In March 2023, a United States district court confirmed that two key executives—Burton Katz and Brent Levison—were liable, alongside their company On Point Global, for orchestrating an elaborate scheme that deceptively promised critical government services. Rather than providing real license renewals, car registrations, or public-benefit eligibility determinations, the websites run by Katz and Levison delivered little more than generic PDF “guides” full of publicly available information. Worse yet, On Point Global also collected and then sold consumers’ personal data—such as phone numbers, addresses, and information about medical diagnoses or debt—profiting from the most vulnerable individuals searching online for immediate financial assistance, driver’s license renewals, or other urgent government services.

According to the Federal Trade Commission (FTC), the damage was astounding: more than $102 million accrued from this matrix of deceptive websites. Consumers flocked to On Point’s sites under the impression they were on official government portals. Many discovered only later that they had paid for worthless PDF files or surrendered their sensitive personal data to be bombarded by solicitations from other dubious third parties. This occurred despite On Point Global’s disclaimers in small, obscure print that it was not affiliated with any government agency—disclaimers the court found wholly inadequate to correct the sites’ larger, bolder misrepresentations, such as big headlines proclaiming: “Renew Your Driver’s License Now” or “Find Out If You Are Eligible For Medicaid.”

By strategically purchasing targeted ads on search engines and social media, On Point Global snared audiences who typed in phrases like “renew Florida driver’s license online” or “Section 8 housing eligibility.” People in dire need of the services On Point Global falsely promised—especially low-income households, seniors, or folks lacking the time or resources to navigate official channels—fell prey to websites that led them down a rabbit hole of sign-ups and fees. In the end, many never got legitimate assistance from any government office. Equally troubling, On Point used the data it collected to spam consumers with text messages or resell those leads to still other scam operators.

The misconduct did not stop at the websites alone. Evidence uncovered in the district court case showed that high chargeback rates (consumer-initiated credit card disputes) became a frequent red flag. Some credit-card processors severed ties with On Point Global because of repeated allegations of fraud. On search engines, On Point faced suspensions for misleading advertising and tried to circumvent the bans by creating separate shell companies (“load balancing”) or artificially splitting consumer charges into small amounts so as not to trigger fraud thresholds. And to bury negative reviews labeling the sites a “scam,” On Point staff reportedly posted fake glowing endorsements.

All this, however, may not have been entirely surprising: Katz had been caught by the FTC in a previous scam involving unauthorized charges on victims’ phone bills. That earlier case ended in 2014 with a permanent injunction banning Katz from “making false or misleading material representations” about consumer services. Astonishingly, Katz, along with the corporation’s general counsel and a top shareholder, Levison, used that same business approach again in On Point Global—blithely violating the 2014 order and effectively daring regulators to catch them.

The latest ruling deemed Katz and Levison in contempt of the 2014 injunction and found that the On Point Global websites were exactly the kind of misrepresentations barred under that prior court order. The new judgment—backed by an extensive victim-claims refund process—held them and their corporate entities jointly and severally liable for tens of millions in compensatory sanctions. Nearly all claimants have reportedly been repaid, a result the court praised as essential for restoring those consumers’ losses.

But while the courts have taken decisive action to clamp down on this one network of fraudulent websites, the broader context raises serious questions about how effectively our economic and regulatory systems function under neoliberal capitalism. Katz and Levison’s operation exemplifies how corporate greed and profit-maximization intersect with regulatory capture, a hands-off approach to oversight, and sometimes minimal enforcement budgets. Even when the FTC obtains permanent injunctions, unscrupulous operators can still flourish, circumventing or outright ignoring the restrictions—particularly if the corporate structure is opaque, if disclaimers are used as a fig leaf for legitimacy, and if the public is left vulnerable in the face of deceptive digital marketing.

In this long-form investigative piece, we will expose how Katz and Levison carried out their alleged scheme at On Point Global, all while ignoring an injunction that was specifically meant to prevent repeat offenses. The aim is to illuminate systemic issues in corporate accountability and consumer advocacy. Within the framework of neoliberal capitalism, these issues reflect a pattern: large corporations that face relatively small or delayed consequences can find it rational to continue or replicate exploitative tactics in pursuit of shareholder profits. As this story makes clear, corporate social responsibility was scant, while wealth disparity-driven desperation made lower-income people easy targets. The alleged wrongdoing thrived on illusions of legitimacy, effective marketing, and the often-outdated notion that disclaimers—no matter how small or hidden—can shield a business from accountability.

Before we proceed to examine the deeper structures enabling such conduct, we will first place the most shocking and egregious details front and center. The facts gleaned from the FTC’s legal complaint, depositions, and district court rulings reveal how a marketing behemoth drew in more than $102 million by siphoning from those who could least afford it—and how the public discovered too late that “renew your license now” was a hollow promise.

What follows is an eight-part chronicle dissecting not just the allegations themselves, but also the larger forces—deregulation, regulatory inaction, political climates that favor commercial speech, and a myopic brand of corporate ethics—that allow these recurring patterns of corporate corruption to persist. After exploring the companies’ alleged corporate tactics and how they effectively “got away” with it for years, we’ll examine the fundamental question: Is this pattern of predation truly a bug in the system, or is it the system working as intended under a profit-first approach? We will close with a discussion of public interest considerations, the methods corporations use to handle PR fallout, and the urgent need for vigilance among consumers, regulators, and social justice advocates alike.

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Corporate Intent Exposed

Corporate wrongdoing often leaves behind a paper trail, but in the case of On Point Global, the brazen “intent” behind the business model appears to have been maximizing revenue by capitalizing on consumer confusion. Although Katz and Levison have disputed aspects of these claims, the district court concluded that On Point’s websites were “materially deceptive” on their face.

First, the websites featured bold promises to provide or finalize official processes—like driver’s license renewals—for a fee. Even the domain names and site designs seemed to mimic official government pages. Large print often said “Renew Drivers License in Your State,” while disclaimers in small or gray font quietly revealed that no service would be completed. Such disclaimers, the court found, “did not dispel confusion.” Rather, the net impression conveyed was that a consumer could complete an official government transaction by paying On Point.

Second, once consumers entered personal data—from addresses to phone numbers, sometimes even sensitive medical or financial information—the site typically output nothing more than a generic PDF that repeated publicly available steps and telephone numbers. In essence, On Point was not performing the promised government service but merely relaying instructions consumers could have freely obtained on official state websites. Meanwhile, On Point monetized the collected data by reselling it to third parties, who might then peddle psychic hotlines, payday loans, or suspicious government grants. In one sense, On Point was trafficking in leads, turning every site visitor into a commodity.

A separate class of On Point’s websites targeted people seeking public benefits—especially for housing, Section 8 eligibility, or food stamp programs (SNAP). These pages employed big bright links saying “Check Your Eligibility” or “Find Out if You Qualify,” and cajoled users into revealing their monthly incomes, medical conditions, number of dependents, and more. Again, the result was not actual assistance from a government agency. Consumers received only a PDF with generic info. The real profit for On Point came from selling these personal details to new advertisers.

The direct, explicit statements on these websites formed the backbone of the district court’s conclusion that the operation was knowingly misleading. Indeed, the court found that disclaimers stating “we are not a government agency” were either too small, too vague, or overshadowed by the overall marketing messages—causing a net impression that the consumer was paying for real government services. The court also noted that hundreds of consumer complaints poured in, disputing credit-card charges or realizing that they had been charged twice.

According to statements in court, internal On Point communications revealed management was very aware that consumers felt deceived. High chargeback rates signaled that the magnitude of confusion went beyond a small fraction of users. Moreover, search engines like Google and Bing repeatedly suspended On Point’s ads for misleading or deceptive content. And at some point, On Point began posting fake positive reviews to drown out real “scam warnings” on review sites.

The question of “intent” here is particularly important. Katz himself had already been enjoined in 2014 from engaging in “false or misleading material representations” after the Acquinity Interactive fiasco, in which Katz’s earlier websites tricked people into providing phone numbers for so-called “free merchandise,” only to funnel unauthorized monthly charges onto their phone bills. That earlier settlement placed Katz under a permanent injunction; allegedly, Katz even told Levison about it, providing a great warning about lying to consumers in any future ventures. Instead, the new operation used nearly identical deception, this time focusing on government-service illusions.

For any corporate executive to float so close to an injunction’s boundaries suggests a willful disregard for a direct judicial order. Coupled with the elaborate steps On Point took to circumvent credit-card processor bans (e.g., creating a patchwork of merchant accounts so no single account’s “chargeback ratio” would exceed thresholds), evidence points to profit-maximizing strategies that placed the brand’s bottom line far above any notion of corporate social responsibility.

The net result was a painful blow to consumers—many from lower-income backgrounds or older populations, who could not easily navigate the labyrinth of actual government websites. Some ended up paying On Point in hopes of expediting essential documents or verifying benefit eligibility that might help them buy groceries, secure affordable housing, or pay medical bills. To see such individuals parted from their money—only to get a worthless PDF and a flood of spam—underscores how economic fallout from unscrupulous corporate actions can reverberate across communities that are already on the knife’s edge of wealth disparity.

By exposing On Point’s repeated pattern of deception, the court pointed to how the company’s alleged wrongdoing was not some slip-up or minor oversight. Rather, it was a business model built on illusions. In the following sections, we will delve into the strategic maneuvers that allowed On Point Global to flourish for as long as it did—maneuvers that, unfortunately, are all too common in an era of digital marketing, neoliberal capitalism, and minimal accountability for unscrupulous players.

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The Corporate Playbook / How They Got Away with It

Corporate scams often follow a recognizable script: create appealing ads, design official-looking webpages, bury disclaimers in fine print, and aggressively chase down unsuspecting consumers. On Point Global’s alleged “playbook” was no exception. But what stands out is the elaborate subterfuge used to maintain their façade, even after repeated consumer complaints and warnings from payment processors.

1. Targeting Vulnerable, Desperate, or Time-Strapped Populations

From the outset, On Point’s strategy took advantage of search terms that reflect urgent consumer needs. People searching “renew license fast,” “Florida driver license renewal,” or “Section 8 housing help” were prime targets because they were often pressed for time or money. In turn, On Point’s Google and Bing ads showcased big headlines to suggest an official or near-official channel, playing directly into the consumer’s stress or confusion.

2. Load Balancing and Corporate Shells

When a particular corporate entity or website triggered too many chargebacks or fraud flags from payment processors, On Point apparently created new corporate shells and merchant accounts. This “load balancing” technique kept each individual merchant account’s ratio of disputed charges below a threshold that would raise immediate suspicion. It is a classic method used by scam operations to prevent any single account from getting cut off—distributing risk across multiple corners of their corporate empire.

3. Misleading Payment Structures

Another hallmark was the way On Point sometimes split charges. For instance, they might charge $3.99 first, then $19.99 (or a similar breakdown), plus a small $1 “charitable donation.” Studies show that small charges are less likely to be disputed—victims might not bother calling their bank to fight a $3.99 fee, even if they realize something was off. Meanwhile, the small donation element might reduce suspicion. For On Point, these small but numerous fees stacked up into tens of millions of dollars of revenue.

4. Burying Clarity in Fine Print

On each website, disclaimers were present—but in a manner the court deemed wholly inadequate. For the typical user, disclaimers appeared in gray text against a gray background or in small font at the very bottom. The main text, in large, bold letters, promised actual government transactions: “Renew Your License,” “Check If You Qualify,” “Register Your Vehicle Today.” The disclaimers might say, “We are not affiliated with any government agency,” or “This site only provides a guide,” but by design or negligence, these disclaimers were overshadowed. Under FTC Act standards, disclaimers must be clear and conspicuous enough to correct a misleading net impression. On Point’s disclaimers didn’t come close.

5. Fake Customer Reviews

As consumer complaints mounted—especially publicly, on review platforms—On Point directed employees to produce fake, positive reviews touting the convenience of the sites. This tactic pushed negative posts off top results or diluted their impact, making it harder for prospective users to realize they were about to get scammed. Internally, employees described the mission as “countering negative reviews,” admitting that many of those negative reviews labeled the business a “scam.”

6. Skirting Advertising Bans

Search engines suspended On Point’s paid ads multiple times for being misleading. But each time, the company returned with new domains, new ad accounts, or fresh corporate identities. The same pattern repeated, suggesting a calculated approach: keep rotating, keep rebranding, keep the money flowing. Even after a so-called “Fraud Reduction Plan,” On Point’s websites continued to perplex and anger consumers who stumbled onto them.

7. Using Disclaimers as Shield

A recurring theme in fraudulent or semi-fraudulent operations is the reliance on disclaimers to shield from liability. The argument typically goes: “We said right there we aren’t affiliated with the government, so it’s not deception.” But in consumer-protection law, a disclaimer must be robust, obvious, and understandable—especially if the main message strongly suggests something else. The district court found On Point’s disclaimers inadequate under well-settled FTC precedent.

Corporate defendants often claim they made efforts to “comply” or that their disclaimers were “sufficient.” But the court saw extensive records of people being actively misled—hundreds of formal complaints, thousands of calls for refunds, and abnormally high chargeback ratios on credit cards. This evidence greatly contradicted any notion that the disclaimers overcame the false impression.

8. Blaming Counsel

Finally, one element of the On Point defense was an attempt to pin blame on lawyers they allegedly consulted. Katz and Levison claimed they had sought “top-drawer” law firms, perhaps hoping to disclaim personal responsibility. The court, however, noted that advice-of-counsel is not a valid defense to civil contempt. By the time you’re under a permanent injunction for earlier false advertising, you cannot outsource your compliance efforts and claim innocence if it fails.

In short, On Point Global’s alleged “corporate playbook” reveals how easily a determined leadership team can dupe consumers on a large scale in an era of minimal gatekeeping. If the threat of regulatory action or lawsuits is perceived as small—or if one believes they can outrun regulators by scaling quickly—then the game may feel worth the risk. Katz and Levison’s websites perfectly illustrate how unscrupulous enterprises can disguise themselves as legitimate service providers and profit rapidly, especially when disclaimers are weaponized as a veneer of legality.

One might ask: Why do these companies assume they can get away with it for so long? The answer often lies in the system that is supposed to oversee them. Regulators are busy, budgets are constrained, and the digital environment is borderline chaotic. Too often, by the time an agency like the FTC or a state attorney general identifies the wrongdoing, millions of dollars have been collected, and the pipeline of unsuspecting visitors continues to flow. Worse still, some fraction of victims never fully realize they were scammed, or they assume it was some legitimate but clumsy step in renewing a license or checking benefits.

As the next section shows, the underlying factor here is profit. The potential payoff dwarfs whatever minimal risk the perpetrators see on the horizon—particularly under a neoliberal capitalist framework that emphasizes market-based solutions and personal responsibility, while starved regulators fight for resources to crack down on corporate greed.

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The Corporate Profit Equation

Profit is the lifeblood of most companies, but in the alleged On Point Global scheme, the pursuit of profit came at the direct expense of unsuspecting consumers. This business model depended on four major revenue streams:

1. Paid-Guide Fees: When consumers wanted to renew a driver’s license or handle a vehicle registration, On Point charged them upfront—sometimes splitting the payment into smaller increments—to deliver a PDF that was worthless to most users. The margin on each PDF was colossal: minimal overhead beyond web hosting, marketing, and disclaimers. Yet tens of millions flowed in, net of chargebacks, refunds, and credit processor fees.
2. Lead-Generation Sales: The public-benefits websites—promising Section 8 housing, food stamps eligibility checks, or low-income medical assistance—harvested sensitive personal data. The company then sold these “leads” to third parties. In 2019 alone, the FTC alleged that On Point generated $17 million from such transactions. Data is the new gold in our digital world; unscrupulous marketing affiliates are often willing to pay handsomely for contact info tied to a specific demographic or financial/medical condition.
3. Cross-Selling or Partner Advertising: Victims’ data was also leveraged for cross-promotional email campaigns. On Point had a pipeline of consumer leads who might be enticed by payday loans, psychic hotlines, or insurance deals. Each time a user clicked through or signed up, On Point could reap partner commissions.
4. Minimizing Refunds / Reducing Chargebacks: Behind the scenes, On Point meticulously worked to keep refunds limited. Officially, they had a “robust” refund policy, but the real emphasis was on ensuring the consumer either didn’t realize the deception in time to dispute the charge or didn’t find the small charge amounts worth the hassle. Through load balancing, On Point kept each merchant account’s dispute ratio below a catastrophic threshold—helping sustain the entire house of cards.

From a broader perspective, this equation exemplifies how corporate accountability can get lost under a purely profit-driven system. If the ratio of paying consumers to complaining ones is large enough, and if each complaining consumer receives a grudging partial refund, the enterprise still walks away with huge net revenue. By the time regulators finally freeze assets or impose a shutdown, tens of millions have been banked.

But there are ripple effects. Users who realize they were scammed may lose faith in legitimate government websites, which can undermine public trust. Others who never realized they were scammed might be lulled into a cycle of confusion. They might even unwittingly give up more personal data to other similar websites. Meanwhile, because On Point targeted lower-income people seeking assistance, the economic fallout lands hardest on those with the fewest resources. A $20 or $30 unexpected charge can mean a lot to a family already on the brink.

That reality highlights the wealth disparity dimension: a model that systematically exploits socioeconomic disadvantages to generate tens of millions of dollars in revenue. The operation ironically used the language of convenience—“Skip the lines!”, “Get your benefits faster!”—but inflicted serious dangers to public health by capturing sensitive data from people with medical conditions or urgent housing needs. It is not a typical business transaction, but a kind of digital trickery aided by a climate of weak oversight.

From the vantage of corporate ethics, On Point’s pursuit of revenue above all else is a cautionary tale. In a regulated environment that truly championed consumer advocacy and social justice, such a scheme would have been impossible to sustain for long. Yet in a neoliberal capitalist environment that often prioritizes commerce over consumer safeguards, the corporate greed impetus can overshadow moral or civic obligations. Over years of operation, On Point’s net proceeds soared well past $100 million, dwarfing the costs of any nuisance chargebacks or the eventual threat of litigation.

Those who argue that corporate social responsibility can be integrated into a profit model must contend with this example. If a business sees a path to easy money by skirting the boundary (or outright ignoring an injunction), will it self-regulate? Or will it rely on disclaimers to do the bare minimum while forging ahead to extract maximum revenue from unknowing consumers?

Ultimately, the real question becomes: What stops them? Our next section will look at the regulatory environment that should have kept On Point in check, but largely failed to do so in a timely fashion.

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System Failure / Why Regulators Did Nothing

On paper, agencies like the Federal Trade Commission exist precisely to block such scams and protect the public interest. In reality, regulators face a barrage of challenges that hamper timely and aggressive enforcement. This raises the specter of regulatory capture and a more general “light-touch” approach that can inadvertently encourage the very kind of repeated misconduct exemplified by Katz and Levison.

1. Limited Resources, Endless Targets

The FTC has broad authority to bring actions under Section 5(a) of the FTC Act and to seek preliminary and permanent injunctions under Section 13(b). However, the digital marketplace is massive. Thousands of questionable sites appear monthly, targeting seniors, low-income consumers, or other vulnerable groups. The agency’s budget constraints, staff limitations, and the long runway for investigating a single enterprise mean that unscrupulous operators can pivot rapidly and remain elusive. By the time the FTC fully documents a scheme, obtains an injunction, and secures a final judgment, scammers often move on—or morph into new corporate shells.

2. The Illusion of “Private Contract” Freedoms

Under neoliberal capitalism, there is a pervasive ideology that individuals freely entering a “contract” via a website or paying for a digital product have “personal responsibility” for the outcome. This perspective implies minimal paternalistic oversight. Some might argue that if disclaimers exist—no matter how small or misleading—consumers should “read the fine print.” Yet consumer-protection law stands for a more balanced approach: disclaimers cannot overshadow the net impression, especially when vulnerable users or essential services are in play. Still, the broader environment remains largely “hands off,” and the burden often falls on the individual to avoid deception.

3. The Complexity of Tech-Driven Fraud

Because On Point’s scheme was embedded in online advertising and lead-generation funnels, it took advantage of the opaqueness of the digital ad ecosystem. The websites changed designs, URLs, and disclaimers rapidly. Payment was processed through multiple merchant accounts. Data was sold to a labyrinth of affiliates. Shutting down the entire operation required unraveling these interlocking corporate structures. Regulators do not have the capacity to systematically audit every suspicious site, especially when new domains can pop up almost instantly.

4. Overreliance on the Courts

While the FTC can investigate, it typically relies on federal courts to issue injunctions or contempt rulings. That takes time. In the On Point saga, the 2014 permanent injunction was supposed to deter Katz from repeating the phone-bill scam blueprint. Yet when Katz teamed up with Levison under the On Point banner, the same patterns reappeared. Only in 2019 did the FTC file a major suit against On Point. By then, the corporate empire had allegedly reaped upwards of $102 million. Even after the FTC secured a preliminary injunction in 2020—freezing assets and halting operations—On Point’s attorneys appealed, and the case meandered through the courts.

5. Legal Loopholes Post-AMG Capital

During the On Point litigation, the Supreme Court’s decision in AMG Capital Management, LLC v. FTC limited the FTC’s ability to obtain certain kinds of monetary relief under Section 13(b). This forced the agency to rely, in part, on civil contempt powers and other narrower legal mechanisms to get money back into victims’ hands. The result is a more convoluted, slower path to restitution. Unscrupulous actors have learned to exploit the ambiguous or narrow pathways for monetary redress, confident that if they are caught, the total cost might be overshadowed by the money they have already collected.

6. Lack of Deterrent

The business rationale behind repeating a scam—even after an initial injunction—often comes down to cost-benefit. If you can pocket $100+ million, operate freely for years, pay some attorneys’ fees, and eventually settle for an amount that might not even surpass your net profits, the math might come out in your favor. Indeed, the court found that Katz’s personal assets were not even tapped to repay On Point’s victims in the end, thanks to corporate funds. The real or perceived leniency of such outcomes can embolden other corporate wrongdoers.

7. Proliferation of “Imitators”

Each time a high-level deception scheme is publicized—especially one involving government-service lookalikes—there is a risk that copycats will emerge. The knowledge that disclaimers or shell-company tactics can buy time becomes a siren song for unscrupulous entrepreneurs. Meanwhile, for the truly desperate consumer—say, someone behind on rent and searching for Section 8 assistance—a new or old scam site can appear at the top of search results tomorrow, and the cycle continues.

In short, there was a fundamental system failure here. Despite a prior injunction meant to deter the same prime actor (Katz), On Point Global thrived. And it took the FTC years to gather the evidence needed to bring a robust enforcement action. The subsequent ruling in favor of the FTC underscores that the system did eventually act. But the question remains—why did regulators do nothing, or little, until so many were victimized? The answer resides in the interplay of underfunded enforcement, the labyrinthine nature of digital marketing, and the ideological presumption that “the market” will self-correct. It shows how easily a well-funded, cunning corporate entity can slip through regulatory cracks under a profit-first framework.

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This Pattern of Predation Is a Feature, Not a Bug

It’s tempting to frame On Point Global’s corporate misconduct as an isolated story of a few bad apples. However, a closer look suggests that these types of consumer deceptions have become a systemic feature of how digital commerce unfolds under neoliberal capitalism. Large corporations will always find new “opportunities” to exploit consumer vulnerabilities when oversight is weak or slow.

1. The Neoliberal Ethos and Deregulation

Since the late 20th century, a policy shift has favored deregulation, trusting markets to self-regulate. In principle, if a firm deceives customers, the market punishes it as word-of-mouth spreads and competitors gain favor. In practice, especially online, the speed and scale of deception can far outpace organic feedback loops. By the time consumers realize the websites are worthless, the operators can pivot domains, rename the brand, or even disclaim wrongdoing. Under this environment, the presence of disclaimers or “terms and conditions” can suffice as legal camouflage.

2. The “Fast Money” Doctrine

Scams or borderline scams often rely on a short horizon to get “fast money” from a mass of consumers. By the time regulators respond, the operation might be rebranded or dissolved. Then the cycle repeats. This short-term profit model thrives in a culture that lionizes entrepreneurial risk-taking and lumps consumer complaints into “buyer beware.” But these are not mere trifles: people’s livelihoods, identities, and financial security can be thrown into chaos. And with state agencies outnumbered and under-resourced, the path to accountability is either lengthy or nonexistent.

3. Incentivizing Questionable Tactics

When corporate boards and shareholders demand quarterly growth, executives face strong incentives to cut corners. That can mean borderline marketing or full-on fraud. The wealth disparity in modern societies makes it even easier to target the underserved. Low-income individuals, the elderly, or immigrants in need of quick official paperwork can’t always differentiate an official site from a lookalike. Even if they suspect foul play, they may lack the time or resources to contest small charges or read the fine print.

In the Katz and Levison saga, the fact that Katz had already been enjoined for phone-bill deception underscores that repeat offending can become an internalized business pattern. It’s not that the 2014 injunction was a small matter; but clearly, the lure of easy millions dwarfed the fear of returning to court. Meanwhile, the disclaimers and nominal disclaimers served as just enough of a fig leaf to operate until the scale of consumer confusion became undeniable.

4. Reluctance to Over-Regulate Online Commerce

Federal and state governments are historically loath to hamper digital innovation with too many regulations, worried they might “stifle growth.” While there’s genuine value in fostering e-commerce, the side effect is a legal environment that often disadvantages consumers who are misled. If the burden to detect fraud rests heavily on individuals, and the corporate response to complaints is to either issue partial refunds or disclaim responsibility, the scam can continue for quite some time.

5. Systemic Erosion of Trust

Repeated experiences of corporate deception degrade public trust in online transactions—and in the government’s ability to protect citizens. This erosion of trust is not simply a footnote; it fuels cynicism, undermines public confidence in actual government websites, and fosters a sense that “big corporations always win.”

When regulators finally catch up, they might freeze the corporation’s assets or impose monetary sanctions. Yet if the money is already made and potential personal liability is easily skirted by corporate structures or insurance policies, has justice truly been served? The On Point scandal ended with corporate assets paying out the consumer claims, but neither Katz nor Levison lost their personal fortunes. From an outside vantage, it could appear that repeated wrongdoing is not only feasible but also profitable.

6. A Feature, Not a Bug

Those who study corporate corruption argue that such predatory practices are inherent in an economic system that places few real checks on private entities—especially when intangible digital products or data are the currency. The repeated reemergence of scams that revolve around disclaimers, “official-sounding” websites, and personal data sales is no accident. It reflects a systemic design that tolerates risk-taking, profit-seeking, and ephemeral accountability.

Even among “legitimate” corporations, you can find parallels—tricky subscription renewals, hidden fees, or manipulative upsells. The difference is often just a matter of degrees. If the brand is big enough and the disclaimers are orchestrated by corporate attorneys, the operation may skirt the law. If it crosses the line, a mild settlement or a promise to behave might suffice to quell regulators.

But at a fundamental level, the real harm falls disproportionately on those individuals who can least afford to lose a single dollar. That asymmetry is what cements the notion that this “pattern of predation” is not an outlier but part of a larger structure. If the legal system truly wanted to eliminate such fraud, you’d see more robust enforcement, quicker interventions, and stiffer penalties that deter future wrongdoing. The fact that On Point Global persisted for years, despite all the red flags, shows a status quo that effectively tolerates this brand of corporate exploitation—until and unless a scandal reaches critical mass.

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The PR Playbook of Damage Control

When suspicion mounts against a corporation that relies on deception, the Public Relations (PR) response is often as orchestrated as the scam itself. On Point Global’s alleged approach to damage control included several hallmarks:

1. Fake Testimonials: As mentioned, staff posted positive reviews on consumer sites to drown out negative feedback from real victims. These orchestrated reviews, couched in everyday language, helped bury the “scam” label on search engines.
2. Claiming Confusion Rather Than Deception: Corporate spokespeople or attorneys for such operations typically assert that their disclaimers are clear, that “some customers misunderstood,” or that they’re “just providing valuable educational guides.” The thrust is to paint the fiasco as a “miscommunication” problem, not an intentional con.
3. Highlighting Refund Policies: Whenever confronted, On Point might point to an official policy offering refunds to dissatisfied customers. The reality is that many consumers found it difficult to even figure out they had been scammed, let alone how to request or secure a full refund. But from a PR standpoint, the mere existence of a “generous refund policy” helps to muddy the waters.
4. Legal Denial & Shifting Blame: In depositions and court documents, Katz and Levison tried to shift responsibility to lawyers who supposedly approved the site disclaimers. The message is: “We did everything by the book as advised by counsel; if anything was wrong, it was an honest mistake.” While that might work in some regulatory contexts, in a civil contempt setting—especially when a prior injunction is in effect—“lack of intent” is no defense.
5. Individualization Tactics: Another frequent tactic is to single out specific consumer “complaints” as anomalies, implying that the majority of people were happy. The reality, of course, is that the proportion of consumers who actually lodge formal complaints is always dwarfed by those who remain silent—either because they don’t realize they were scammed, they feel the amounts are too small to fight over, or they don’t know which agency to contact.
6. Misdirection & Technical Language: Companies in hot water may bury inquiries in technical jargon about Terms & Conditions, disclaimers, or disclaimers about disclaimers. They rely on the confusion or disinterest of the public to let them carry on. Meanwhile, they emphasize the “complexity” of e-commerce to discourage deeper scrutiny.

In the modern age, where large-scale corporate greed can quickly come to light on social media, the PR machine tries to keep scandal at bay until the enterprise can pivot or rebrand. Because On Point’s core business model was so reliant on believability, managing negative public perception was crucial. If potential customers Googled “On Point scam,” and the search results displayed a wave of condemnation, the revenue pipeline would be jeopardized.

Although ultimately the FTC lawsuit and judicial intervention forced On Point’s network to shut down or drastically alter, the PR strategies they employed are instructive. They demonstrate how “damage control” is not simply about apologizing or righting wrongs, but rather about continuing revenue generation and avoiding accountability. For consumers, the lesson is that a corporation’s official statements or star ratings can be artificially inflated—and that the presence of disclaimers or a “help desk” rarely means a site is legitimate.

Even after the final rulings, PR spin can overshadow the underlying systemic problem. The executives might say, “We had a misunderstanding, but everything’s resolved now.” This rhetorical approach downplays how big the harm actually was, how many consumers were affected, and how the entire fiasco underscores deeper flaws in the environment of corporate ethics and regulatory enforcement.

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Corporate Power vs. Public Interest

If there is a singular takeaway from the On Point Global saga, it is the dramatic showdown between corporate power and public interest—and how difficult it can be for the latter to prevail. Beneath the veneer of disclaimers and legal arguments lies a fundamental tension: our legal system can be slow and reactive, whereas unscrupulous corporate actors can be lightning-fast, flexible, and opportunistic.

1. The Human Toll

At the end of the day, the court’s $19.6 million restitution pot—though substantial—arrived after years of consumer harm. While the victim-claims process allowed many individuals to recoup losses, thousands more may not have realized they were eligible or had even been scammed. Data on how many people, especially from marginalized communities, simply wrote off the charges as a “weird site fee” is unknown. Meanwhile, the intangible damage of giving away personal data might linger: identity theft risk, a barrage of spam and phishing attempts, or the emotional stress of losing trust in online resources.

2. Broader Impact on Marginalized Communities

Scams that promise government services or benefit checks notoriously hit low-income, elderly, or disabled individuals disproportionately. If you are well-resourced—technologically savvy or with ample time to read disclaimers—you might avoid such pitfalls. But for a single mother working two jobs, or a senior with minimal internet fluency, these sites appear to be a lifeline. The economic fallout can thus amplify existing wealth disparity.

Beyond the direct monetary losses, these communities suffer socially. They might lose faith in actual government programs or be less likely to pursue legitimate benefits in the future, fearing more deception. In turn, local economies suffer because money that could circulate within them is siphoned off by the scammers. The intangible cost is a deeper sense of alienation and mistrust toward official processes.

3. The Question of Corporate Accountability

Yes, the FTC eventually prevailed, and the district court hammered Katz and Levison with findings of personal involvement and knowledge of the wrongdoing. But consider that Katz was not forced to forfeit personal assets. The joint-and-several liability arrangement meant that corporate funds covered the final restitution. As critics point out, if unscrupulous executives can hide behind corporate entities, then the deterrent effect on future wrongdoing may be limited.

In other high-profile frauds, individual executives have faced criminal charges. Here, it was a civil matter under the FTC Act. Civil contempt allowed the court to freeze assets and eventually repay consumers, but it came too late to prevent harm on a massive scale. Moreover, the complexities of the digital marketplace often give an illusion of accountability rather than a reality, as defendants can claim they “didn’t mean to mislead” or that everything was “in compliance” with disclaimers.

4. A Microcosm of Neoliberal Capitalism

The On Point Global fiasco is not just about a single corporation. It is emblematic of how neoliberal capitalism—with its emphasis on individual responsibility, minimal regulatory intervention, and near-religious faith in market-driven solutions—creates an environment ripe for exploitation. Regulators try to keep up, but the pace of digital transformation and the sophistication of profit-driven scammers can outstrip them.

One might argue that the underlying architecture of big tech platforms (Google Ads, Facebook, affiliate marketing) inadvertently facilitates or at least fails to curtail, the spread of deception. After all, if you have the advertising budget, you can get your link in front of millions of users searching “DMV renewal.” The platform’s main focus is ad revenue, not consumer protection. Meanwhile, the standard response from these platforms, if pressed, is: “We take measures to ban misleading content,” yet the cat-and-mouse game continues.

5. Consumers’ Rights and Agency

For those who champion consumer advocacy, the On Point case underscores that real solutions require more than lawsuits filed years after the fact. Consumer education is critical—helping people spot suspicious disclaimers, verifying domain names (e.g., “.gov”), or calling official agencies if uncertain. But consumer education alone can’t close the gap if entire corporate operations are engineered to look official.

In addition, stronger public policy measures—like prompt domain takedowns for proven fraud, or holding executives personally liable for repeat offenses—could shift incentives. Alternatively, credit-card networks can be more proactive in shutting down merchants with repeated high chargeback rates. Payment processors, after all, serve as a gatekeeper, and the revelations about On Point’s “load balancing” show how easily that gate can be circumvented.

6. Looking Ahead

If the system remains unchanged, it is likely that new On Point Globals will emerge, promising quick fixes to bureaucratic processes, hooking unwary consumers, and raking in profits until or unless the FTC intervenes. The big question is whether lawmakers or the tech industry will adapt to prevent or at least minimize the next wave of deceptive marketing.

Just as importantly, will we see any fundamental shift in corporate ethics? If corporate executives weigh the cost of occasional lawsuits against the huge upside of capturing market share through deception, some will inevitably choose the latter—unless the deterrents become meaningful. The status quo is often akin to a speeding ticket on the highway: if your time savings or profit gained from speeding outweighs the risk of a one-time fine, you might keep speeding.

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https://www.ftc.gov/system/files/ftc_gov/pdf/katz_ftc_brief.pdf

https://www.ftc.gov/system/files/ftc_gov/pdf/ftc_v._burton_katz_et_al_ftc_opposition_to_motion_for_stay_pending_appeal_8.10.21.pdf

https://www.ftc.gov/system/files/documents/cases/federal_trade_commission_v._burton_katz_11th_cir._brief_of_the_ftc.pdf

It’s the Katz!