PRIMARY SOURCEMark Comer’s own 2008 memoir, and his own live websiteCONFIRMEDthe man the memoir names as his first bandmate ran iMall’s sales and is a vice president of Legally Mine today
In 2008, before the golf charity and before the asset-protection brand, Mark Comer published a book about how he made his money. It is called Discoveries of an Accidental Guru, it runs three hundred pages, and it is his own first-person account of his business life. Three things about that account belong on the record. It tells the story of iMall five separate times and never once names the Federal Trade Commission, the lawsuit, or the lifetime ban. It describes the business he built there not as a website but as a machine he can point at any product. And it names, as the friend he started his first band with, a man who ran that machine’s sales for five years and is a vice president of Legally Mine today.
Why this belongs on this site. This site has already reported, from the government’s own records, that a federal court barred Mark Comer for life in 1999 from selling business opportunities, and that this spring the Legally Mine brand at the center of the rest of this reporting moved to a company he controls. What is new here is the source. Not another filing about him, but the book he wrote about himself. Read next to the record, it does three things a government filing cannot: it shows what he chose to leave out, it states in his own words what the business actually is, and it names one of the people who carried it.
iMall is the spine of the memoir’s success story, and it appears again and again: the venture he was too busy running to chase other ideas, the company his father’s speech calls the family’s making, the “Internet mall” his team built and took public, the shares whose sale, in his own words, made him “millions.” In none of those tellings is there a Federal Trade Commission, a complaint, a stipulated judgment, a ban, or a four million dollar penalty. The word iMall itself is never printed; it is always “my Internet mall” or “the Internet mall.” The single event that most shaped the company, a federal fraud case its founder signed his name to, is absent from the founder’s own book about the company.
The omission travels with a second number. In the memoir, a speech by Comer’s father puts the sale of iMall to Excite@Home at $560 million. iMall’s own filing with the Securities and Exchange Commission put the deal at roughly $425 million in stock, at a fixed exchange ratio, and the acquirer’s share price fell in the months before the deal closed. No public filing this site can reach states $560 million. And the figure is not a ghostwriter’s flourish left in a book from 2008. Comer’s own author website was still saying it years later. As recently as a July 2024 capture preserved on the Internet Archive, the site’s biography told readers he “sold one of his companies for an appraised value of $560 million” and “became a millionaire in 5 different business sectors,” with no mention of the 1999 case anywhere on the page. The same “5 different business sectors” line runs through his multilevel-marketing profiles as well. Across sixteen years, across his own book and his own live website, the story is told the same way, and the federal case is not in it.
The most useful passage in the book is not the boast about the sale. It is the chapter on his tools for financial success, where he stops describing iMall as an internet company and starts describing it as a system. The model, he writes, was to advertise a free educational seminar, deliver training at it, and then sell the audience an advanced product. And he is explicit that the product is interchangeable. Find a good one, he writes, plug it into the system, and watch the money flow out the other end. The same model, he adds, can be carried into another industry to build another business. The website was never the asset. The seminar funnel was, and he says so.
That is the through-line this site has been documenting, now stated by the man who built it. In 1999, as the ban came down, he bought iMall’s Seminar Division back out of the company for $333,000 in stock. In 2008 he wrote that the seminar is a machine you can point at any product. In 2026 the Legally Mine brand, a program sold to professionals at seminars, landed in his company. The book is the middle term between the two acts: the man who carried the machine out of a company under federal fire in 1999 explained in print in 2008 that carrying the machine, and pointing it at the next product, is the entire method.
Even before the sale, that machine had a supporting cast, and it was the same two names. Utah’s business registry and iMall’s own filings show that iMall leased its Provo office from RDR Properties, a company Comer and his co-founder Craig Pickering each owned a third of, and paid its advertising through Sierra Advertising, a firm the two of them owned, already noted in this site’s July 30 post. Two earlier companies the two men formed, Cabot, Richards & Reed in 1992 and Answer Now in 1993, were the seminar and call-center businesses that became iMall’s Seminar Division in the first place. The company that took the federal penalty rented its office and bought its advertising from its own founders.
Early in the book, Comer describes forming his first band as a teenager in Springville, Utah, with a friend he names as Dave Gibb. That is where most readers would leave the name. The public record does not.
A David Gibb from Springville was iMall’s National Sales Director from November 1994 to July 1999, the span of the company’s seminar business, according to his own LinkedIn profile, which lists the same Springville high school and describes the job as running “workshops training independent representatives, and sales managers.” That is the seminar sales operation the FTC’s case was about. The same David Gibb is today a vice president of Legally Mine, presenting its “Safeguarding Wealth” asset-protection seminar on the veterinary-conference circuit. And he is a named defendant in McNeff v. McNeff, the McNeff family’s own federal lawsuit over the business, filed in the U.S. District Court for the District of Utah.
Set the three public facts in a line. The man who ran the sales floor of the seminar company Mark Comer was banned over is an executive of the asset-protection brand Mark Comer captured, and the two of them go back, by Comer’s own account, to a garage band in Springville. This site has shown the machine moving to Comer. This is one of the people who moved with it.
The fair counterpoint. Nothing here is a finding that Mark Comer has violated the 1999 order, and this site does not claim it. A memoir is not a legal filing; there is no duty to recite a settled case in a motivational book, and leaving it out is not unlawful. The $560 million is Comer’s own stated figure; iMall’s SEC filing states roughly $425 million; this site reports the gap between the two, not a fraud. Buying assets from a company you helped run is lawful, and the 1999 repurchase was disclosed in a public filing, the opposite of hidden. On David Gibb: his iMall employment and his Legally Mine role are stated on his own public LinkedIn profile and Legally Mine’s own materials; the memoir names a “Dave Gibb” from the same town; and the McNeff v. McNeff docket lists him as a defendant. His role at iMall was not part of the FTC case, which named only Mark Comer and Craig Pickering, and nothing here accuses David Gibb of any wrongdoing; he is presumed to have acted lawfully. The identification of the memoir’s boyhood “Dave Gibb” with the iMall and Legally Mine executive rests on the shared name and Springville origin; the career facts rest on the public records, which stand on their own. A shared employee across decades is not an ownership or family tie between Mark Comer and the McNeff family, and no such tie is established or claimed here. Mark Comer does not own Bricks & Minifigs, and nothing here says he does. Every quotation from the book and the website is reproduced as written, so a reader can weigh it, and every person named is presumed to have acted lawfully.
Sources. Discoveries of an Accidental Guru: 100 Truths of Business and Personal Success, by Mark Comer (707 Publishing, 2008), a digitized copy of which is catalogued at the Internet Archive under ISBN 978-0-9820546-0-4, quoted for the account of iMall, the chapter on financial tools, and the naming of Dave Gibb. Comer’s author website, accidentalgurubook.com, as captured by the Internet Archive on July 18, 2024, for “an appraised value of $560 million” and “millionaire in 5 different business sectors.” iMall, Inc.’s SEC filings and the executed FTC judgment, quoted and posted in full in the July 30 post, for the roughly $425 million stock deal, the Seminar Division’s share of revenue, and the $333,000 repurchase. RDR Properties, Sierra Advertising, Cabot, Richards & Reed, and Answer Now, from the Utah Division of Corporations business registry and iMall’s Form 10-KSB for 1998. David Gibb’s iMall and Legally Mine roles and Springville schooling, from his own LinkedIn profile and Legally Mine’s public seminar materials; his defendant status from the docket in McNeff v. McNeff, No. 2:21-cv-00048 (D. Utah). The 2026 brand transfer, the charity, and the lend-sponsor-capture sequence in The lenders, The machine, and the July 21 post; the legal analysis, left open, on The law.
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