other consideration from a consumer, including causing Billing Information to be submitted for payment, including against the consumer’s credit card, debit card, bank account, telephone bill, or other account.

D. “Clearly and Conspicuously” means that a required disclosure is difficult to miss (i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of the following ways:

1. In any communication that is solely visual or solely audible, the disclosure must be made through the same means through which the communication is presented. In any communication made through both visual and audible means, such as a television advertisement, the disclosure must be presented simultaneously in both the visual and audible portions of the communication even if the representation requiring the disclosure (“triggering representation”) is made through only one means. 2. A visual disclosure, by its size, contrast, location, the length of time it appears, and other characteristics, must stand out from any accompanying text or other visual elements so that it is easily noticed, read, and understood.

3. An audible disclosure, including by telephone or streaming video, must be delivered in a volume, speed, and cadence sufficient for ordinary consumers to easily hear and understand it.

4. In any communication using an interactive electronic medium, such as the Internet or software, the disclosure must be unavoidable. 5. The disclosure must use diction and syntax understandable to ordinary consumers and must appear in each language in which the triggering representation appears.

6. The disclosure must comply with these requirements in each medium through which it is received, including all electronic devices and face-toface communications.

7. The disclosure must not be contradicted or mitigated by, or inconsistent with, anything else in the communication.

8. When the representation or sales practice targets a specific audience, such as children, the elderly, or the terminally ill, “ordinary consumers” includes reasonable members of that group.

E. “Covered Product” means all CreditBuilder Line Products, either sold alone or with other products or services as part of a combined or bundled package; any DUN & BRADSTREET, INC. 651 Decision and Order product or service that includes an option to submit or add the names of or information about a Business’s vendors, suppliers, or other entities to that Business’s own credit report or credit file; and any product or service that Respondent markets to Businesses as being designed to allow a Business to monitor its own credit report, including CreditMonitor.

F. “CreditBuilder 2018” means the CreditBuilder “basic” product in the form that Respondent began offering in January 2018 and includes subscriptions with an initial purchase date (prior to any renewals) from January 1, 2018 through April 30, 2020.

G. “CreditMonitor Substitute Product” means a CreditBuilder Line Product to which Respondent migrated Businesses that had purchased CreditMonitor, during a period when Respondent temporarily stopped offering CreditMonitor, and any subsequent CreditBuilder Line Product to which Respondent migrated any such Business.

H. “CreditBuilder Line Product” means CreditBuilder, CreditBuilder Basic, CreditBuilder Plus, CreditBuilder Premium, Credit Essentials, and Credit Essentials Plus, as well as any predecessor to, successor to, or variant of any of these products; and includes CreditBuilder 2018 as defined above. I. “Current Customer” includes Businesses that are customers of Respondent as of the date of the entry of this Order, and does not include a Business that first purchased a product after the date of the entry of this Order. When specifically stated in this Order, Current Customer may be further limited to exclude a Business that first purchased a product on or after May 1, 2020. J. “Negative Option Feature” means, in an offer or agreement to sell or provide any product or service, a provision under which the consumer’s silence or failure to take affirmative action to reject a product or service or to cancel the agreement is interpreted by the seller or provider as acceptance of the offer. K. “Pro Rata Result” means the dollar figure resulting from applying discount adjustments and term adjustments to the figure of $399 for Refund Customers who are Current Customers, and to the figure of $480 for Refund Customers who are former customers. For a Relevant Subscription Term during which a customer paid a discounted price, the discount adjustment shall be a multiplier equal to the price paid divided by the list price (e.g., if a customer paid $800 for a product listed at $1,000, the discount adjustment multiplier is .8). For a Relevant Subscription Term that is less than a one-year term, the term adjustment shall be a multiplier equal to the length of the Relevant Subscription Term divided by one year (e.g., if the Relevant Subscription Term is three months, the term adjustment multiplier is .25). The effects of the adjustment multipliers shall be cumulative (multiplied by each other) if a customer paid a discounted price for a Relevant Subscription Term of less than one year.

VOLUME 173 Decision and Order L. “Relevant Subscription Term” means the Business’s current or most recent CreditBuilder Line Product subscription term.

M. “Respondent” means Dun & Bradstreet, Inc., a corporation, doing business as D&B (“D&B”), and its successors and assigns.

N. “Trade Reference” means a source, including a vendor, supplier, or other entity, that supplies Respondent (or that a Business represents could supply Respondent) with commercial payment information about a Business. O. “Trade Reference Acceptance Percentage” means the aggregate calculation of the number of all Businesses’ submissions of payment experiences from Trade References that have been added to Businesses’ own credit reports or credit files through the operation of any CreditBuilder Line Product, divided by the number of all Businesses’ attempted submissions of payment experiences from Trade References to be added to Businesses’ own credit reports through any CreditBuilder Line Product, expressed as a percentage. The divisor of this calculation shall not be reduced for multiple attempted submissions by a Business of a single Trade Reference or a single payment experience, nor shall the divisor be reduced for any attempted submissions that Respondent has automatically rejected for any reason. Provisions I. Prohibited Misrepresentations IT IS ORDERED that Respondent, and Respondent’s officers, agents, employees, and attorneys, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, in connection with the advertising, promotion, offering for sale, or sale of, or the Charging for, any product, must not misrepresent, expressly or by implication:

A. that using any product is likely to allow a Business to have its previously unreported commercial payment experiences added to the Business’s credit report; B. that Respondent will actively assist a Business in adding unreported commercial payment experiences to the Business’s credit report; C. that using any product is likely to help build and/or improve a Business’s credit report;

D. the ease with which information or payment experiences can be added to or will be included on a Business’s credit report;

E. that Respondent will accept identified vendors, suppliers, or other entities as Trade References (whether identified by the Business or by Respondent’s agents or DUN & BRADSTREET, INC. 653 Decision and Order employees), including specifically identified entities, entities comparable to specifically identified entities, or specific types or categories of entities; F. that any product is needed for Respondent to initiate or conduct a background check on a Business, or to otherwise activate or establish the Business’s credit report or credit file;

G. that any product will provide a Business with a complete credit report or credit file including a full set of scores and ratings;

H. that any product with a Negative Option Feature will be Charged at that product’s list price at the time of renewal;

I. an obligation on the part of a Business to affirmatively act in order to avoid Charges, including where a Charge will be assessed pursuant to the offer unless the consumer takes affirmative steps to prevent or stop such a Charge; J. that Respondent is collecting payment for or is renewing the same product that the Business purchased the prior term; or K. any other material fact about the price or features of any product, or concerning a Business’s ability to have, monitor, maintain, build, or improve its own credit report or credit file.

II. Prohibitions Regarding Negative Option Feature IT IS FURTHER ORDERED that Respondent, and Respondent’s officers, agents, employees, and attorneys, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, are prohibited from using a Negative Option Feature:

A. To renew an existing agreement with or Charge a Current Customer for (1) a CreditBuilder 2018 product or (2) a CreditMonitor Substitute Product, unless Respondent receives the express consent of the customer to renew the product, and has complied with the Notification required by Section VII below. B. To renew an agreement with or Charge a Business for any Covered Product when Respondent has increased the list price of the product, unless Respondent first provides the Business with notice of such increase before the agreement is scheduled to renew, and gives the Business at least 30 days after such notice to cancel and avoid being Charged for the product.

1. Notice shall be provided by email. If Respondent does not have a working email for the Business, or if the emailed notice is returned as undeliverable, notice shall be provided by United States Postal Service, first class mail, postage pre-paid. If Respondent sends notice by United States Postal VOLUME 173 Decision and Order Service, Respondent must give the Business at least 30 days from the date of mailing to cancel and avoid being Charged for the product. If Respondent does not have a mailing address for the Business, or if a notice sent by United States Postal Service is returned as undeliverable, Respondent must receive the express consent of the Business before renewing the product at the increased price.

2. The notice shall include the product’s list price for the current term, the product’s new list price, instructions on the procedure to cancel if the Business does not want to renew (as set forth in this Part B.3 below), and the deadline by which the Business must affirmatively act to avoid being Charged. The subject line of the email, and the front of the envelope for notice by United States Postal Service, shall read, without any additional language, “Price Increase Affecting Your Dun & Bradstreet [X] Product.” Respondent shall insert the name of the specific Covered Product at issue where indicated by [X]. Provided, however, that if Respondent has increased the list price of the product but Respondent is providing the Business with a discount so that the Business will not pay any of the price increase, the notice shall also include the price that Respondent will Charge the Business, and the subject line of the email and the front of the envelope for notice by United States Postal Service shall read, without any additional language, “Price Information About Your Dun & Bradstreet [X] Product.” 3. Respondent shall provide a simple mechanism that the Business can easily use to cancel the product and avoid being Charged, including a telephone number and web form. Respondent must assure that all calls to this telephone number are answered during normal business hours. Respondent shall provide the telephone number and a link to the web form in the notice, and shall post it to an easily accessible location on the Internet. C. To renew an agreement with or Charge a Business for any Covered Product a Business purchased when Respondent has materially changed the product’s feature or features in a manner that limits, reduces, or eliminates such feature or features. D. To substitute a different product for the Covered Product a Business purchased, provided that, this Part D does not apply and Parts B and C of this Section apply instead if:

1. Respondent renames or rebrands the Covered Product that the Business purchased, or 2. Respondent eliminates and ceases to offer the Covered Product a Business purchased (the “Eliminated Product”), under the following conditions: a. The list price of the substitute product is no higher than the list price of the Eliminated Product. For purposes of the calculation required DUN & BRADSTREET, INC. 655 Decision and Order by this condition, Respondent may not consider any introductory or discounted pricing of the substitute product.

b. The substitute product has every material feature of the Eliminated Product, and none of those features are limited or reduced in comparison to the Eliminated Product. Respondent may not use a combination of substitute products to meet this condition. c. Respondent (i) provides the Business with prompt notice of such product substitution, and (ii) gives the Business at least 30 days after such notice to cancel and avoid being Charged for the substitute product. The notice shall be provided in the same manner as set forth in Part B.1. of this Section. If Respondent is required to send notice by United States Postal Service and does not have a mailing address for the Business, or if a notice sent by United States Postal Service is returned as undeliverable, Respondent must receive the express consent of the Business before Charging the Business for a substitute product.

d. The required notice shall identify the Eliminated Product and its list price; shall identify the substitute product, its list price and its features; and shall disclose that the Eliminated Product is no longer being offered. The notice shall also provide instructions on the procedure to cancel if the Business does not want to renew (as set forth in Part B.3 above), and the deadline by which the Business must affirmatively act to avoid being Charged. The subject line of the email, and the front of the envelope for notice by United States Postal Service, shall read, without any additional language, “Notice of Substitution of your [name of Eliminated Product] to a Different Product.”

e. If, at any time, Respondent reintroduces the Eliminated Product, Respondent shall revert the Business’s subscription back to a subscription to the Eliminated Product. For the first subscription term upon such reversion, Respondent shall charge the Business no more than the lowest of (i) the amount the Business paid for its most recent term of subscription to the Eliminated Product, or (ii) the amount the Business paid for its most recent term of subscription to any Covered Product, or (iii) the list price of the reintroduced Eliminated Product. In the event of such reversion, Respondent shall provide notice to the Business of the reversion in a manner consistent with the terms of Parts D.2.c and d, above. E. For all oral offers for Covered Products, without obtaining express oral confirmation, before obtaining a Business’s Billing Information, that the Business VOLUME 173 Decision and Order understands that the transaction includes a Negative Option Feature, and understands the specific affirmative steps the Business must take to prevent or stop further Charges. For such transactions, Respondent shall maintain for three (3) years from the date of each transaction an unedited voice recording of the entire transaction.

III. Required Disclosure: Aggregated Trade Reference Acceptance Percentage IT IS FURTHER ORDERED that Respondent, and Respondent’s officers, agents, and employees, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, in connection with the advertising, promotion, offering for sale, or sale of, or the Charging for, any CreditBuilder Line Product or bundled product that includes a CreditBuilder Line Product, must disclose, Clearly and Conspicuously, before obtaining the Business’s Billing Information, the aggregated Trade Reference Acceptance Percentage for the preceding calendar year. Upon the start of a new calendar year, Respondent may continue to disclose the most recently available calendar year’s percentage until Respondent has calculated the updated percentage for the preceding calendar year, provided that Respondent must begin disclosing the percentage for the preceding calendar year no later than April 1.

IV. Required Disclosure: Respondent Does Not Identify Ineligible Trade References And Reasons For Rejection IT IS FURTHER ORDERED that Respondent, and Respondent’s officers, agents, and employees, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, in connection with the advertising, promotion, offering for sale, or sale of, or the Charging for, any CreditBuilder Line Product or bundled product that includes a CreditBuilder Line Product, must disclose, Clearly and Conspicuously, before obtaining the Business’s Billing Information: A. that although Respondent maintains lists of named entities that are ineligible to be added as Trade References through CreditBuilder Line Product submissions, Respondent will not disclose in advance of any Trade Reference payment experience submission whether such Trade Reference is ineligible; and B. that if Respondent rejects a Trade Reference payment experience submission, Respondent will not identify to the Business the specific reason for rejection of that submission.

Provided that, if Respondent changes its practices described in either Part A or Part B of this Section (or both of them), this Section shall require accurate disclosure of the resulting practice or practices.

DUN & BRADSTREET, INC. 657 Decision and Order V. Unfairness Relief: Dispute Investigation and Resolution IT IS FURTHER ORDERED that Respondent, and Respondent’s officers, agents, employees, and attorneys, and all other persons in active concert or participation with any of them, who receive actual notice of this Order, whether acting directly or indirectly, shall, free of charge, provide Businesses with access to information gathered, collected or maintained by Respondent, other than Respondent’s proprietary or derived scores, ratings, calculations, summaries, predictions and analyses, that Respondent reports about them, and shall, free of charge, provide such Businesses with reasonable means to dispute the accuracy of such information. A. If a Business notifies Respondent directly (by notifying a customer service representative or using an online process provided by Respondent) that it disputes the accuracy of information that Respondent reports about the Business, Respondent shall, free of charge, either delete the information from files gathered, collected, or maintained by Respondent, or conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate. A reasonable reinvestigation must be responsive to the specific allegations, if any, in the Business’s dispute.

B. In conducting a reinvestigation, Respondent shall review and consider all relevant information, including, as applicable, information in Respondent’s own files, publicly available information, information Respondent receives from vendors, suppliers or other entities, and information submitted by the disputing Business with respect to such disputed information. Respondent shall have no obligation to resolve disputes among other businesses as to billing or payments. C. If a Business notifies Respondent directly (by notifying a customer service representative or using an online process provided by Respondent) that it disputes any information that Respondent reports about the Business’s basic identifying information, such as its name, address, or operating status (in business or out of business), Respondent shall complete its investigation within seven (7) business days from the date on which Respondent receives notice of the dispute from the Business. This seven-business-day period may be extended for not more than seven (7) additional business days if Respondent is unable to complete its investigation within seven business days despite reasonable efforts. For disputes about a Business’s DUNS number (for instance, incorrect number reported or multiple DUNS assigned to the same Business), the time frames in this Part C shall be extended by seven (7) business days.

D. If a Business notifies Respondent directly (by notifying a customer service representative or using an online process provided by Respondent) that it disputes any information that Respondent reports based on publicly available information, such as judgments and liens, or on payment experience information: 1. For any disputed publicly available information, if requested by the Business, Respondent shall promptly identify to the disputing Business the VOLUME 173 Decision and Order open source of the information, to the extent reasonably available, if not already provided to the Business;

2. For any disputed payment experience information that Respondent does not remove from the Business’s record, if requested by the Business, Respondent shall, to the extent permitted by the source that reported the payment experience information, promptly provide the disputing Business with the name of such source and the date of the payment experience at issue; provided, however, that Respondent may include reasonable limits on the number of items that can be disputed at one time; 3. Respondent shall complete its investigation within fourteen (14) business days from the date on which Respondent receives notice of the dispute from the Business. This fourteen-business-day period may be extended for not more than fourteen (14) additional business days if Respondent is unable to complete its investigation within fourteen (14) business days despite reasonable efforts; and 4. If Respondent provides the disputing Business with additional details regarding the disputed information pursuant to this Part D, and asks the Business to confirm that it continues to dispute the information in light of the additional details, then (i) Respondent may defer any additional reinvestigation until the Business informs Respondent that it continues to dispute the information, and (ii) the time between when the additional details are provided to the Business and when the Business informs Respondent that it continues to dispute the information shall not be counted in determining the time periods and deadlines set forth in this Part D. E. If, after any reinvestigation required by Part C or D of this Section, an item of information is found to be inaccurate, or additionally as to payment experience information, cannot be verified, Respondent shall promptly adjust its records to correct, modify, or delete that item of information to the extent that Respondent has gathered, collected, or maintained that item of information. Respondent shall maintain systems such that: (i) to the extent Respondent’s products provide credit reports, scores, or ratings that contain information that updates on a daily basis, the product is designed to display the result of the correction, modification, or deletion of such information within four (4) business days after the investigation is completed; and (ii) to the extent Respondent’s products provide credit reports, scores, or ratings that contain information that updates on a periodic basis, the product is designed to display the result of the correction, modification, or deletion of such information no later than Respondent’s next periodic issuance of the information or an update to the information.

F. Following any deletion of payment experience information which is found to be inaccurate or the accuracy of which cannot be verified, Respondent shall furnish notification that the item has been deleted to any entity identified by the affected DUN & BRADSTREET, INC. 659 Decision and Order Business, if (1) the identified entity obtained information from Respondent about the affected Business within a period beginning 60 days prior to notice of the dispute that resulted in deletion, and (2) the information obtained by the identified entity included or relied on the deleted information. G. Respondent shall maintain reasonable procedures designed to prevent the reoccurrence in a Business’s credit file and credit reports of errors corrected pursuant to this Section.

H. If Respondent removes any payment experience information from a Business’s credit report pursuant to Part E of this Section, Respondent shall maintain reasonable procedures to prevent the reappearance of such information in the Business’s file unless the source of the information confirms that the information is complete and accurate.

I. Respondent shall provide notice to a disputing Business of the results of a reinvestigation under this Section not later than five (5) business days after the completion of the reinvestigation. Such notice shall include a statement that the reinvestigation is completed and provide the Business with free access to the information as revised as a result of the reinvestigation, other than Respondent’s proprietary or derived scores, ratings, calculations, summaries, predictions and analyses, that Respondent reports about them.

J. Notwithstanding anything to the contrary in this Section V, Respondent’s responsibilities set forth in this Section V apply only to Respondent’s own records and reports pertaining to a Business. Respondent has no obligation under this Section V to take any action to investigate, correct, modify, or delete information that is collected or maintained about a Business by Respondent’s affiliates or partners, provided, however, that if a Business notifies Respondent directly (by notifying a customer service representative or using an online process provided by Respondent) that it disputes the accuracy of any such information, Respondent shall either (i) request that the affiliate or partner investigate the dispute or (ii) provide the Business with information sufficient for the Business to contact the affiliate or partner directly to dispute the accuracy of the information. VI. Refunds to Customers IT IS FURTHER ORDERED that Respondent shall issue refunds as follows: A. Within sixty (60) days after entry of this Order, Respondent shall provide refunds or attempt to provide refunds to all Refund Customers, as defined in this Section, who are not Current Customers, in the manner set forth in this Section. For Current Customers who receive notice pursuant to Parts A and B of Section VII, below, Respondent shall provide refunds or attempt to provide refunds within forty-five (45) days of receiving the Current Customer’s notice of cancellation. VOLUME 173 Decision and Order B. Potential Refund Customers include all Current Customers and former customers of CreditBuilder Line Products who:

1. paid for at least one subscription to a CreditBuilder Line Product on or after April 27, 2015;

2. were CreditBuilder Line Product customers before May 1, 2020; 3. have not already received a full refund for the customer’s Relevant Subscription Term; and, 4. submitted one or more Trade Reference payment experience requests in the Relevant Subscription Term and, a. for Businesses that submitted one or two Trade Reference payment experience requests in the Relevant Subscription Term, did not have all of the experiences accepted, verified, and added to their credit report, or b. for Businesses that submitted three or more Trade References in the Relevant Subscription Term, had fewer than three separate requested Trade Reference payment experiences accepted, verified, and added to their credit report.

c. The calculation of the number of separate Trade Reference payment experiences accepted, verified, and added shall exclude any Trade Reference that already had an agreement with Respondent to automatically report commercial payment information to Respondent on a regular basis about Businesses, regardless of whether Respondent added payment experiences between that Trade Reference and the customer to the customer’s credit report. Provided, however, that if the requirements of VI.B.1-3 are met, the following shall also be Potential Refund Customers if they submitted no Trade Reference payment experience requests in the Relevant Subscription term: (a) CreditBuilder 2018 customers, and (b) Businesses that purchased or were Charged for a CreditMonitor Substitute Product.

C. Potential Refund Customers, and their current contact information, must be identified to the extent such information is in Respondent’s possession, custody or control, including from third parties. Potential Refund Customers include those identified at any time, including after Respondent’s execution of the Agreement through the eligibility period, which runs for one (1) year after the issuance date of the Order.

DUN & BRADSTREET, INC. 661 Decision and Order D. Refund Customers are (i) all Potential Refund Customers who are not Current Customers and (ii) Potential Refund Customers who are Current Customers and who timely cancel their current CreditBuilder Line Product subscription pursuant to Section VII of this Order.

E. For Refund Customers who are not Current Customers and who are first identified after Respondent first emails or mails Notices pursuant to Section VII, Respondent shall issue a refund or attempt to issue a refund within forty-five (45) days of their identification.

F. For Refund Customers who are Current Customers, Respondent shall issue the amount of compensation calculated pursuant to Part G of this Section through a refund applied to the credit card or other method of payment Respondent has on file for the Refund Customer. Respondent shall provide such Current Customers, other than those who paid for a CreditBuilder 2018 product in the Relevant Subscription Term, with access to all functions of Respondent’s CreditMonitor product through the end of the Current Customer’s Relevant Subscription Term. G. For Refund Customers who are not Current Customers or for whom Respondent does not have a valid credit card or other method of payment on file, Respondent shall issue the amount of compensation calculated pursuant to Part H of this Section by sending a check by United States Postal Service, in accordance with the following instructions:

1. For Refund Customers who are not Current Customers, Respondent shall include a letter in the form shown in Attachment D. 2. The envelope containing the letter must be in the form shown in Attachment E.

3. The face of each check must Clearly and Conspicuously state: “Please cash or deposit this check within 180 days or it may no longer be good.” Respondent may void any checks that have not been negotiated after 187 days from the date the checks were originally mailed, subject to Part G.5. of this Section.

4. The mailing must not include any other enclosures or marketing information, and shall not in any manner offer any products. 5. The mailing must be sent by first-class mail, postage prepaid, address correction service requested with forwarding and return postage guaranteed. For any mailings returned as undeliverable, Respondent must use standard address search methodologies such as re-checking Respondent’s own data and records and the Postal Service’s National Change of Address database and re-mailing to the corrected address within fifteen (15) business days. VOLUME 173 Decision and Order Respondent may void any re-mailed checks that have not been negotiated after 187 days from the date the checks were re-mailed. H. The amount of compensation for each Refund Customer who paid for a CreditBuilder Line Product shall be calculated as follows: 1. For Refund Customers who paid for a CreditBuilder 2018 product in the Relevant Subscription Term, the amount of compensation is the total amount the Refund Customer paid Respondent for the Relevant Subscription Term for the CreditBuilder 2018 product. 2. For Refund Customers who are Current Customers, other than those who paid for a CreditBuilder 2018 product in the Relevant Subscription Term, the amount of compensation for each Refund Customer is the total amount the Refund Customer paid Respondent for the Relevant Subscription Term for the CreditBuilder Line Product reduced by $399, except that, as applicable, the compensation will instead be reduced by the Pro Rata Result.

3. For Refund Customers who are former customers, other than those who paid for a CreditBuilder 2018 product in the Relevant Subscription Term, the amount of compensation for each Refund Customer is the total amount the Refund Customer paid Respondent for the Relevant Subscription Term for the CreditBuilder Line Product reduced by $480, except that, as applicable, the compensation will instead be reduced by the Pro Rata Result. 4. If a Refund Customer upgraded or otherwise moved from one CreditBuilder Line Product to another CreditBuilder Line Product during the Relevant Subscription Term and had a portion of a previous payment applied to the upgraded CreditBuilder Line Product subscription, the amount of compensation shall include the amount applied to the more recent subscription.

5. If a Refund Customer already received a partial refund for its CreditBuilder Line Product in the Relevant Subscription Term, Respondent may reduce the compensation by the amount of the refund already provided. If requested by the Commission pursuant to I.2 below, Respondent must produce any refund records on which it relies to reduce compensation pursuant to this Part.

I. Respondent must report on this refund program under penalty of perjury: 1. Respondent must submit a report at the conclusion of the program: summarizing its compliance, including the total number of, and dollar amounts for, Refund Customers, refunds made, refund checks mailed, and refund checks negotiated.

DUN & BRADSTREET, INC. 663 Decision and Order 2. If a representative of the Commission requests any information regarding the program, including any of the underlying customer data, Respondent must submit it within ten (10) business days of the request. Upon request by Respondent, this ten-business-day period may be extended for a reasonable number of days by the Commission’s requesting representative, and such extension shall not be unreasonably withheld. 3. Failure to provide required refunds or any requested information will be treated as a continuing failure to obey this Order. VII. Notification to Current Customers of Covered Products that Automatically Renew IT IS FURTHER ORDERED that Respondent shall, within sixty (60) days of entry of this Order, provide adequate and timely Notice of this Order by email (if Respondent has an email address for the customer) or United States Postal Service (if Respondent does not have an email address for the customer) to each Current Customer of a Covered Product that Respondent automatically renews, who paid or agreed to pay money to Respondent or Billing Information as a means of paying Respondent.

A. For Current Customers who are Potential Refund Customers with a subscription to a CreditBuilder 2018 product, the Notice shall provide notice of this Order, information about the automatic renewal schedule or subscription end date of the product, and an opportunity to cancel their CreditBuilder 2018 subscription and receive a refund. The Notice shall be in the exact wording and format set forth in Attachment A. The subject line of the email and letter must read “Option to cancel your CreditBuilder product and potential refund from Dun & Bradstreet.” The Notice shall include or enclose (if by mail) only the information described in Part D of this Section, and shall not include any other message, attachment, or enclosure.

B. For all other Current Customers who are Potential Refund Customers, the Notice shall provide notice of this Order, information about the automatic renewal schedule or subscription end date of their product, and an opportunity to cancel their subscription and receive a partial refund. The Notice shall be in the exact wording and format set forth in Attachment B. The subject line of the email and letter must read “Option to cancel your CreditBuilder or Credit Essentials product and potential partial refund from Dun & Bradstreet.” The Notice shall include or enclose (if by mail) only the information described in Part D of this Section, and shall not include any other message, attachment, or enclosure. C. For all other Current Customers that have a paid subscription to any Covered Product that automatically renews or would automatically renew absent the application of Section II.A of this Order, the Notice shall provide notice of this Order and information about the automatic renewal schedule or subscription end date of their Covered Product or Products. The Notice shall be in the exact wording and format set forth in Attachment C. The subject line of the email and letter must VOLUME 173 Decision and Order read “Notice of lawsuit and information about your Dun & Bradstreet product or products.” The Notice shall include or enclose (if by mail) only the information described in Part D of this Section, and shall not include any other message, attachment, or enclosure.

D. The Notice shall include or enclose (if by mail) the following: 1. a list of all paid subscriptions to Covered Products, 2. a list of all paid subscriptions to any of Respondent’s other products that the customer has purchased from the same business unit responsible for Covered Products, 3. a brief description (in compliance with Section I of this Order) of each such product, 4. the price the customer paid for each product in its current term, 5. the current list price and, if different, renewal price, of each such product, 6. the date each product is scheduled to automatically renew and, for products covered by Section II. A of this Order, the end date of the product subscription term and a disclosure that such product will not automatically renew, and 7. a telephone number that the customer can call to obtain a complete list of Respondent’s paid products to which the customer subscribes. E. Respondent must use reasonable means to attempt to determine whether each Notice sent by email pursuant to this Section was opened by the recipient. If Respondent has no indication that the recipient opened the email within twenty (20) business days after the date Respondent sent it, Respondent shall, within ten (10) additional business days, send the Notice (with enclosure) by United States Postal Service. Any deadline for the recipient to respond to the Notice shall run only from the last date that Respondent sent a Notice to the recipient. F. Notices sent by United States Postal Service pursuant to this Section shall be sent first-class mail, postage prepaid, address correction service requested with forwarding and return postage guaranteed. For Notices in the form of Attachment A or Attachment B, the front of the envelope shall read “Option to cancel your CreditBuilder or Credit Essentials product and potential refund from Dun & Bradstreet.” For Notices in the form of Attachment C, the front of the envelope shall read “Notice of lawsuit and information about your Dun & Bradstreet product or products.” For any mailings returned as undeliverable, Respondent must use standard address search methodologies such as re-checking Respondent’s DUN & BRADSTREET, INC. 665 Decision and Order own data and records and the Postal Service’s National Change of Address database and re-mail to the corrected address within fifteen (15) business days. G. Notwithstanding any other provision of this Order, Respondent shall, within thirty (30) days of a written request, provide the Commission with all records reasonably requested about each customer to whom a Notice is sent pursuant to this Section. In accordance with Section X below, Respondent shall implement systems and procedures designed to maintain all of the following records about each such customer, and in accordance with this Part G, the FTC may request any or all of them for any such customer: name; all known addresses, telephone numbers, and email addresses; whether Respondent has any indication that the customer opened the Notice email (and, if so, the form of such indication); the date or dates that Respondent sent a Notice; whether the customer canceled the CreditBuilder Line Product subscription; and copies of all communications with the customer that are made through the channels identified in the Notice and that relate to the Notice, including webform submissions, recordings of telephone calls, and recordings of voicemail messages.

VIII. Acknowledgments of the Order IT IS FURTHER ORDERED that Respondent obtain acknowledgments of receipt of this Order:

A. Respondent, within 10 days after the effective date of this Order, must submit to the Commission an acknowledgment of receipt of this Order sworn under penalty of perjury.

B. For 3 years after the issuance date of this Order, Respondent must deliver a copy of this Order to: (1) all principals, officers, directors, and LLC managers and members; (2) all employees having managerial responsibilities for any Covered Product subject to a Negative Option Feature, and all agents and representatives who participate in the sale of any Covered Product; and (3) any business entity resulting from any change in structure as set forth in the Provision titled Compliance Reports and Notices. Delivery must occur within 10 days after the effective date of this Order for current personnel. For all others, delivery must occur within 10 days of when they assume their responsibilities. C. From each individual or entity to which Respondent delivered a copy of this Order, Respondent must obtain, within 30 days, a signed and dated acknowledgment of receipt of this Order.

IX. Compliance Reports and Notices IT IS FURTHER ORDERED that Respondent make timely submissions to the Commission:

VOLUME 173 Decision and Order A. One year after the issuance date of this Order, Respondent must submit a compliance report, sworn under penalty of perjury, in which Respondent must: (1) identify the primary physical, postal, and email address and telephone number, as designated points of contact, which representatives of the Commission may use to communicate with Respondent; (2) identify all of Respondent’s businesses by all of their names, telephone numbers, and physical, postal, email, and Internet addresses; (3) describe the activities of each business, including the goods and services offered and the means of advertising, marketing, and sales; (4) describe in detail whether and how Respondent is in compliance with each Provision of this Order, including a discussion of all of the changes Respondent made to comply with the Order; and (5) provide a copy of each Acknowledgment of the Order obtained pursuant to this Order, unless previously submitted to the Commission. B. For 10 years after the issuance date of this Order, Respondent must submit a compliance notice, sworn under penalty of perjury, within 14 days of any change in: (1) any designated point of contact; or (2) the structure of Respondent or any entity that Respondent has any ownership interest in or controls directly or indirectly that may affect compliance obligations arising under this Order, including: creation, merger, sale, or dissolution of the entity or any subsidiary, parent, or affiliate that engages in any acts or practices subject to this Order. C. Respondent must submit notice of the filing of any bankruptcy petition, insolvency proceeding, or similar proceeding by or against Respondent within 14 days of its filing.

D. Any submission to the Commission required by this Order to be sworn under penalty of perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by concluding: “I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on: “_____” and supplying the date, signatory’s full name, title (if applicable), and signature.

E. Unless otherwise directed by a Commission representative in writing, all submissions to the Commission pursuant to this Order must be emailed to [email protected] or sent by overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580. The subject line must begin: In re Dun & Bradstreet, Inc., [plus the docket number]. X. Recordkeeping IT IS FURTHER ORDERED that Respondent must create certain records for 10 years after the issuance date of the Order, and retain each such record for 5 years, unless otherwise specified below. Specifically, Respondent must create and retain the following records: DUN & BRADSTREET, INC. 667 Decision and Order A. accounting records showing the revenues from the sale of all Covered Products sold, and, to the extent such records are created and maintained in the ordinary course of business, the costs incurred in generating those revenues, and resulting net profit or loss;

B. personnel records showing, for each person providing services in relation to any aspect of the Order, whether as an employee or otherwise, that person’s: name; addresses; telephone numbers; job title or position; dates of service; and (if applicable) the reason for termination;

C. copies or records of all consumer complaints and refund requests for Covered Products made to customer service, whether received directly or indirectly, such as through a third party, and any response;

D. all records necessary to demonstrate full compliance with each Provision of this Order, including all submissions to the Commission; and E. a copy of each unique advertisement or other marketing material for Covered Products making a representation subject to this Order. XI. Compliance Monitoring IT IS FURTHER ORDERED that, for the purpose of monitoring Respondent’s compliance with this Order:

A. Within 10 days of receipt of a written request from a representative of the Commission, Respondent must: submit additional compliance reports or other requested information, which must be sworn under penalty of perjury, and produce records for inspection and copying.

B. For matters concerning this Order, representatives of the Commission are authorized to communicate directly with Respondent. Respondent must permit representatives of the Commission to interview anyone affiliated with Respondent who has agreed to such an interview. The interviewee may have counsel present. C. The Commission may use all other lawful means, including posing through its representatives as consumers, suppliers, or other individuals or entities, to Respondent or any individual or entity affiliated with Respondent, without the necessity of identification or prior notice. Nothing in this Order limits the Commission’s lawful use of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 57b-1.

XII. Order Effective Dates IT IS FURTHER ORDERED that this Order is final and effective upon the date of its publication on the Commission’s website (ftc.gov) as a final order. This Order will terminate 20 VOLUME 173 Decision and Order years from the date of its issuance (which date may be stated at the end of this Order, near the Commission’s seal), or 20 years from the most recent date that the United States or the Commission files a complaint (with or without an accompanying settlement) in federal court alleging any violation of this Order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of: A. Any Provision in this Order that terminates in less than 20 years; B. This Order’s application to any Respondent that is not named as a defendant in such complaint; and C. This Order if such complaint is filed after the Order has terminated pursuant to this Provision.

Provided, further, that if such complaint is dismissed or a federal court rules that the Respondent did not violate any Provision of the Order, and the dismissal or ruling is either not appealed or upheld on appeal, then the Order will terminate according to this Provision as though the complaint had never been filed, except that the Order will not terminate between the date such complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date such dismissal or ruling is upheld on appeal.

By the Commission.

ATTACHMENT A [D&B letterhead] Customer No: XXX-XX-XXX Date Re: Option to cancel your CreditBuilder product and potential refund from Dun & Bradstreet Dear CreditBuilder Customer:

Our records show that you subscribed to our CreditBuilder product. We’re writing to tell you that you can choose to cancel your CreditBuilder subscription and get a refund. DUN & BRADSTREET, INC. 669 Decision and Order The Federal Trade Commission (FTC), the nation’s consumer protection agency, recently filed a lawsuit against us. The FTC said we made misleading claims in our marketing of CreditBuilder and other products, including about your ability to add payment experiences to your credit report. We did not admit to these things, but to settle the lawsuit with the FTC, we’re giving you the option to cancel your subscription and get a refund. Our records show the following CreditBuilder subscription is eligible for cancellation: • [Description of the CreditBuilder subscription] • You paid $xx.xx for the current subscription term • The current list price is $xx.xx • Your subscription ends on (Month, Day, Year) If you want to cancel your subscription and get a refund, you must let us know within 30 days of the date on this letter by • calling us at [toll free number], • completing the online form at [web form URL], or • returning the included Notice of Cancellation and Request for Refund form (Enclosure A) to us by mail at the address on the form.

If you cancel your subscription • You’ll get a refund of what you paid for your current subscription term. • Within 45 days of the date we get your request to cancel, we’ll issue a credit to the method of payment currently on file. (If the payment method we have on file is no longer valid, we will send you a check by mail.) • You’ll lose access to your CreditBuilder subscription. • Cancelling your subscription will not affect your DUNS® number or your business’s information, scores, or ratings.

If you want to keep your subscription, you don’t have to do anything. If you keep your CreditBuilder subscription, we won’t automatically renew it and charge you. But, we may contact you to ask if you want to renew it.

[Include the next section only if there WILL NOT be an enclosed list of paid subscriptions in addition to CreditBuilder 2018] You may have other subscriptions with us. To get a list of products to which you subscribe, call us at [(XXX) XXX-XXXX].

[end of section] VOLUME 173 Decision and Order [Include the next section only if there WILL be an enclosed list of paid subscriptions in addition to CreditBuilder 2018] We’ve enclosed a list of other paid subscriptions you have, how much you paid for each, when it expires, if we’ll automatically renew it, and when we’ll charge you. You may have other subscriptions not included in the list. To get a complete list of your subscriptions, call us at [(XXX) XXX-XXXX].

[end of section] You can learn more about the FTC’s lawsuit against Dun & Bradstreet at www.ftc.gov/[url]. Enclosure A to Attachment A Notice of Cancellation and Request for Refund TO: [Address of Company] Re: Cancellation Request for Customer No. XXX-XX-XXX I am writing to request cancellation of my CreditBuilder subscription. Please refund my payment by issuing a credit to the method of payment currently on file. DUN & BRADSTREET, INC. 671 Decision and Order Enclosure B to Attachment A Your Current Subscriptions to Other Paid Products Not Eligible for Refund* Subscription Amount You Paid Current List Your Renewal Date of for this Term Price Price Renewal or End of Term Product 1 $xx.xx $xx.xx $xx.xx [description] Product 2 $xx.xx $xx.xx $xx.xx [description] If you see a price in the Your Renewal Price column, that means we will automatically renew that subscription on the date listed and we will charge you at the specified renewal price. You may contact us at [(XXX) XXX-XXXX] at any point before the date the product is scheduled to renew to request that we not renew your subscription at the end of the current term. * You may have other subscriptions not included in this list. To get a list of products to which you subscribe, call us at [(XXX) XXX-XXXX].

VOLUME 173 Decision and Order ATTACHMENT B [D&B letterhead] Customer No: XXX-XX-XXX Date Re: Option to cancel your CreditBuilder or Credit Essentials product and potential partial refund from Dun & Bradstreet Dear CreditBuilder or Credit Essentials Customer: Our records show that you subscribed to our CreditBuilder or Credit Essentials products. We’re writing to tell you that you can choose to cancel your CreditBuilder or Credit Essentials subscription and get a partial refund.

The Federal Trade Commission (FTC), the nation’s consumer protection agency, recently filed a lawsuit against us. The FTC said we made misleading claims in our marketing of these products, including about your ability to add payment experiences to your credit report. We did not admit to these things, but to settle the lawsuit with the FTC, we’re giving you the option to cancel your subscription and get a partial refund. Our records show the following CreditBuilder or Credit Essentials subscription is eligible for cancellation: • [Description of the subscription] • You paid $xx.xx for the current subscription term • The current list price is $xx.xx • Your subscription renews on (Month, Day, Year) at a renewal price of $xx.xx. [For CreditMonitor Substitute Product customers, replace this bullet with: Your subscription ends on (Month, Day, Year)] If you want to cancel your subscription and get a refund, you must let us know within 30 days of the date on this letter by • calling us at [toll free number], • completing the following form at [web form URL], or • returning the included Notice of Cancellation and Request for Refund form (Enclosure A) to us by mail at the address on the form.

If you cancel your subscription • You’ll get a partial refund of what you paid for your current subscription term. DUN & BRADSTREET, INC. 673 Decision and Order • Within 45 days of the date we get your request to cancel, we’ll issue a credit to the method of payment currently on file. (If the payment method we have on file is no longer valid, we will send you a check by mail.) • You’ll keep your access to certain product features on our website for the remainder of your current term, including unlimited access to view your Dun & Bradstreet credit report. Learn more at [CreditMonitor product description URL]. • Cancelling your subscription will not affect your DUNS® number or your business’s information, scores, or ratings.

If you want to keep your subscription, you don’t have to do anything. [Include the next sentence only for Credit Monitor Substitute Product customers: If you keep your subscription, we won’t automatically renew it and charge you. But, we may contact you to ask if you want to renew it.] [Include the next section only if there WILL NOT be an enclosed list of paid subscriptions in addition to those listed above] You may have other subscriptions with us. To get a list of products to which you subscribe, call us at [(XXX XXX-XXXX].

[end of section] [Include the next section only if there WILL be an enclosed list of paid subscriptions in addition to those listed above] We’ve enclosed a list of other paid subscriptions you have, how much you paid for each, when it expires, if we’ll automatically renew it, and when we’ll charge you. You may have other subscriptions not included in the list. To get a complete list of your subscriptions, call us at [(XXX) XXX-XXXX].

[end of section] You can learn more about the FTC’s lawsuit against Dun & Bradstreet at www.ftc.gov/[url]. VOLUME 173 Decision and Order Enclosure A to Attachment B Notice of Cancellation and Request for Partial Refund TO: [Address of Company] Re: Cancellation Request for Customer No. XXX-XX-XXX I am writing to request cancellation of my (check the appropriate box) ☐ CreditBuilder subscription ☐ Credit Essentials subscription Please partially refund my payment by issuing a credit to the method of payment currently on file.

DUN & BRADSTREET, INC. 675 Decision and Order Enclosure B to Attachment B Your Current Subscriptions to Other Paid Products Not Eligible for Refund* Subscription Amount You Paid Current List Your Renewal Date of for this Term Price Price Renewal or End of Term Product 1 $xx.xx $xx.xx $xx.xx [description] Product 2 $xx.xx $xx.xx $xx.xx [description] If you see a price in the Your Renewal Price column, that means we will automatically renew that subscription on the date listed and we will charge you at the specified renewal price. You may contact us at [(XXX) XXX-XXXX] at any point before the date the product is scheduled to renew to request that we not renew your subscription at the end of the current term. * You may have other subscriptions not included in this list. To get a complete list of your subscriptions, call us at [(XXX) XXX-XXXX].

VOLUME 173 Decision and Order ATTACHMENT C [D&B letterhead] Customer No: XXX-XX-XXX Date Re: Notice of lawsuit and information about your Dun & Bradstreet product or products Dear Customer:

Our records show that you subscribed to our CreditBuilder, Credit Essentials, or CreditMonitor products. The Federal Trade Commission (FTC), the nation’s consumer protection agency, recently filed a lawsuit against us. The FTC said we made misleading claims in our marketing of these products, including misleading claims about the automatic renewal of our products. We did not admit to these things, but to settle the lawsuit with the FTC, we’re giving customers information about products they currently subscribe to and information about the automatic renewal schedule of those products.

We’ve enclosed a list of paid subscriptions you have, how much you paid for each, when it expires, if we’ll automatically renew it, and when we’ll charge you. You may have other subscriptions not included in the list. To get a complete list of your subscriptions, call us at [(XXX) XXX-XXXX].

You can learn more about the FTC’s lawsuit against Dun & Bradstreet at www.ftc.gov/[url]. DUN & BRADSTREET, INC. 677 Decision and Order Enclosure to Attachment C Your Current Paid Subscriptions* Subscription Amount You Paid Current List Your Renewal Date of for this Term Price Price Renewal or End of Term Product 1 $xx.xx $xx.xx $xx.xx [description] Product 2 $xx.xx $xx.xx $xx.xx [description] If you see a price in the Your Renewal Price column, that means we will automatically renew that subscription on the date listed and we will charge you at the specified renewal price. You may contact us at [(XXX) XXX-XXXX] at any point before the date the product is scheduled to renew to request that we not renew your subscription at the end of the current term. If you see “N/A” in the Your Renewal Price column, that means we won’t automatically renew that subscription when the term is scheduled to end, and we won’t charge you. We may contact you about renewing the subscription before it expires. * You may have other subscriptions not included in this list. To get a list of products to which you subscribe, call us at [(XXX) XXX-XXXX].

VOLUME 173 Decision and Order ATTACHMENT D [D&B letterhead] Customer No: XXX-XX-XXX Date Re: Refund check for CreditBuilder or Credit Essentials subscription from Dun & Bradstreet Dear Former CreditBuilder or Credit Essentials Customer: Our records show that you subscribed to our CreditBuilder or Credit Essentials products. The Federal Trade Commission (FTC), the nation’s consumer protection agency, recently filed a lawsuit against us. The FTC said our marketing of these products included misleading claims. We did not admit to these things, but to settle the lawsuit with the FTC, we’re giving you a refund. We’ve enclosed a refund check for the amount you are entitled to receive. Please cash or deposit the enclosed check within 180 days.

If you have any questions, please call [toll free number]. You can learn more about the FTC’s lawsuit against Dun & Bradstreet at www.ftc.gov/[url]. Sincerely, Dun & Bradstreet DUN & BRADSTREET, INC. 679 Analysis to Aid Public Comment ATTACHMENT E – Envelope Template The envelope referenced at Section VI.G.2 must be in the following form, with the underlined text completed as directed:

Dun & Bradstreet, Inc.

101 John F. Kennedy Parkway Short Hills, NJ 07078 FORWARDING AND RETURN POSTAGE GUARANTEED ADDRESS CORRECTION SERVICE REQUESTED [name and mailing address of consumer, including zip code] ABOUT YOUR PURCHASE OF CREDITBUILDER OR CREDIT ESSENTIALS AND REFUND ANALYSIS OF CONSENT ORDER TO AID PUBLIC COMMENT The Federal Trade Commission (“FTC” or “Commission”) has accepted, subject to final approval, an agreement containing a proposed consent order (“Proposed Order”) from Dun & Bradstreet, Inc. (“D&B”). The Proposed Order has been placed on the public record for 30 days to receive comments by interested persons. Comments received during this period will become part of the public record. After 30 days, the Commission will again review the agreement and the comments received and will decide whether it should withdraw from the agreement and take appropriate action or make final the agreement’s Proposed Order. This matter involves D&B’s sale of paid CreditBuilder and related products (“CreditBuilder products”). D&B typically marketed CreditBuilder products to small and midsized businesses (who are the consumers in this matter) as a means to improve what D&B reports about the business on its commercial credit reports. The FTC’s proposed five-count complaint challenges several of D&B’s CreditBuilder sales and renewal practices as deceptive, and also VOLUME 173 Analysis to Aid Public Comment alleges that certain conduct was unfair, all in violation of Section 5(a) of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. § 45(a).

The first four counts of the proposed complaint allege deceptive acts or practices in violation of the FTC Act.

• First, the complaint alleges that D&B’s representations that a business could use CreditBuilder products to have previously unreported commercial payment experiences added to its credit report, and that D&B would actively assist CreditBuilder customers in adding payment experiences, were deceptive because, in numerous instances, customers did not get payment experiences added, and D&B did not actively assist the customer in adding payment experiences. • Second, the complaint alleges that D&B made false claims that CreditBuilder products were required for D&B to conduct a background check on the business or to complete its D&B report, including providing the business with a full set of scores and ratings.

• Third, the complaint alleges that, in connection with collecting updated payment information for CreditBuilder products scheduled to renew, D&B sometimes misrepresented that D&B was collecting payment for and renewing the product that the business purchased the prior term, when, in fact, D&B was collecting payment information to enroll the customer in a different product from the one to which the customer previously subscribed.

• Fourth, the complaint alleges that when D&B collected customer credit card information for payment, it failed to adequately disclose practices that resulted in recurring and increasing charges, including automatic billing. In addition to the alleged deceptive marketing and renewal practices, the complaint alleges in its fifth count that D&B engaged in an unfair practice by reporting incorrect information on businesses’ credit reports while failing to provide those businesses with a reasonable means to dispute such information and have inaccurate information corrected. The proposed complaint alleges that this conduct caused or is likely to cause substantial injury to consumers that is not outweighed by countervailing benefits to consumers or competition and is not reasonably avoided by consumers themselves. Such practice constitutes an unfair act or practice in violation of Section 5 of the FTC Act.

The Proposed Order is designed to prevent D&B from engaging in similar acts or practices in the future. It includes injunctive relief to address these alleged violations. • Part I prohibits future deceptive acts and practices similar to those at issue in the complaint by prohibiting D&B from misrepresenting: o That using D&B’s product is likely to allow a business to have its previously unreported commercial payment experiences added to its credit report; DUN & BRADSTREET, INC. 681 Analysis to Aid Public Comment o That D&B will actively assist a business in adding its unreported commercial payment experiences to its credit report; o That using D&B’s product is likely to help a business build or improve its credit report;

o The ease with which information or payment experiences can be added to a business’s credit report; and o That D&B’s product is needed when it is not, and that a product will enable a prospective customer to have a “complete” file. • Part I also features ancillary relief relating to the challenged conduct by prohibiting misrepresentations relating to what payment experiences customers can add, as well as to D&B’s renewal and charging practices.

• Part II provides additional specific relief relating to D&B’s renewal and charging practices for products covered under the Proposed Order, to make sure that D&B makes clear disclosures about renewals both before a customer subscribes and during the period of the subscription.

• Parts III and IV require D&B to make certain disclosures to potential customers of CreditBuilder products, so that those potential customers can make better informed decisions about whether to purchase the products. • Part V sets out specific requirements for D&B to follow when a business disputes information that D&B reports about it. The requirements of this Part V apply generally, and are not limited only to D&B customers. • Part VI requires D&B to offer refunds (or partial refunds) to certain customers and former customers of CreditBuilder products. Refund or partial refund eligibility under the Proposed Order will depend on customers’ specific circumstances and how they used or attempted to use their CreditBuilder products. • Part VII requires D&B to send notices to all current customers of paid products covered under the Proposed Order that automatically renew. Parts VIII through XII are reporting and compliance provisions. Part VIII mandates that D&B acknowledge receipt of the Proposed Order and, for three years, distribute the Proposed Order to certain employees and agents and secure acknowledgments from recipients of the Proposed Order. Part IX requires D&B to submit compliance reports to the FTC one year after the order’s issuance and submit additional reports when certain events occur. Part X requires that, for 10 years, D&B creates certain records and retain them for at least 5 years. Part XI provides for the FTC’s continued compliance monitoring of D&B’s activity during the Proposed Order’s effective dates. Part XII is a provision “sunsetting” the Proposed Order after 20 years, with certain exceptions.

VOLUME 173 Analysis to Aid Public Comment The purpose of this analysis is to facilitate public comment on the Proposed Order. It is not intended to constitute an official interpretation of the complaint or Proposed Order, or to modify in any way the Proposed Order’s terms.

ELECTRONIC PAYMENT SYSTEMS, LLC 683 Complaint