PRIMARY SOURCEthe executed federal judgment and iMall’s own SEC filings
On November 30, 1998, Mark Comer signed a federal court order promising to stop selling business opportunities and never again to misrepresent what a buyer could earn. In March 1999, the same month the Federal Trade Commission approved that settlement, he bought the business it was about. iMall’s own annual report records the company selling “the fixed assets related to the former Seminar Division to Mark Comer” for $333,000, paid in the company’s own stock. The ban did not end the seminar. It moved it into his name. Every figure below is from iMall’s SEC filings and the FTC’s own executed order, obtained in full via FOIA request.
Why this belongs on this site. The asset-protection brand at the center of the rest of this reporting, Legally Mine, was built by the McNeff family whose franchise dispute is the rest of this site, and this spring its brand moved to a company controlled by Mark Comer. This site has already reported that Comer signs the flagship charity’s returns and that the FTC barred him for life in 1999. What was not yet on the record is the shape of the 1999 case itself, now that the executed order and the company’s filings are in hand: not a man who got caught, but a man who kept the thing he was caught selling.
iMall is remembered as a dot-com; Excite@Home bought it in 1999 for stock then valued near $425 million. But iMall’s own annual report says the company was, by revenue, a seminar business. Its “Seminar Division” accounted for approximately 95 percent of the Company’s revenues, about $7.3 million in 1998. What the seminars sold was a business opportunity. The FTC’s complaint describes it: iMall drove consumers to free seminars “through direct mail pieces, radio commercials, a television infomercial, a promotional cassette, seminar presentations and telemarketing,” and pitched them, “in return for a $2,995 fee,” the chance to become iMall Consultants selling web pages. The claim made at the seminar was an earnings claim: buyers “putting as little as five to 10 hours per week into the business” could “reasonably expect to earn between $2,000 and $20,000 per month,” with mailers featuring testimonials of consumers who had “supposedly earned as much as $100,000 from the program.” The FTC alleged those claims were false and had no reasonable basis, and that the sales violated the Franchise Rule.
The settlement is usually summarized as a lifetime ban on selling internet business opportunities. The executed Stipulated Final Judgment, entered April 12, 1999, is broader than that summary. Beyond the permanent bans on internet and pay-per-call business opportunities, two further bars on Comer carry no expiration and no industry limit. He is permanently enjoined from “violating any provision of the Franchise Rule, 16 C.F.R. § 436, as it is now written or as it may hereinafter be amended,” the rule that in 2007 grew to govern the financial-performance claims a franchisor may make; and from “misrepresenting any fact material to a consumer’s decision to purchase any service or product,” which is not limited to the internet, or to franchises, or to any industry. The order also entered a $4 million judgment and required a $500,000 bond before either man could sell business opportunities again.
The activity bans are drafted to reach him in any costume. Each one applies “whether directly or indirectly, in concert with others, or through any intermediary, business entity or device.” That is 1998 language for a simple idea: the prohibition attaches to the man, not to whatever company he acts through. The two unlimited bars above carry no such clause because they need none. They are unqualified. Comer signed the order personally on November 30, 1998, represented by Barry J. Cutler of Baker & Hostetler, a former director of the FTC’s own Bureau of Consumer Protection. He was not a man who did not understand the rule.
In a fraud case, the contested element is nearly always state of mind: what the seller knew, and when. That element is ordinarily proved sideways, by inference, over years of discovery. A signed federal injunction is the element, reduced to a document. The man under this order cannot say he did not know that earnings claims are regulated, or that the Franchise Rule applied to what he sold. The order names the rule, cites it, binds him to its future amendments, and carries his signature, entered on the advice of a lawyer who had run the FTC bureau that enforces it. The Federal Rules of Evidence admit a prior order in a later case about similar conduct for exactly this purpose: not to show bad character, which is forbidden, but to show “knowledge” and “absence of mistake,” the two things every misrepresentation defense claims. Fed. R. Evid. 404(b)(2).
An injunction also runs on a second track that ordinary fraud law does not have. A fraud claim must prove intent. A contempt motion does not: it asks whether a valid order existed, whether the person knew of it, and whether it was obeyed. This order closes its own escape hatches. The defendants agreed that the complaint’s facts “shall be taken as true in any subsequent litigation filed by the Commission to enforce its rights pursuant to this Order, including, but not limited to, a nondischargeability complaint in any bankruptcy proceeding,” and the court ordered that it “shall retain jurisdiction of this matter for all purposes.” No end date is attached to either sentence. Whether any present-day conduct of any business falls inside the order is a question no court has been asked, and this page does not answer it. What the document establishes is narrower and harder: since April 12, 1999, what Mark Comer knows about the law of selling has been fixed, in writing, by a federal court.
iMall discontinued the Seminar Division on August 28, 1998, as the FTC investigation closed in. Then, in the company’s own words in its annual report for that year: “In March 1999 the Company entered into an agreement to sell the fixed assets related to the former Seminar Division to Mark Comer, a beneficial owner of more than 5% of the outstanding Common Stock and a former officer and director of the Company. The total purchase price was $333,000 paid by delivery by Mr. Comer to the Company of 20,091 shares of Common Stock.” The FTC approved the settlement on March 30, 1999. In the same month, the man taking a federal ban on the seminar business bought that business out of the company, paying with iMall stock that was months from converting into Excite@Home shares. The order itself left the door open for the currency of the deal: “Nothing in this Order shall be construed so as to prohibit either defendant Pickering or defendant Comer from owning stock in iMall.” The same filing records iMall also paying “Sierra Advertising, a private advertising firm owned in part by Messrs. Pickering and Comer,” in connection with the same wind-down. The value walked out of the company that took the penalty and into the hands of the men who ran it.
The “$4 million settlement” was not one payment. It was $750,000 owed by iMall the company and $3.25 million owed personally, jointly, by Comer and his co-founder Craig Pickering. The company’s half is documented as paid: iMall’s quarterly report states that “in April of 1999 the Company paid the agreed upon settlement of $750,000 with the Federal Trade Commission.” The personal $3.25 million appears nowhere in iMall’s filings, because it was not the company’s debt; by that summer iMall reported it was aware of no legal proceedings of material impact. What the record shows about the men’s ability to pay is only this: the merger agreement names Comer and Pickering among iMall’s “Significant Stockholders,” and the company they held significant stock in was bought months later for roughly $425 million. Whether the personal $3.25 million was ever collected is not on any public document this site can reach. Neither man filed for bankruptcy. The question the record leaves open is whether the government ever got the money, from a man whose next career was making money impossible for anyone to get.
After 1999 Comer became the all-time top earner of a multilevel marketing company sold through recruitment events, then the president of a foundation whose annual golf event this site has already walked through its own returns, and now the holder, through his company Centra Wealth Solutions, of the Legally Mine asset-protection brand, a program sold to professionals at seminars whose pitch, on its own live website, is “saving more than TWICE the cost of the program in tax savings.” That is a claim about money made at a seminar, the exact form the 1999 case was about.
And the road the brand took to reach him is already on this site’s own pages. In 2001, two years after the settlement, the SEC filings of a Utah nutrition company record Comer lending the company money at 10.5 percent interest and then converting the debt into stock: lend first, own after, on the public record since 2001. In 2020, a $300,000 loan from Comer to Daniel McNeff, known from McNeff’s own testimony in federal court, and set out on the site’s legal-analysis page. In the 2021 through 2024 seasons, a Legally Mine banner in the event galleries of the foundation Comer leads, while the brand still belonged to the McNeff family. And in 2026, amid the creditor pressure documented in The lenders, the brand itself, landing in his company. Lend, sponsor, capture: three documented steps, each from a public record, each reported here before this post connected them in one line.
The shape rhymes with 1999. As Legally Mine came under a 2025 Ohio order for the unauthorized practice of law, the McNeff entity that held it was renamed to a husk and the brand reappeared, days later, inside Comer’s clean company; the seminar’s own recorded claims are reviewed, doctrine by doctrine, in the July 29 response. In 1999 the seminar assets walked out of the company under FTC fire into Comer’s hands. In 2026 the brand walked out of the company under a state court’s fire into Comer’s. The difference is that this time the thing being carried out is the machine that carries things out.
The fair counterpoint. Nothing here is a finding that Mark Comer has violated the 1999 order, and this site does not claim it. The 1999 judgment was a stipulated settlement, not a merits admission, and the identification of today’s Mark Comer with the 1999 defendant rests on several independent public identifiers, set out with the same care in The law. Buying assets from a company you helped run is lawful; the 1999 repurchase is disclosed in a public SEC filing, which is the opposite of hidden. Several of the order’s provisions expired by their own terms long ago: the $500,000 bond requirement and the monitoring and record-keeping duties ran five years, and the bar on selling franchises ran ten; the provisions quoted above as permanent are the ones the order itself leaves without an end date. Whether an asset-protection program sold to professionals is the kind of “service or product” the order reaches, and whether any present claim is a misrepresentation, are fact-specific questions no court has decided. Public records show Centra holds the brand’s registered name; who runs the brand’s day-to-day marketing is not established by any public record, and the brand’s live site continues to present the operation as it existed under the McNeff family. The 1999 repurchase was, on iMall’s own filing, an insider transaction, a more-than-5-percent owner buying from his own company; the 2026 brand transfer is different in kind: no ownership or family tie between Mark Comer and the McNeff family is established, and this site does not claim one. Lending a man money and sponsoring a tournament are lawful, ordinary acts; what Centra paid for the brand, and how the transfer is measured under Utah’s transfer statutes in light of them, are open questions, analyzed and left open on the same page. Comer does not own Bricks & Minifigs, and nothing here says he does. The $3.25 million is recorded as unverified, not as unpaid; the absence of a public record of collection is not proof of non-payment. Every quotation above is reproduced as written in the filing or order it comes from, so a reader can weigh it. Nothing here is a finding of law, and every person named is presumed to have acted lawfully.
Sources. The executed Stipulated Final Judgment and Order for Permanent Injunction, FTC v. iMall, Inc., Craig R. Pickering, and Mark R. Comer, No. 99-03650 (C.D. Cal., entered April 12, 1999), obtained from the Federal Trade Commission under FOIA (request 2026-00892) and posted here in full; the quoted prohibitions, the intermediary clause, the taken-as-true clause, the stock provision, and the retained-jurisdiction provision appear at Sections III, IV, and XVI of the order. The FTC’s Complaint in the same matter, on file with this site, for the seminar-pitch allegations. iMall, Inc. SEC filings (EDGAR, CIK 1020862, cited by filing): Form 10-KSB for fiscal 1998 (filed March 31, 1999), quoted for the Seminar Division’s share of revenue, the $333,000 asset sale to Mark Comer for 20,091 shares, and the Sierra Advertising payment; Form 10-QSB for the first quarter of 1999, quoted for the $750,000 payment to the FTC; Form 10-QSB for the second quarter of 1999 for the no-material-proceedings statement; and the Form 8-K of July 13, 1999 attaching the Excite@Home merger agreement, quoted for “Significant Stockholders.” The FTC’s April 15, 1999 announcement, “Internet Mall Promoters Settle FTC Charges,” for the redress allocation and bond. On the evidentiary use of prior orders, Fed. R. Evid. 404(b)(2). The 2026 brand transfer and the Ohio unauthorized-practice order are documented in The lenders and The machine; the charity returns, the 2021 through 2024 event-gallery sponsorships, and the 2001 Whole Living, Inc. lending-to-ownership filings (SEC, CIK 1091983) in the July 21 post; the $300,000 loan, from Daniel McNeff’s federal-court testimony, and the identity confirmation in The law; the seminar’s recorded claims in the July 29 response; the network itself on the map. Barry J. Cutler’s FTC role is a matter of public record.
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