Corporate Misconduct Accountability Project
On Point Global · FTC Enforcement Action and Civil Contempt
FTC vs Burton Katz: $102M Government Services Scam Targeting Vulnerable
Burton Katz and Brent Levison ran websites falsely promising driver’s license renewals and benefit eligibility checks, delivering worthless PDFs while collecting over $102 million from consumers who believed they were paying for real government services.
CRITICAL SEVERITY
TL;DR
Burton Katz and Brent Levison operated On Point Global, a network of deceptive websites that promised to renew driver’s licenses, register vehicles, and determine eligibility for public benefits like Section 8 housing and food stamps. Instead of providing these services, the sites delivered generic PDF documents with publicly available information while charging fees and harvesting sensitive personal data to sell to third parties. The operation generated over $102 million, targeting vulnerable populations including low-income families, seniors, and people seeking urgent government assistance. Despite Katz being under a 2014 permanent injunction for similar phone-bill scams, the scheme continued for years before the FTC secured contempt findings and $19.6 million in consumer restitution.
This case reveals how corporate fraud operations exploit the most vulnerable while regulators struggle to keep pace with digital deception.
$102M+
Total revenue from deceptive websites
$19.6M
Consumer restitution ordered by court
$85M
Net revenue from paid-guide sites alone
$17M
Revenue from selling personal data in 2019
64
Times Visa fraud thresholds were triggered in 3 years
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | On Point Global operated websites that prominently promised to renew driver’s licenses, register vehicles, and process other government services, but instead delivered only generic PDF documents containing publicly available information after charging consumers fees. | high |
| 02 | The company used paid search advertising on Google and Bing targeting terms like ‘renew Florida driver’s license online’ and ‘dmv.pa.gov’ to direct desperate consumers to official-sounding websites with names like DMV.com and floridadriverslicenses.org. | high |
| 03 | Burton Katz operated the scheme despite being under a 2014 permanent injunction that specifically barred him from making false or misleading material representations about products or services, including their cost, nature, characteristics, and performance. | critical |
| 04 | Brent Levison, as General Counsel and Senior Vice President, admitted under oath that Katz told him about the 2014 injunction and that he saw the document when it was entered, yet he actively participated in creating and operating the deceptive websites. | critical |
| 05 | The benefit-eligibility websites falsely promised to determine if consumers qualified for Section 8 housing, food stamps, Medicaid, and veterans benefits, collecting sensitive personal information including medical diagnoses, disability status, income, and debt levels. | high |
| 06 | On Point Global sold the personal data collected from benefit-eligibility seekers to third parties for $17 million in 2019 alone, exposing consumers to spam, scams, and identity theft risks. | high |
| 07 | The company deliberately used load balancing, creating multiple corporate shells and merchant accounts to distribute transactions and keep individual chargeback ratios below fraud-detection thresholds set by credit card processors. | high |
| 08 | On Point Global directed employees to write fake positive reviews posing as objective third parties to bury negative reviews from consumers who called the operation a scam. | medium |
Regulatory Failures
How the system failed consumers · 6 points
| 01 | Despite Katz being under a 2014 permanent injunction for similar phone-bill scams, the FTC did not file suit against On Point Global until 2019, allowing five years of operation that generated over $102 million in revenue. | high |
| 02 | Credit card processors terminated multiple On Point accounts due to excessive chargebacks and fraud concerns, yet the company simply opened new merchant accounts under different corporate names and continued operating. | high |
| 03 | Google and Bing repeatedly suspended On Point’s advertising for misleading content, but the company returned with new domains and ad accounts each time, demonstrating how easily advertising bans can be circumvented. | medium |
| 04 | The district court did not enter a preliminary injunction halting On Point’s operations until 2020, and final contempt sanctions were not confirmed until March 2023, nearly a decade after Katz’s first injunction. | high |
| 05 | The Supreme Court’s 2021 AMG decision limited the FTC’s ability to obtain monetary relief under Section 13(b), forcing the agency to rely on more complex civil contempt powers and creating additional barriers to consumer restitution. | medium |
| 06 | The final $19.6 million restitution was paid entirely from corporate funds, meaning Burton Katz and Brent Levison never forfeited personal assets despite being found personally liable for the fraud. | high |
Profit Over People
The revenue extraction model · 6 points
| 01 | On Point Global generated $85 million net of refunds and chargebacks from the paid-guide websites between 2017 and 2019, making them the company’s largest revenue source. | high |
| 02 | The company deliberately split charges into small amounts like $3.99 and $19.99, plus a $1 charitable donation, knowing that consumers would be less likely to dispute smaller charges even when they realized something was wrong. | high |
| 03 | On Point’s profit margins were massive because the only costs were web hosting, marketing, and minimal staff, while each worthless PDF could be sold thousands of times with essentially zero marginal cost. | medium |
| 04 | The company acknowledged in a Fraud Reduction Plan submitted to credit card processors that they still encountered confusion from customers despite disclaimers, yet continued operating the same deceptive model. | high |
| 05 | On Point Global targeted the most desperate and vulnerable consumers searching for urgent government services, calculating that those with the fewest resources would be least able to fight back or realize they had been scammed. | critical |
| 06 | The receiver later determined that On Point’s paid-guide websites could not be operated lawfully even with modifications and shut them down entirely, confirming that the business model was inherently fraudulent. | high |
Economic Fallout
Who paid the price · 6 points
| 01 | Hundreds of consumers filed complaints with government agencies explaining that they believed the websites would provide actual government services and felt deceived when they received only generic information. | high |
| 02 | On Point Global’s chargeback rates were so high that they triggered Visa’s fraud monitoring thresholds 64 times over three years, indicating massive consumer dissatisfaction and recognition of fraud. | high |
| 03 | Many consumers successfully disputed credit card charges and obtained chargebacks, but these individual victories did nothing to stop the ongoing operation or warn other potential victims. | medium |
| 04 | Consumers who provided personal data to the benefit-eligibility websites reported being bombarded with spam emails and text messages for psychic counseling, sweepstakes, and government grants after their information was sold. | medium |
| 05 | The opt-in claims process ultimately compensated claimants but many victims may never have realized they were eligible or that they had been scammed in the first place, especially for small-dollar charges. | medium |
| 06 | For low-income families already on the financial edge, unexpected charges of $20 or $30 represented real hardship, potentially forcing choices between the fraudulent charge and other necessities. | high |
Community Impact
Targeting the vulnerable · 6 points
| 01 | On Point Global specifically targeted low-income individuals, seniors, and disabled people seeking public benefits by operating websites promising Section 8 housing, food stamps, Medicaid, and veterans assistance eligibility checks. | critical |
| 02 | The benefit-eligibility websites collected extraordinarily sensitive information including specific medical diagnoses like cancer, diabetes, and chronic pain, disability status, household income, and debt levels from people desperately seeking government help. | critical |
| 03 | People searching for urgent government services like driver’s license renewals were often time-strapped workers who could not afford to take time off to visit a DMV office in person, making them especially vulnerable to promises of online convenience. | high |
| 04 | The scheme undermined public trust in legitimate government websites and online services, potentially causing victims to avoid seeking assistance through actual government channels in the future. | medium |
| 05 | Immigrant communities and non-native English speakers were particularly vulnerable to the confusing disclaimers and official-looking website designs that mimicked government portals. | medium |
| 06 | The personal data collected and sold by On Point Global exposed the most vulnerable populations to secondary exploitation by payday lenders, scam artists, and identity thieves. | high |
Corporate Accountability Failures
How they evaded consequences · 7 points
| 01 | Burton Katz and Brent Levison argued below that the victim-claims process was appropriate and urged the court to execute it without delay, but then appealed the same contempt sanctions they had endorsed after consumers were repaid. | high |
| 02 | Katz and Levison claimed they relied on advice from three top-drawer law firms, attempting to shift blame to their attorneys, but conceded that advice of counsel is not a defense to civil contempt. | medium |
| 03 | The district court found that disclaimers stating the sites were not affiliated with government agencies were buried in tiny gray text against gray backgrounds, overshadowed by bold headlines promising actual services. | high |
| 04 | On Point Global’s staff fielded thousands of customer calls and emails daily, predominantly from unsatisfied consumers seeking refunds, yet management continued the same business model. | high |
| 05 | Brent Levison, as General Counsel responsible for compliance and regulatory matters, directed employees to engage in load balancing to deflate chargeback rates rather than fix the underlying deception. | high |
| 06 | The court rejected the defendants’ assertion that they made all reasonable efforts to comply with the 2014 injunction, noting they continued to perpetuate the deceptive scheme rather than tell the truth. | high |
| 07 | Multiple corporate co-defendants settled or did not appeal, but Katz and Levison personally chose to appeal contempt findings even though their liability was zero because corporate funds paid the full judgment. | medium |
The PR Machine
Suppressing negative feedback · 4 points
| 01 | On Point Global ordered employees to write fake positive reviews posing as objective third parties satisfied with the paid guides they received, specifically to push negative reviews off the first page of Google search results. | high |
| 02 | Internal communications show management explicitly discussed the need to bury reviews calling the operation a scam and directed staff to create content praising the convenience and value of the services. | high |
| 03 | The company touted a robust refund policy in public statements and court filings, but the real emphasis was on ensuring consumers either did not realize they were scammed or found small charges not worth disputing. | high |
| 04 | On Point Global’s Facebook page for DMV.com explicitly advertised that you can renew your driver’s licenses online here and skip the lines doing it from your home, directly contradicting any claimed disclaimers. | high |
Exploiting Delay
Years of unchecked operations · 5 points
| 01 | The 2014 Acquinity injunction against Katz was supposed to prevent exactly this type of deception, yet On Point Global operated from at least 2017 to 2019 before the FTC filed suit, demonstrating that permanent injunctions provide little real deterrent. | high |
| 02 | Even after the FTC filed suit in 2019, the case meandered through preliminary injunction hearings, appeals, and discovery for years before final contempt sanctions were confirmed in March 2023. | medium |
| 03 | The district court initially sided with Katz and Levison on key remedy issues over FTC objections, approving an opt-in claims process that the FTC argued would under-compensate victims. | medium |
| 04 | Katz and Levison successfully persuaded the district court to execute the claims process immediately without further appeals, then turned around and appealed after the money was distributed, attempting to have it both ways. | high |
| 05 | The Supreme Court’s AMG decision in 2021 forced the FTC to pursue more complex legal theories for monetary relief, creating additional delay and uncertainty in an already protracted case. | medium |
The Bottom Line
What this case reveals · 6 points
| 01 | This case demonstrates that even permanent injunctions against specific individuals for consumer fraud do not prevent repeat offending when the profit potential dwarfs the perceived risk of eventual enforcement. | critical |
| 02 | The Eleventh Circuit affirmed all key rulings, holding that the websites were materially deceptive on their face, that Levison had actual notice of the 2014 injunction, and that the contempt sanctions were proper. | high |
| 03 | The court confirmed that district courts retain inherent authority to impose compensatory sanctions for contempt of FTC Act injunctions, rejecting Katz and Levison’s argument that AMG precluded such relief. | medium |
| 04 | Nearly all victim claimants were eventually repaid through the court-supervised claims process, but this restitution came years after the harm and likely reached only a fraction of those actually deceived. | medium |
| 05 | The fact that Burton Katz and Brent Levison never paid a dollar personally despite being found individually liable for fraud demonstrates how corporate structures shield executives from meaningful accountability. | critical |
| 06 | On Point Global’s ability to operate for years despite high chargebacks, processor terminations, search engine bans, and a prior injunction against its CEO reveals systemic failures in consumer protection infrastructure. | critical |
Timeline of Events
2014
Burton Katz stipulates to permanent injunction in FTC v. Acquinity Interactive, barring false or misleading representations about products, services, or consumer payment obligations.
2014
Katz tells Brent Levison about the Acquinity injunction and Levison sees the document when it is resolved or entered.
2017-2019
On Point Global operates deceptive government-services websites, generating over $102 million in revenue while Katz and Levison hold executive roles.
2017-2019
On Point Global triggers Visa fraud monitoring thresholds 64 times in three years due to excessive chargeback rates.
2019
On Point Global generates $17 million from selling personal data collected through benefit-eligibility websites.
2019
FTC files suit against Katz, Levison, and On Point Global alleging violations of the FTC Act and contempt of the 2014 Acquinity injunction.
2020
District court enters preliminary injunction halting On Point’s deceptive operations and appointing a receiver to manage assets.
2021
Supreme Court decides AMG Capital Management v. FTC, limiting FTC’s ability to obtain monetary relief under Section 13(b).
September 2021
District court grants summary judgment for FTC, finding websites materially deceptive and holding Katz and Levison in contempt of 2014 injunction.
November 2021
After bench trial, district court finds defendants jointly and severally liable for up to $102,769,235.47, with final amount to be determined through victim-claims process.
February 2022
District court approves receiver’s opt-in claims process over FTC objections. Katz and Levison urge immediate execution to put money in consumers’ pockets sooner.
March 2023
Receiver notifies court that claims process is complete and defendants’ total liability is $19,599,235.68, paid from corporate funds.
March 2023
District court confirms $19.6 million sanctions amount. Katz and Levison appeal the contempt rulings and sanctions they previously endorsed.
August 2023
Appeal becomes final when 150-day deadline passes without separate judgment entry, making March 2023 order appealable.
Direct Quotes from the Legal Record
QUOTE 1
On Point’s own admission of consumer confusion
allegations
“In a Fraud Reduction Plan, On Point acknowledged to a credit-card processor that we still encounter confusion from customers despite the disclaimers.”
💡 The company knew its disclaimers were not working but continued the deception anyway.
QUOTE 2
Bold false promises on the websites
allegations
“The sites featured a large, bold headline, Renew Drivers License In Your State, next to which these words appeared in orange capital letters: GET ALL THE INFORMATION TO COMPLETE THE PROCESS NOW.”
💡 The prominent messaging explicitly promised to complete government processes, not just provide information.
QUOTE 3
Levison’s sworn admission of knowledge
accountability
“Levison testified that Katz made him very aware of the FTC/Acquinity matter and settlement shortly after it was resolved. When FTC counsel showed Levison a copy of the order, Levison admitted, Yes, I have seen this order when it was resolved or when it got entered into.”
💡 Levison cannot claim he didn’t know about the injunction his company was violating.
QUOTE 4
District court’s finding on website deception
allegations
“The district court held that On Point’s paid-guide sites could lead a reasonably prudent consumer to believe that they were going to renew their license or car registration.”
💡 The court found the websites deceptive on their face, not just because some consumers misunderstood.
QUOTE 5
Disclaimers failed to correct net impression
accountability
“On Point’s choice of centering, bold type, and white background made the deceptive text such as ‘Renew Driver’s License’ jump out at a consumer, while the disclaimers were difficult to read, confusing at best, and failed to disclose that the websites would not complete licensing or registration transactions.”
💡 Small print cannot overcome large bold lies in the headline.
QUOTE 6
Fake review campaign directive
pr_machine
“On Point directed employees to write fake reviews posing as an objective third party satisfied with the PAID GUIDE they received, in order to push negative reviews off of the first page in google search listings.”
💡 The company deliberately tried to suppress evidence that consumers were calling it a scam.
QUOTE 7
Employee complaints about the business model
accountability
“One employee lamented that On Point did not add value to the users. Guides are sometimes confusing for the people and that causes problems for us such as suspensions from our main platforms Google & Bing. Another employee complained that some of the money we earn comes from a service that has, at least in the past, tried to misrepresent itself as something other than a how-to guide.”
💡 Even On Point’s own staff knew the business was built on deception and felt remorse.
QUOTE 8
Katz and Levison’s about-face on remedies
accountability
“Katz and Levison urged the district court to approve the distribution plan, conceding it was well within the Court’s equitable power to redress consumer loss by allowing any consumers who believe they were deceived by Defendants’ websites to request and receive reimbursement, and asked the court to put money in the pockets of consumers sooner. Katz and Levison declared that the claims process aligns with the evidence and was the appropriate contempt remedy.”
💡 They endorsed the exact remedy they now appeal, waiving their objections through invited error.
QUOTE 9
No personal assets touched
accountability
“The receiver explained that she had collected more than $30 million from the corporate defendants, meaning she would not need to reach Katz or Levison’s personal assets to satisfy the $19.6 million judgment.”
💡 Despite being found personally liable for over $100 million in fraud, Katz and Levison paid nothing out of pocket.
QUOTE 10
Eleventh Circuit’s affirmation of deception finding
conclusion
“This Court recognized when affirming the district court’s earlier entry of a preliminary injunction that the district court had ample evidence to conclude that the websites were misleading.”
💡 The appeals court had already found the websites deceptive before the final trial even occurred.
QUOTE 11
Inherent contempt authority survives AMG
conclusion
“When a district court enters an injunction under Section 13(b), the court retains inherent contempt powers to remedy violations of its own orders, and such authority exists independently of the underlying statute’s prescribed remedies.”
💡 The Supreme Court’s AMG decision did not eliminate courts’ power to sanction contempt of their own orders.
QUOTE 12
Targeting the desperate
community
“On Point targeted consumers looking for government websites, paying Google and Bing to display sponsored links to its sites when consumers searched for dmv.pa.gov, renew Florida driver’s license online, and similar terms.”
💡 The company deliberately intercepted people searching for official government services at their moment of greatest need.
QUOTE 13
Benefit sites collected sensitive medical data
community
“The benefit-eligibility websites solicited sensitive personal information including specific medical diagnoses like cancer, diabetes, hearing loss, dermatitis, psoriasis, eczema, skin rashes, and chronic pain, as well as disability status, employment status, health insurance coverage status, and need for low-income medical assistance.”
💡 The most vulnerable people gave up their most private information thinking they would get help qualifying for benefits.
QUOTE 14
Load balancing to evade fraud detection
profit
“On Point deflated chargeback ratios by dividing charges into two installments often $3.99 and $19.99 and seeking $1 charitable contributions, knowing that consumers would rarely dispute the smaller amounts.”
💡 Every aspect of the payment structure was engineered to fly under fraud-detection radar.
QUOTE 15
Receiver shut down paid-guide sites entirely
conclusion
“The receiver removed On Point’s paid-guide websites after concluding they could not be run lawfully.”
💡 An independent officer of the court determined the business model was inherently fraudulent and could not be fixed.
Frequently Asked Questions
What exactly did On Point Global do wrong?
On Point Global operated websites that looked like official government portals and explicitly promised to renew driver’s licenses, register vehicles, and determine eligibility for public benefits like Section 8 housing and food stamps. After consumers paid fees or provided sensitive personal information, they received only worthless PDF documents with publicly available information. The company also sold the personal data to third parties.
How much money did Burton Katz and Brent Levison make from this scheme?
The court found that On Point Global generated over $102 million in total revenue. The paid-guide websites alone brought in $85 million net of refunds and chargebacks between 2017 and 2019. In 2019, the benefit-eligibility websites generated $17 million from selling personal data.
Didn’t the websites have disclaimers saying they weren’t government sites?
Yes, but the district court found those disclaimers were buried in tiny gray text against gray backgrounds at the top and bottom of pages, overshadowed by large bold headlines promising actual government services. Under consumer protection law, disclaimers must be clear and conspicuous enough to correct the overall misleading impression. On Point’s disclaimers failed that test.
Was Burton Katz already under a court order not to do this?
Yes. In 2014, Katz stipulated to a permanent injunction in an earlier FTC case called Acquinity Interactive that specifically barred him from making false or misleading material representations about products, services, costs, or consumer payment obligations. He told his business partner Brent Levison about this injunction, yet they operated On Point Global using the same deceptive playbook.
Did the victims get their money back?
Some did. The court ultimately ordered $19.6 million in restitution through an opt-in claims process. Nearly all claimants who came forward were repaid. However, this represents only about 19% of the total $102+ million the operation collected, and many victims likely never realized they were eligible to file claims or that they had been scammed at all.
Did Burton Katz or Brent Levison go to jail or pay personally?
No. This was a civil case, not a criminal prosecution. The court held them jointly and severally liable for the restitution, but the $19.6 million judgment was paid entirely from corporate funds. The court-appointed receiver collected over $30 million from the corporate defendants, so Katz and Levison never had to forfeit personal assets despite being found individually liable.
Who were the typical victims of this scam?
The scheme specifically targeted vulnerable populations including low-income families seeking public benefits, seniors trying to renew licenses, disabled individuals, and time-strapped workers who couldn’t take time off to visit a DMV office in person. The benefit-eligibility sites collected sensitive data from people searching for Section 8 housing, food stamps, Medicaid, and veterans benefits.
How did On Point Global avoid getting shut down for so long?
The company used sophisticated evasion tactics including load balancing (creating multiple corporate shells and merchant accounts to keep individual chargeback ratios below fraud thresholds), rotating domain names and ad accounts when search engines banned them, splitting charges into small amounts to avoid disputes, and posting fake positive reviews to bury scam warnings.
Why didn’t credit card companies or Google stop this sooner?
Credit card processors did terminate multiple On Point accounts for excessive chargebacks, and Google and Bing repeatedly suspended the company’s ads for misleading content. But On Point simply opened new merchant accounts under different corporate names and returned with new domains each time, playing an ongoing cat-and-mouse game that allowed the operation to continue.
What can I do to avoid scams like this?
Always verify you are on an official government website by checking that the URL ends in .gov. Be extremely skeptical of paid services for things that government agencies provide for free or for statutory fees. Never provide sensitive personal information including medical diagnoses, Social Security numbers, or financial details to a website unless you are certain it is legitimate. Search for the company name plus the word scam before paying. If something feels off, exit the site and contact the relevant government agency directly using a phone number from their official .gov website.
https://www.ftc.gov/system/files/ftc_gov/pdf/katz_ftc_brief.pdf
It’s the Katz!
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