The basis for the CPA Hub were the innovations, which helped build a productive interaction with the partners. We deployed the resources to stimulate their growth, helping with localization and targeting. As a results, they are able to create more effective advertising strategies and easily scalable ad campaigns leveraging all available communication channels.
Defendants’ program consists of a series of tiered membership levels, each with a membership fee higher than the last. Defendants pay a consumer only when the consumer recruits new consumers to join the program, through commissions on the new consumers’ membership fees. Although Defendants’ program ostensibly provides business coaching that will help members build a successful business, the goal of that “coaching” is to persuade the member to purchase a higher membership tier. – Source FTC