In the Matter of Victory Media, Inc., a corporation, also doing business as G.I. Jobs, and also doing business as Military Friendly, File No. 162 3210 #00005

Submission Number:
00005
Commenter:
Fretwell
State:
California
Initiative Name:
In the Matter of Victory Media, Inc., a corporation, also doing business as G.I. Jobs, and also doing business as Military Friendly, File No. 162 3210
The FTC can help reduce deception practices by Victory Media by imposing fines near the high end of the FTC's statutory authority. It seems clear that Victory Media's continued aggressive stance regarding alleged illegal activity reflects no intention to actually abate their exploitation of military personnel unless they are forced to do so by substantive punitive measures. If their past behavior is any indication, Victory Media will simply adapt to the FTC settlement by changing the packaging - rather than the substance - of their business model, unless the FTC makes that behavior too costly to continue. A simple example: Victory Media continues as recently as this week to claim that ""the methodology and weighting is based on many different complex inputs, is statistically driven and then audited by Ernst & Young." http://www.trentonian.com/general-news/20171020/mccc-received-military-f... However, the private watchdog group, Veterans Education Success, reports: "Ernst & Young's global head of communications denied any relationship to Victory Media or its Military Friendly Schools list. Later, Victory Media produced a single partner of EY Pittsburgh who admitted they had a contract with Victory Media, but EY clarified EY "cannot vouch" for the "methodology" of "Military Friendly Schools" survey and list. Specifically, EY did not engage in any analysis of Victory Media's methodology, but instead had simply checked that Victory Media followed its own methodology. In other words, there was no assessment of the usefulness or validity of Victory Media's methodology." Allowing this intentionally deceptive misrepresentation to continue harms America's veterans and harms higher-education's role in our society. A substantive fine from the FTC will make the deception less profitable.