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The Federal Trade Commission has obtained a stipulated final order barring a Carrollton, Texas-based defendant from promoting or selling work-at-home business opportunities, including medical billing opportunities. According to the Commission’s complaint, the defendant violated the FTC Act by making numerous misrepresentations to consumers, including that she had doctors who were ready to out-source their medical billing claims work, that consumers who used her services would earn substantial income, and that there was a 100 percent satisfaction guarantee. The stipulated final order also bars the defendant from violating the FTC’s Franchise Rule and contains a judgment of $3.26 million, which has been suspended due to her inability to pay.

“Deceiving consumers is not only a lousy way to do business, it’s also illegal,” said Howard Beales, Director of the FTC’s Bureau of Consumer Protection. “We’re pleased that the Court has barred this fraudulent promoter from selling any home-based business opportunities in the future and deceiving any more consumers.”

Today’s stipulated final order was entered into with Michele Graham, former president of Medical-Billing.Com, Inc. (Medical-Billing), doing business as Professional Management Consultants. Graham allegedly was involved in all of the company’s activities, including advertising, promotion and sales, and handling consumer complaints.

The FTC’s original complaint in this matter named both Graham and Medical-Billing as defendants. The FTC dismissed its action against corporate defendant Medical-Billing. The company, which is now in Chapter 7 bankruptcy, has no assets and has ceased all operations. The Commission’s lawsuit was filed as part of the 2002 “Operation Dialing for Deception” law enforcement sweep.

The Defendant’s Business Practices

As the FTC first alleged when announcing “Operation Dialing for Deception,” Graham, acting as the owner and president of Medical-Billing, solicited consumers throughout the United States, offering them the opportunity to start or expand an existing work-at-home medical billing business. In letters sent to consumers, Graham allegedly guaranteed consumers that she could locate health-care professionals to use their medical billing services that would generate from $15,000 to $75,000 per year.

Graham offered consumers three levels of investment – $4,000, $6,000, and $9,000. All three participating levels came with a “100% refund guarantee.” After consumers signed contracts with the defendant to purchase her marketing services, they allegedly typically received no help from the defendant in obtaining new business. The defendants allegedly used stalling tactics to avoid consumer complaints, with very few consumers ever receiving their money back, despite the “full-refund” guarantee.

According to the Commission’s complaint, Graham violated the FTC Act in three ways: 1) by misrepresenting to consumers that she would provide health-care professionals who would use the consumers to process their medical claims; 2) by misrepresenting that consumers who bought her medical billing marketing services would earn a specific level of income; and 3) by misrepresenting that she would provide dissatisfied consumers with full refunds.

Terms of the Stipulated Order

The stipulated final order announced today contains an array of terms to prevent the defendant from engaging in similar deceptive conduct in the future. First, it prohibits Graham from promoting or selling work-at-home business opportunities, including medical billing opportunities. Next, the order mandates that Graham comply with the FTC’s Franchise Rule in the future, including providing complete and accurate disclosures and earnings claims documents. In addition, the order prohibits Graham from misrepresenting – in connection with the advertising, promotion, or sale of any good, service, franchise, business venture, or work-at-home opportunity – either of the following: 1) that she has established business relationships with any health-care professionals, and 2) that consumers can readily obtain refunds if dissatisfied with her products or services. Finally, Graham is prohibited from misrepresenting any fact material to a consumer’s decision to purchase any good or service she markets.

The stipulated final order also contains a suspended judgment of $3.26 million and provides the FTC with the right to reopen the case and reinstate the monetary penalty if Graham is found to have concealed any of her assets. Other standard provisions include prohibitions on Graham’s sale of any customer lists and certain compliance and record-keeping requirements.

The Commission vote to approve the order was 5-0. It was filed in the U.S. District Court for the Northern District of Texas, Dallas Division, on November 18, 2003, and requires the signature of the judge.

NOTE: This stipulated final judgment is for settlement purposes only and does not constitute an admission by the defendants of a law violation. Stipulated judgments have the force of law when signed by the judge.

Copies of the Commission’s complaint and stipulated final judgment are available from the FTC’s Web site at and also from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, DC 20580. The FTC works for the consumer to prevent fraudulent, deceptive, and unfair business practices in the marketplace and to provide information to help consumers spot, stop, and avoid them. To file a complaint, or to get free information on any of 150 consumer topics, call toll-free, 1-877-FTC-HELP (1-877-382-4357), or use the complaint form at The FTC enters Internet, telemarketing, and other fraud-related complaints into Consumer Sentinel, a secure, online database available to hundreds of civil and criminal law enforcement agencies worldwide.


Mitchell J. Katz,
Office of Public Affairs


Tom Carter or Gary Kennedy
FTC Southwest Region, Dallas

(FTC File No. X020044; Civ. No. 3-02CV 0702P)