PRIMARY SOURCEthe executed federal judgment and iMall’s own SEC filings
This is the plain-language version of the cited update, written to be read out loud. The court order it describes is posted in full on the site. Nothing here is a court ruling, and everyone named is presumed to have acted lawfully.
The man whose company took over the Legally Mine brand this spring signed a promise to a federal court in 1998. Most people remember it as a lifetime ban on selling internet business opportunities. The actual signed order has now been obtained in full from the FTC via FOIA request, all twenty-three pages, and two parts of the promise are bigger than that, and they never expire.
Mark Comer promised, first, never to violate the FTC’s Franchise Rule, and not just the rule as it stood in 1998: the order says “as it is now written or as it may hereinafter be amended.” The rule was later amended, in 2007, and today it is the rule that governs what a franchise seller may tell a buyer about money. Second, he promised never to misrepresent “any fact material to a consumer’s decision to purchase any service or product.” Read that slowly: any fact, any service, any product. Not internet products. Anything, sold to anyone, forever. He signed it personally, on November 30, 1998, and his lawyer was not some general practitioner: it was Barry Cutler of Baker & Hostetler, who used to run the very FTC bureau that brings these cases. The order was also written so it could not be dodged with paperwork. The selling bans in it reach him, quote, “whether directly or indirectly, in concert with others, or through any intermediary, business entity or device.” That is 1998 legal language for: no matter what name is on the company.
Here is the part almost nobody knows. iMall looked like a dot-com, but by its own annual report about 95 percent of its revenue came from its Seminar Division, hotel-ballroom events where people paid $2,995 after being told they could make $2,000 to $20,000 a month working five to ten hours a week. The FTC said those claims were false. And in March 1999, the same month the FTC approved the settlement, iMall’s own filing says it sold “the fixed assets related to the former Seminar Division to Mark Comer” for $333,000, which he paid not in cash but in iMall stock. The order even says, in writing, that nothing in it stops Comer from owning iMall stock. A few months later iMall was bought for stock worth about $425 million. So the ban did not end the seminar business. The seminar business moved into the banned man’s name, and he paid for it with shares that were about to turn to gold.
The famous $4 million settlement was two pieces. The company owed $750,000, and its next quarterly filing says plainly that it paid. The other $3.25 million was owed personally by Comer and his co-founder. That piece appears in no public filing anywhere, and whether the government ever collected it is a question no public record answers. Not proof it went unpaid, to be fair. Just a hole where a receipt would be, next to two men whose stock was months from a nine-figure buyout.
The site has already published each step of the road, and lined up they read like a method. In 2001, two years after the settlement, SEC filings show Comer lending a Utah nutrition company money at 10.5 percent and then converting the loan into ownership. Lend first, own after. In 2020, Daniel McNeff, the man who built Legally Mine, testified in federal court about a $300,000 loan, and the lender was Mark Comer. From 2021 to 2024, Legally Mine’s banner hangs in the photo galleries of the golf tournament that funds the foundation Comer runs, back when the brand still belonged to the McNeff family. And in 2026, with creditors pressing the McNeff side, the brand landed in Comer’s company. Lend, sponsor, capture. Three steps, every one of them from a public record.
In a fraud case the whole fight is usually over what the seller knew. Was it a lie, or an honest mistake? A signed court order ends that argument for the person who signed it. He knew the rule: it is quoted in the order. He understood it: the former head of FTC consumer protection explained it to him. He even agreed, in the order, that the government’s complaint counts as true if the FTC ever has to come back and enforce it, and the court kept jurisdiction over him, quote, “for all purposes,” with no end date. And breaking a court order is its own separate offense, called contempt, where nobody has to prove what you meant, only what the order said and what you did. Nobody has accused him of breaking this order, and this site does not either. But twenty-seven years later, the promises are still on the books, they still follow the man through any company, and the man they follow now holds the brand this site reports on.
To be fair, and it matters: the 1999 settlement was a deal, not a trial verdict. Buying the seminar assets was disclosed in a public filing, the opposite of hiding it. Lending money and sponsoring a golf tournament are lawful, ordinary things to do, and there is no family or ownership tie between Comer and the McNeffs. Some parts of the order did expire, the bond and the ten-year franchise ban among them. And the public record shows Comer’s company holds the Legally Mine name; it does not show who runs the brand’s day-to-day marketing, and the brand’s own website still presents itself the way it did under the family that built it. He does not own Bricks & Minifigs, and nothing here says he does.
This is a plain-language retelling. The exact quotes, the section numbers, the SEC filings, and the full twenty-three-page order are in the full update. Nothing here is a finding of law.
The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the criminal charges referenced are unadjudicated and every defendant is presumed innocent. Sources are linked so readers can check the record. · Home · Map · The law · Bodycam