Consumer Protection

The FTC Has Shut Down Bogus Military Recruiting Websites

Most Americans have heard some version of the old adage “If it looks like a duck, walks like a duck, and quacks like a duck, it’s probably a duck.”  Thirty years ago, that  old saying made sense, but in the second decade of the 21st century, it no longer holds true.  Technology and the internet have changed everything about how we process information.  We can no longer believe what we see and what we read without deeper investigation.  This recent scam illustrates that point.  It is yet another example of sophisticated technology being used to dupe the public.  In this case, the victims are young adults considering military service who relied on bogus, military recruiting websites to their detriment.

The FTC Shut Down 14 Websites Designed to Scam Potential Military Recruits.

On September 6, 2018, the Federal Trade Commission seized 9 of 14 phony websites that were set-up to mimic genuine military recruitment sites.  The FTC filed a lawsuit in Federal Court alleging that two companies made close to 11 Million Dollars by gathering personal information from potential recruits and selling their information to for-profit schools and colleges.  The schools involved paid between $15 and $40 for each recruit’s information.

The earliest of the fake websites cropped up in 2010, with new ones periodically added to the mix.  These websites look amazingly real.  One of them, has a banner at the top, reading “Presented by the Army CCM Information Network.”  It contains military photos, log-in information, and links you can click.  It would take a truly sophisticated internet user to spot the sites as fakes.  The following is a list of the bogus websites:


These websites had more than 100,000 visitors per month.  Online ads for the websites used familiar phrases like “The Army wants you.”

This is how it worked.  The website required recruits to enter their personal information – name, address, phone numbers, emails, education, etc. The website promised complete confidentiality, that all information provided would remain private and protected. That was a complete lie.  The defendants were selling the information.

Once the young man or woman entered the information, a website employee contacted the potential recruit.  Millions of follow-up phone calls were made.  In many cases, the telemarketer pretended to be military personnel.  The telemarketers then talked about education opportunities that could benefit the recruit and help him or her toward a military career.  They recommended their clients, for-profit schools working in partnership with the scammers.  They even represented that the U.S. Military partnered with these schools and recommended them for aspiring recruits.

The schools would then make follow-up calls, extolling the virtues of their institution and sometimes offering “deals” on tuition.  Even if the recruit did not get sucked into an overpriced education from a questionable school, that individual’s private information was out there, probably being sold to some other company.

This Form of Lead Generation is Illegal and Subject to Prosecution.

The concept of lead generation has been around for many years.  It’s basically a tool to find consumers who will respond to a company’s sales pitch and buy its product.  Door to door salesmen would often ask if their customer knew someone else who might need a vacuum cleaner.  Cable providers, credit card companies and other businesses may offer customers a discount for providing names of other people who might be interested in the product or service. The internet allows lead generation at unprecedented speed and volume.  Lead aggregators are companies that act as a middle man between the lead generator and the customer.  They offer to sell the leads to willing customers at a fixed rate per lead, and they take a cut of the action for their trouble.

Using fake websites, violating the “do not call” registry, and selling illegally obtained information are all federal crimes.  It is those crimes that led to the FTC filing a criminal complaint on September 6, 2018. 

The FTC Action.

The FTC complaint alleged criminal conduct by eight defendants, four corporations and four individuals.  The defendants are:

  • Sunkey Publishing, Inc;
  • Sun Key Publishing, LLC;
  • com, LLC;
  • Wheredata, LLC;
  • Christopher Upp, individually and as an officer of Sunkey Publishing, Sun Key Publishing and Wheredata;
  • Mark Van Dyke, individually and as an officer of both Sunkey and Sun Key;
  • Lon Brolliar, individually and as an officer of;
  • Andrew Dorman, individually, and as an officer of

The FTC charged the 8 defendants with violating the FTC Act, the Telemarking Sales Rule, and the Do Not Call Provisions of the Telemarketing Sales Rule.  The Alabama based corporations have agreed to relinquish the phony websites and stop their illegal practices.  A Federal judge assessed civil penalties -- $11.1 Million against Sunkey and $1 Million against Fanmail.  The defendants claimed they were out of money, so the monetary payments have been suspended.  Of course, if the government finds the poverty claims are false, the penalties will be reinstated. Finally, the defendants must contact all the schools who purchased the information and tell them to stop using the information and to delete the data.

Based on my research, no one is going to jail for these crimes, and I cannot help but wonder if the individual defendants will simply form new corporations and set up a new scam.  It’s also interesting to note that the names of all the for-profit schools involved in the scam have been redacted from the public record and are not available.  There is one exception.  The identity of one school was disclosed in the lawsuit – Grantham University, an online, for-profit school based in Kansas.

Federal Trade Commissioners, Rogit Chopra and Rebecca Kelly, responded to news of the scam with a written statement;  “When schools and marketers collude to steer young people away from military service, it enriches them but costs all of us. . . The fake military recruiting scheme . . .harmed young people looking to serve their country, as well as the public more broadly . . . Not only was the alleged conduct unlawful, it was also un-American.

How to Avoid Bogus Websites.

In recent years, this question has been asked repeatedly.  Unfortunately, there is no easy or foolproof answer.  If you are looking for a government website, always look for “.gov” in the URL.  Any time you are thinking of filling out an online application, check for complaints or reviews of the website before entering any information.  If you believe you have been contacted by a government imposter, contact the FTC at  You may also want to call the Consumer Protection Division of the Arizona Attorney General’s Office.  In Phoenix, call (602) 542-5763; in Tucson, call (520) 628-6648; outside the two metropolitan areas, you can make a toll-free call to (800) 352-8431.

Signing up for military service is an honorable and commendable thing to do.  Stealing a potential recruit’s personal information is a despicable act.  If you want to enlist in the military, your best bet is to do it the old-fashioned way.  Visit your local military recruiter.  With a personal visit, you will be better able to ask questions and evaluate the information you receive.


Complaint filed by the FTC:

FTC Complaint Website:

Arizona Attorney General:



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