“Consumers will earn between $500 and $12,500 per sale,” read the website for Digital Income System, Inc. “Every time one of our professionals closes a sale on your behalf, we will send you a huge commission check right to your doorstep.” According to the Federal Trade Commission, those promises were false, part of a membership-sales scheme that charged consumers between $1,000 and $25,000 for access to a program that rarely delivered anything close to the advertised income.DOCUMENTED
The case was announced in November 2020 as part of Operation Income Illusion, a coordinated federal and state crackdown on work-from-home and employment scams that emerged during a period of widespread job insecurity.DOCUMENTED Digital Income System, Inc. and five individual defendants, including Derek and William Foley, ultimately agreed to settlements permanently prohibiting them from any future business or investment opportunity marketing.DOCUMENTED
- The FTC's complaint against Digital Income System, Inc. was first announced in November 2020 as part of Operation Income Illusion.
- Named individual defendants included Derek and William Foley and a defendant identified as Hedrick.
- Consumers were charged between $1,000 and $25,000 for memberships in the program.
- The website claimed consumers would earn commissions between $500 and $12,500 per sale.
- The settlement imposes a nearly $3.6 million judgment against Digital Income System and the Foleys, and a $217,426 judgment against Hedrick.
- A default judgment was later entered against two additional promoters, Christopher Brandon Frye and Kaitlyn Scott, carrying judgments of $600,000 and $171,500 respectively.
What the complaint alleges
According to the FTC, Digital Income System and its individual defendants falsely told consumers they could earn substantial commissions from the sale of memberships in the company's own programs, giving purchasers access to their own referral websites and marketing materials designed to recruit further paying members.DOCUMENTED That structure — members earning money primarily by recruiting new members, rather than by selling any independent product or service to outside customers — is a recurring feature the FTC has flagged across many business-opportunity cases, since it means the program's compensation depends on a continuously expanding base of new paying recruits rather than genuine demand for anything of independent value.REVIEWED
What Operation Income Illusion targeted
Operation Income Illusion was a coordinated sweep involving multiple federal and state law enforcement partners targeting work-from-home and employment scams broadly, timed to a period when consumers facing job losses and economic uncertainty were especially receptive to promises of easy supplemental or replacement income.REVIEWED Digital Income System was one of several operations named in that sweep, each sharing a similar structural feature: a membership or program fee charged upfront, paired with inflated or entirely fabricated claims about the income a purchaser could expect to earn by reselling access to the same program to others.
How the additional defendants were added
The case's expansion to include Christopher Brandon Frye and Kaitlyn Scott, both of whom faced default judgments after not appearing to contest the charges, reflects how these investigations often widen over time as the FTC identifies additional individuals who actively promoted a scheme's earnings claims to prospective members, distinct from the core operators who built and ran the underlying program.REVIEWED A default judgment, entered when a named defendant fails to respond to a complaint, still carries the same legal force as a negotiated settlement, including the specific monetary judgments imposed against Frye and Scott individually.
Terms of the settlement
The settlement permanently prohibits Digital Income System, the Foleys, and Hedrick from engaging in any future business or investment opportunity as part of a settlement with the Commission.DOCUMENTED The judgments — nearly $3.6 million against Digital Income System and the Foleys, and $217,426 against Hedrick — are partially suspended due to the defendants' documented inability to pay the full amounts, contingent on all four defendants turning over specified assets; if any defendant is later found to have misrepresented their finances, the full judgment becomes immediately due.DOCUMENTED
The website promised a “huge commission check right to your doorstep” for every sale closed on a member's behalf — a promise the FTC says rarely, if ever, materialized.
Why the case matters
For consumers evaluating any work-from-home opportunity promising commissions for recruiting or reselling memberships, the Digital Income System case illustrates a warning sign worth checking before paying an enrollment fee: a program whose primary earning mechanism is recruiting other paying members, rather than selling a product or service to an outside customer with no stake in the program itself, carries the same structural risk regulators have identified across dozens of similar schemes swept up in Operation Income Illusion.
How to distinguish a legitimate opportunity from a recruitment scheme
A useful test many consumer advocates recommend before joining any income-generating program is asking whether the company's compensation would still make sense if recruiting new members were entirely prohibited — in other words, whether the underlying product or service has independent value to someone with no interest in reselling it themselves.REVIEWED Programs like the one described in the FTC's complaint typically fail that test immediately, since the core commission structure depends on an ever-expanding pool of new paying recruits rather than demand from genuine end customers who have no stake in the referral chain.
Why economic uncertainty makes these pitches more effective
Operation Income Illusion was announced during a period of significant job loss and economic disruption, when consumers actively searching for replacement or supplemental income were an unusually large and receptive population for exactly this kind of pitch.REVIEWED Regulators have observed that fraud targeting employment and income opportunities tends to spike during periods of broad economic stress, since the underlying appeal — a straightforward path to earning money from home — becomes more urgent and less subject to the ordinary skepticism a consumer might apply during more stable economic conditions. That pattern is part of why sweeps like Operation Income Illusion tend to target dozens of similarly structured schemes at once, rather than pursuing operators one at a time as individual complaints accumulate.
Consumers who suspect they may have encountered a similarly structured recruitment scheme can report it directly to the FTC, which continues to track patterns across complaints to identify new operations before they reach the scale this one did.
Sources behind this report
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