IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

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1 Filing # Electronically Filed 10/13/ :53:17 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA, Plaintiff, vs. Case No. INTERFACE 3 LLC, f/k/a INTERFACE BOCA LLC, a Florida limited liability company, ROMAN VINTFELD, an individual, ITALENT.COM LLC, a Delaware limited liability company, 33 WATER STREET LLC, a Delaware limited liability company, GOT TALENT LLC, a New Jersey limited liability company, INTERFACE OPERATIONS GROUP LLC, a New Jersey limited liability company, INTERFACE HOLDINGS GROUP LLC, a New Jersey limited liability company, INTERFACE MANAGEMENT GROUP LLC, a New Jersey limited liability company, INTERFACE I LLC, a New Jersey limited liability company, INTERFACE SONO LLC, a Delaware limited liability company, and INTERFACE IP GROUP LLC d/b/a OTRIAD LLC, a Delaware limited liability company, Defendants, HILLSIDE MANAGEMENT GROUP, INC., a New Jersey corporation, DANIELLE VINTFELD, an individual, and MIKE (MIKHAIL) WINFELD a/k/a MIKE VINTFELD, an individual, Relief Defendants. / COMPLAINT Plaintiff, OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA ( Plaintiff or the Attorney General ), sues the Defendants, 1

2 INTERFACE 3 LLC, f/k/a INTERFACE BOCA LLC, a Florida limited liability company, INTERFACE OPERATIONS GROUP LLC, a New Jersey limited liability company, INTERFACE HOLDINGS GROUP LLC, a New Jersey limited liability company, INTERFACE MANAGEMENT GROUP LLC, a New Jersey limited liability company, INTERFACE I LLC, a New Jersey limited liability company, INTERFACE SONO LLC, a Delaware limited liability company, INTERFACE IP GROUP LLC d/b/a OTRIAD LLC, a Delaware limited liability company, ITALENT.COM LLC, a Delaware limited liability company, 33 WATER STREET LLC, a Delaware limited liability company, GOT TALENT LLC, a New Jersey limited liability company, and ROMAN VINTFELD, an individual (collectively, the Defendants ), and the Relief Defendants, HILLSIDE MANAGEMENT GROUP, INC., a New Jersey corporation, DANIELLE VINTFELD, an individual, and MIKE (MIKHAIL) WINFELD a/k/a MIKE VINTFELD, an individual (collectively, the Relief Defendants ), and states the following in support hereof. JURISDICTION and VENUE 1. This action is brought pursuant to Florida s Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes ( FDUTPA ). 2. Plaintiff is an enforcing authority of FDUTPA and is authorized by (1)(a), Fla. Stat., to bring an action to obtain a declaratory judgment that an act or practice violates FDUTPA. The Attorney General further is authorized by (1)(b), Fla. Stat., to bring an action to enjoin any person who has violated, is violating, or is otherwise likely to violate FDUTPA and by (3), Fla. Stat., to obtain further equitable relief as appropriate. 2

3 3. This Court has jurisdiction pursuant to Florida Statutes Section and FDUTPA. 4. Venue is proper in the Fifteenth Judicial Circuit as Defendants engaged in business in Palm Beach County, Florida and their actions affected more than one judicial circuit in the State of Florida. 5. Defendant InterFace 3 LLC, f/k/a InterFace Boca LLC ( InterFace ), is a Florida limited liability company with a principal place of business in Boca Raton, Palm Beach County, Florida. 6. Defendant Roman Vintfeld ( Vintfeld ) is an individual residing in Mahwah, Bergen County, New Jersey, is not in the military and is otherwise sui juris. 7. Defendant InterFace Holdings Group LLC ( InterFace Holdings ) is a New Jersey limited liability company with a principal place of business in East Brunswick, Middlesex County, New Jersey. 8. Defendant InterFace Operations Group LLC ( InterFace Operations ) is a New Jersey limited liability company with a principal place of business in East Brunswick, Middlesex County, New Jersey. 9. Defendant InterFace Management Group LLC ( InterFace Management ) is a New Jersey limited liability company with a principal place of business in East Brunswick, Middlesex County, New Jersey. 10. Defendant GOT TALENT LLC ( Got Talent ) is a Delaware limited liability company with a principal place of business in Edgewater, New Jersey. 11. Defendant InterFace I LLC ( InterFace I ) is a New Jersey limited liability company with a principal place of business in East Brunswick, New Jersey. 3

4 12. Defendant INTERFACE SONO LLC ( InterFace SoNo ) is a Delaware limited liability company with a principal place of business in Framingham, Massachusetts. 13. Defendant InterFace IP Group LLC, d/b/a Otriad LLC ( Otriad ) is a Delaware limited liability company with a principal place of business in New York, New York. 14. Defendant italent.com LLC ( italent ) is a New Jersey limited liability company with a principal place of business in Atlanta, Georgia. 15. Defendant 33 Water Street LLC ( 33 Water Street ) is a Delaware limited liability company with a principal place of business in Norwalk, Connecticut. 16. Relief Defendant Hillside Management Group, Inc. ( Hillside Management ) is a New Jersey limited liability company with a principal place of business in Fort Lee, New Jersey. 17. Relief Defendant Danielle Vintfeld ( Danielle Vintfeld ) is an individual residing in Mahwah, Bergen County, New Jersey, is not in the military and is otherwise sui juris. 18. Relief Defendant Mike (Mikhail) Winfeld a/k/a Mike Vintfeld ( Mike Vintfeld ) is an individual residing in Fort Lee, New Jersey, is not in the military and is otherwise sui juris. 19. Plaintiff has conducted an investigation and the head of the enforcing authority, Attorney General Pamela Jo Bondi, has determined that an enforcement action serves the public interest. A copy of that determination is attached hereto as Exhibit A. 20. InterFace, at all times material hereto, provided goods or services within the definition of Section (8), Florida Statutes. 21. InterFace, at all times material hereto, solicited consumers within the definition of Section (7), Florida Statutes. 22. InterFace, at all times material hereto, was engaged in a trade or commerce as defined by Section (8), Florida Statutes. 4

5 23. Defendant Vintfeld is the director and managing member of InterFace, Interface Operations, Interface Holdings, Interface Management, Interface I, InterFace SoNo, Otriad, italent, 33 Water Street and Got Talent. 24. At all material times hereto, Defendant Vintfeld owned, managed and controlled the day-to-day operations of InterFace, Interface Operations, Interface Holdings, Interface Management, Interface I, InterFace SoNo, Otriad, italent, 33 Water Street and Got Talent. 25. At all material times hereto, Defendant Vintfeld participated in and controlled the actions and practices of InterFace, possessed actual and/or constructive knowledge of all unfair and deceptive acts and practices complained of in this Complaint, and directly participated in and directed the unfair and deceptive acts and practices complained of herein. 26. Relief Defendants Hillside Management, Danielle Vintfeld and Mike Vintfeld received consumers funds to which they had no legitimate claim and were unjustly enriched. DECEPTIVE ACTS AND PRACTICES 27. At all times material hereto, Defendant InterFace was a purported talent marketing company not properly licensed with the State of Florida as a talent or modeling agency. 28. Defendant InterFace engages in the occupation or business of procuring or attempting to procure engagements for artists, including models, singers, musicians and actors, in exchange for fees. 29. Defendant InterFace claims, in its advertising and marketing and through its online website, to have helped over 10,000 people get started in exciting Entertainment and Fashion opportunities! 5

6 30. Defendant InterFace, through its agents and employees and at the direction of Defendant Roman Vintfeld, engages in high-pressure and misleading sales tactics in order to sell its services to consumers. 31. At the outset, talent scouts acting on behalf of InterFace approach parents in shopping malls and retail venues throughout South Florida, including but not limited to malls in Sunrise, Miami, Pembroke Pines, Doral, Boca Raton, Wellington and Ft. Lauderdale, Florida (Palm Beach, Broward and Dade counties). 32. These scouts engage the parents children by profusely complimenting their looks, and suggest that they have enormous potential for careers in modeling or acting. The scouts convince the parents to complete contact cards after which InterFace telemarketers solicit the parents by phone to make in-person appointments at the company s studio in Boca Raton, Florida. 33. During these telephone solicitations, InterFace telemarketers falsely and deceptively misstate that a director is interested in meeting the children at no cost to the parents, while intentionally omitting material facts pertaining to the true costs and nature of the company s services. 34. InterFace also purchases leads from third parties, such as internet lead generators, and makes unsolicited phone calls to consumers who have not previously expressed an interest in InterFace s services, to induce them into making an appointment. 35. During the initial in-person sales meetings with consumers, Defendant InterFace employs misleading and aggressive sales tactics designed to convince consumers to pay hundreds of dollars for the company s services, including but not limited to: 6

7 a. Using trumped-up titles such as Evaluation Director for sales employees who are new to the company and have absolutely no prior training in modeling or talent scouting; b. Convincing parents that their children have the look to succeed in modeling and/or acting, even those children that do not have industry-standard looks and would not likely be signed by licensed modeling agencies or casting agencies; c. Using emotional pressure to convince parents to invest in their children s future and provide them with a once-in-a-lifetime opportunity, while promising that the financial returns from a future career in the modeling/talent industry will far outweigh the costs; d. Making false promises about the children s future potential success and likelihood of employment; e. Creating a false sense of urgency by fabricating imminent casting calls or auditions for which the children would be perfect ; f. Touting an 80% success rate that is false and misleading; g. Creating false and misleading impressions about the company s relationships with clients such as Gap, Carter s, Disney and Nickelodeon, and with prominent modeling agencies such as Ford, Wilhelmina and Elite, which relationships don t actually exist; and h. Creating false and misleading impressions about past clients successes. 36. Defendant InterFace, through its agents, managers and employees, consistently and intentionally engages in deception by omission by failing to provide material disclosures regarding: 1) the true nature and extent of the company s services; and 2) future fees that parents 7

8 will be required to pay in order to reap any value whatsoever from their initial payments to the company. 37. For example, InterFace sales employees unfairly and deceptively mislead consumers into signing and paying $575 to $5,645 for a Professional Services Agreement, which provides a range of photo shoot packages including options for numbers of outfits and headshots, and which lists the number of images a client will receive. 38. Sales employees are trained to and do in fact intentionally create the false impression that the photo shoot and accompanying fees are necessary for the company to aggressively market and promote the parents children, and will include the images. However, in reality, fees paid for this agreement entitle the child to nothing more than the photo shoot itself, plus makeup and hair. 39. It is not until after the parent and their child(ren) appear for the photo shoot and return for a second appointment with a Marketing Director, usually a few days later, that they learn for the first time that the actual prints and marketing require the payment of additional fees and a separate agreement for an online membership. These fees range from an additional $800 to $2,400, plus $9.95/month for online photo access in addition to a $45 copyright release fee. 40. Thus, the consumer learns that their initial payment of $575 to $5,645 was for the experience of a photo shoot and nothing more, not even the actual pictures. By then, it is too late for the consumer to cancel their agreement and get their money back. 41. Adding insult to injury, during this second meeting, the marketing director yet again intentionally misleads consumers into purchasing additional services, convincing them not to waste their initial investment or deprive their child of a golden opportunity, and again 8

9 emphasizing how successful their children are going to be. Notably, all of the above sales tactics are employed on parents in the presence of their children. 42. However, the marketing directors again fail to inform the parents of the fine print, which is that all they are contractually entitled to receive for their additional $800 to $2,400 is a total of three s containing the child s profile page sent to industry professionals. In most cases, these s are no better than spam mail and are completely ignored by reputable agencies and casting companies. 43. Indeed, Defendant InterFace falsely, unfairly, and deceptively advertises their connections and relationships with legitimate modeling agencies such as Wilhelmina, Ford Models, and Elite Model Management when, in fact, no such connections or relationships exist. 44. Ultimately, Defendant InterFace fails to deliver on its promises and representations, and it fails to provide the expected services for the initial fees it leads consumers to believe are all-inclusive. Very few clients see any legitimate results, success, or efforts made on their behalf. 45. While InterFace hides behind its contracts when consumers complain, sales employees are trained to and do in fact intentionally prevent and distract consumers from reading through the written agreements in full during the sales meetings or at home. Instead, the employees quickly flip through the contracts with the consumers, purposely gloss over the fine print, and summarize important provisions in a manner that is misleading and/or contrary to the actual written terms. 46. Defendant InterFace unfairly and deceptively leads consumers to believe there is a 3-day cancellation period with no strings attached, in order to reassure undecided consumers and induce them to sign the agreement without a meaningful opportunity to read and understand 9

10 it. However, in order to actually cancel the contract, the consumer has to send their request, in writing, by certified mail and return receipt requested within three days (including weekends). 47. Once a consumer has had the opportunity to review the full contract, realizes that they have been misled, and requests a cancellation and refund, InterFace systematically and purposefully engages in stalling tactics, ignores consumers phone calls and s, and avoids providing the very refunds it uses as a selling point in order to lure hesitant consumers into a false sense of complacency. As of this date, InterFace owes thousands of dollars in refunds to consumers who cancelled their agreements in strict compliance with the company s policies. 48. Defendant InterFace, through its agents, managers and employees, and under the direct control of Defendant Roman Vintfeld, engages in a deliberate and systematic pattern of misleading and deceiving Florida consumers about the true nature and extent of its services and the actual, total costs involved. 49. Defendant Vintfeld remotely monitors and records, by video and audio, every inch of the company s office in Boca Raton, Florida. He consistently listens to and views the sales presentations with consumers, most of whom are unaware that they and their children are being monitored and recorded and have not provided meaningful consent. He then provides direct feedback and instructions to his employees and managers, who in turn report back to him on a daily basis regarding sales volume and revenues. 50. Accordingly, Defendant Vintfeld has actual and/or constructive knowledge of the aforementioned acts and omissions of InterFace employees, and he directs and controls, and has the ability to control, the acts and practices of InterFace including all of the aforementioned misrepresentations made to consumers. 10

11 51. Such aforementioned misrepresentations were in fact relied upon by reasonable persons and consumers of InterFace, who suffered monetary damages as a result. COMMON ENTERPRISE 52. InterFace, InterFace Holdings, InterFace Operations, InterFace Management, Got Talent, InterFace I, InterFace SoNo, Otriad, italent and 33 Water Street (the Corporate Defendants ) have operated and functioned as a common enterprise while engaging in the deceptive acts and practices and other violations of law alleged in this Complaint. They have conducted the business practices described herein through an interrelated network of companies that have common ownership, control, officers, directors, members and managers. The Corporate Defendants share a corporate office and call center based out of East Brunswick, New Jersey. The Corporate Defendants also commingle funds and rely on a shared method and system to identify potential clients, sell their services, bill clients, and handle customer service. 53. For example, InterFace, InterFace I, InterFace SoNo and italent are considered the local sales centers in Florida, New Jersey, Connecticut, Massachusetts and Georgia. Got Talent provides the local scouting services in each mall and retail location, which then provides leads to the main call center in New Jersey for telemarketing to potential clients. Otriad provides the online and digital marketing and social media for each of the entities. 33 Water Street was formed to purchase and maintain the real property for InterFace SoNo in Connecticut. 54. InterFace Management provides management and executive functions for all of the Corporate Defendants. 55. InterFace Operations provides the corporate services for each of these entities, including but not limited to customer service, call center operations, IT support, human resources, accounting and billing. 11

12 56. Consumer funds that are solicited in each of the sales centers are transferred to, and commingled with, accounts in the name of InterFace Holdings, which acts as the holdings company for the financial assets of the Corporate Defendants. InterFace Holdings is also the parent company and 100% owner of InterFace Operations, InterFace Management and Otriad. 57. From there, funds are dispersed and transferred back and forth to each of the Corporate Defendants as necessary to continue their operations, as well as to InterFace Management, which then further transfers funds to Roman Vintfeld and Danielle Vintfeld, individually, and to Mike Vintfeld through Hillside Management. 58. Because these Corporate Defendants have operated as a common enterprise, each of them is jointly and severally liable for the acts and practices described in this Complaint. 59. Defendant InterFace commingled and transferred monies received from Florida consumers into accounts held by the Corporate Defendants along with Hillside Management, Danielle Vintfeld and Mike Vintfeld. 60. Relief Defendants Hillside Management, Danielle Vintfeld and Mike Vintfeld have no legitimate claim to the monies received from those consumers through transfers made by InterFace, and were unjustly enriched at the expense of Florida consumers. COUNT I VIOLATIONS OF FLORIDA S DECEPTIVE AND UNFAIR TRADE PRACTICES ACT (FDUTPA) 61. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 60 as if fully set forth herein. 62. Section (1), Fla. Stat., establishes that unfair or deceptive acts or practices in the conduct of any trade or commerce are unlawful. 12

13 63. As described above, and through their common enterprise, Defendants have engaged in deceptive and unfair acts and practices likely to deceive a consumer acting reasonably in violation of the provisions of Chapter 501, Part II of the Florida Statutes. 64. As a result of Defendants unfair and deceptive trade practices, Defendants have caused damage to consumers in the State of Florida. 65. Unless Defendants are permanently enjoined from engaging further in the acts and practices complained of herein, the continued activities of Defendants will result in irreparable injury to the public and consumers in the State of Florida for which there is no adequate remedy at law. COUNT II PER SE VIOLATIONS OF FDUTPA BASED ON VIOLATIONS OF CHAPTER 468, PART VII, FLORIDA STATUTES 66. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 60 as if fully set forth herein. 67. Florida Statutes Section (3) establishes that a violation of FDUTPA may be based upon any law, statute, rule, regulation, or ordinance which proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or practices. 68. Chapter 468, Part VII, Florida Statutes, pertaining to Talent Agencies is a statute that proscribes unfair methods of competition, or unfair, deceptive, or unconscionable acts or practices. Among other provisions, section , Fla. Stat., makes it unlawful for any talent agency to publish or cause to be published any false, fraudulent, or misleading information, representation, notice, or advertisement; or to give any false information or make any false promises or representations concerning an engagement or employment to any applicant. 13

14 69. Additionally, section (1) establishes that it shall be unlawful for any person to own, operate, solicit business, or otherwise engage in or carry on the occupation of a talent agency in this state unless the person first procures a license for the talent agency. 70. Section (1) defines a talent agency as any person who, for compensation, engages in the occupation or business of procuring or attempting to procure engagements for an artist. 71. Through their common enterprise, Defendants own, operate, solicit business, engage in and carry on the occupation or business of procuring or attempting to procure engagements for artists, in exchange for fees. 72. Therefore, despite representing itself as a talent marketing company and not a talent agency, InterFace is in fact a talent agency and subject to the provisions of Chapter 468, Part VII, Florida Statutes. 73. Defendants violated Section (1), Fla. Stat. by owning and operating a talent agency without a license in this State. 74. Defendants InterFace and Vintfeld violated Section , Fla. Stat., by: a. Failing to maintain a record sheet for each booking; b. Failing to maintain required records pursuant to (2), Fla. Stat.; c. Failing to post in a conspicuous place in the office of such talent agency a printed copy of Chapter 468, Part VII; d. Failing to advise an artist, in writing, that the artist has a right to rescind a contract for employment within the first 3 business days after the contract s execution; e. Publishing or causing to be published false, fraudulent, or misleading information, representation, notice, or advertisements; failing to provide written 14

15 disclosures under (6), Fla. Stat.; and giving false information and making false promises or representations concerning an engagement or employment; f. Sending or causing to be sent any person as an employee to any place for the modeling or photographing of a minor in the nude in the absence of written permission from the minor s parents or legal guardians; and g. Dividing fees with others as defined in (8), Fla. Stat. 75. The violations by Defendants InterFace and Vintfeld of Sections (1) and , Florida Statutes, constitute per se violations of FDUTPA. 76. By failing to maintain a license with the State as a talent agency, and misleadingly representing itself as a talent marketing company, InterFace has attempted to avoid the legal requirements imposed by Chapter 468, Part VII and thereby mislead and deprive Florida consumers of its protections. 77. These actions and omissions by Defendants and resulting violations of Chapter 468, Part VII constitute unfair and deceptive trade practices in violation of FDUTPA. COUNT III UNJUST ENRICHMENT OF RELIEF DEFENDANTS 78. Plaintiff adopts, incorporates herein and re-alleges paragraphs 1 through 60 as if fully set forth herein. 79. Relief Defendants Hillside Management, Danielle Vintfeld and Mike Vintfeld each obtained funds as part of, and in furtherance of, the FDUTPA violations alleged above without a legitimate claim to those funds. 80. Relief Defendants Hillside Management, Danielle Vintfeld and Mike Vintfeld were unjustly enriched. 15

16 81. Under those circumstances, it is not just, equitable or conscionable for them to retain the funds unlawfully received from Florida consumers. 82. Relief Defendants Hillside Management, Danielle Vintfeld and Mike Vintfeld should each be ordered to disgorge the funds they received as a result of the Defendants violations of FDUTPA. WHEREFORE, the Attorney General requests that this Honorable Court enter Judgment against the Defendants, jointly and severally, to: A. DECLARE that the foregoing acts and practices are unfair, deceptive and/or unconscionable in violation of FDUTPA. B. DECLARE that the foregoing acts and practices are violations of Chapter 468, Part VII of the Florida Statutes, which constitute per se violation of FDUTPA. C. Permanently ENJOIN Defendants Vintfeld, InterFace, Interface Operations, Interface Holdings, Interface Management, Interface I, InterFace SoNo, Otriad, italent, 33 Water Street and Got Talent, and their officers, affiliates, agents, servants, employees, attorneys and those persons in active concert or participation with them who receive actual notice of this injunction from marketing, soliciting, advertising, selling, providing, promoting, rendering, engaging in or accepting payment for any modeling, acting or talent services in the State of Florida. D. AWARD such equitable or other relief as is just and appropriate pursuant to Section , Florida Statutes, including, but not limited to, disgorgement of ill gotten gains and repatriation of assets necessary to satisfy any judgment. E. AWARD full restitution to all consumers who are shown to have been injured, pursuant to Section , Florida Statutes. 16

17 F. ASSESS civil penalties in the amount of Ten Thousand Dollars ($10,000.00) as prescribed by Section , Fla. Stat. or Fifteen Thousand Dollars ($15,000.00) for victimized senior citizens as prescribed by Section , Fla. Stat. for each act or practice found to be in violation of Chapter 501, Part II, of the Florida Statutes. G. AWARD attorneys fees and costs pursuant to Section , Fla. Stat. or as otherwise authorized by law. H. As against the Relief Defendants, jointly and severally, AWARD such equitable or other relief as is just and appropriate pursuant to Section , Florida Statutes, including, but not limited to, disgorgement of ill gotten gains and repatriation of assets necessary to satisfy any judgment. I. GRANT such other relief as this Honorable Court deems just and proper. Dated this 13th day of October, 2014 Respectfully Submitted, PAMELA JO BONDI Attorney General of the State of Florida /s/ Sarah L. Shullman By: Sarah Shullman Assistant Attorney General Florida Bar No Office of the Attorney General Consumer Protection Division 1515 N. Flagler Drive, Suite 900 West Palm Beach, Florida Telephone: (561) Facsimile: (561)

18 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA, Plaintiff, vs. Case No. INTERFACE 3 LLC, f/k/a INTERFACE BOCA LLC, a Florida limited liability company, ROMAN V!NTFELD, an individual,!talent. COM LLC, a Delaware limited liability company, 33 WATER STREET LLC, a Delaware limited liability company, GOT TALENT LLC, a New Jersey limited liability company, INTERFACE OPERATIONS GROUP LLC, a New Jersey limited liability company, INTERFACE HOLDINGS GROUP LLC, a New Jersey limited liability company, INTERFACE MANAGEMENT GROUP LLC, a New Jersey limited liability company, INTERFACE I LLC, a New Jersey limited liability company, INTERFACE SONO LLC, a Delaware limited liability company, and INTERFACE IP GROUP LLC d/b/a OTRIAD LLC, a Delaware limited liability company, Defendants, HILLSIDE MANAGEMENT GROUP, INC., a New Jersey corporation, DAN!ELLE VINTFELD, an individual, and MIKE (MIKHAIL) WINFELD a/k/a MIKE VINTFELD, an individual, Relief Defendants. DETERMINATION OF PUBLIC INTEREST NOW COMES, PAMELA JO BONDI, ATTORNEY GENERAL, STATE OF FLORIDA, and states: Exhibit A

19 13th October Exhibit A