Filed Complaint and Application For Injunctive Relief

MICHAEL k.
JEANES
Clerk of tf~e Superior Caurt
Br Celina Lo~e~, Deputy
Date 12/?2I2015 Time 14:46.5h
KELLY /WARNERS PLLC D~scriati~n R~cnmt
8283 N. Hayden Road, Suite 229
Scottsdale, Arizona 85258 CIVIL, ~EI~ CO~F'i.AIi~T 31'a.t10
7
Daniel R. Warner, Esq.(AZ Bar # 02b503)
3
Email: dan(cDkellywarnerlaw.com ror~~ ar~ou~T ~i~~.00
Aaron M. Kelly, Esq.(AZ Bar #025443} Recei~~# 24~58~`1
Email: aaron c kell warnerlaw,cam
4 Tel: 480-33 i -9397
Fax:1,866-961-49$4
5 Atlarn~ysfnr Pluinliffs
6
~N SUPEItIOIt CO(1I2T OF THE STATE OF ARIZONA
7
IN AND FOR THE COUNTY OF MARICOPA
8
No.~t~~~~ ~ ~0~~~
RUSSELL RUFFINO, an individual; CLIENTS
10 ON DEMAND,LLC,a California limited
liability company, COMPLAINT AND
I1
APPLICATION FOR
}~ Plaintiffs, INJUNCTIVE RELIEF
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1~ ~ ~ M
a•~~~. 13
a~~_ (Unfair Competition under the
R{ M
~ ~ O ,-.
14 Lanham Act, Defamation, False
~ ° Na
a ~•~~ MEL.AYNA M. LOK4SKY and JOHN DOE Light Invasion ofPrivacy,
e ~¢~; 15
a~~~ LOKOSKY,husband and wife; JOHN DOES I- Tartious Interference with Current
~ C
16 X; JANE DOES I-X; ABC PARTNERSHIPS I- and Prospective Business
~' 2~ a
a~ ~" X; DEF LIMITED LIABILITY COMPANIES Relationships, Aiding and
17 [-X; and XYZ CORPORATIONS I-X, Abetting, and Conspiracy)
"~~+N~~
18 Defernc~~nts.
l9
20
For their claims far relief against Defendants, Plaintiffs RUSSELL RUFFTN4
~~
("Plaintiff') and CLIENTS ON DEMAND, LLC ("COD") (coliective(y "Plaintiffs"),
22
23 allege as follows:
24 PARTIES,.IURISDICTION AND VENUE
25
]. Plaintiff is a natural person, a citizen of the United States, and a resident of
2d
27 the State of California.
28
2. Alaintiff is a manager of CQD.
1
2 3. COD is a limited liability company duly created, existing and operating under
3
the laws and ordinances of the State of California with its principal place of business in
4
California.
5
6 4. Defendants Melayna M. Lokosky ("Lokosky" or "Defendant"} and John Doe
7
I~4kosky, husband and wife, reside in the State of Arizona, Maricopa County.
8~
5. Upon information and belief, all acts of Lokosky as alleged herein were
9
10 performed for the benefit of her marital community with her spouse and/or vice versa.
6. Upon information and belief, all Defendants are residents of Arizona and are
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therefore subject to general personal jurisdiction of the courts located in the State of
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~~~ 13
ate„_
a~ ~M 14 Arizona.
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d ~'~ 15 7. Defendants' actions, upon which the allegations in this Complaint are based,
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were performed in and while residing in Maricopa County, Arizona.
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l8' 8. JOHN and JANE DOES 1-10 are fictitious persons who may have an interest
19 herein. ABC PARTNERSHIPS I -10; XYZ CORPORATIONS 1-10; and DEF

20
LIMITED LIABILITY CQMPANIES 1-ld are fictitious entities who may have an
2l
22 interest herein. At such time as the true name of such fictitious persons and/or entities
23 become known to Plaintiffs, Plaintiffs may amend their pleadings to reflect same.
24
9. The amount in controversy herein exceeds the minimum amount required for
25
26
jurisdiction in this Caurt.
?~ 10. Upon information and belief,jurisdiction and venue are proper in this Court.
2g
2
FACTS
1
2 11. All of the allegations contained within the paragraphs above and below are
3
hereby incorporated by reference as if fully set out herein.
4
i2. COD provides marketing coach services to local and online businesses in the
5
6 United States, Canada, Australia, and United Kingdom.
7
13. COD was formed to provide top-level marketing coaching to clients ana has
8
becorn~ a leader in its field.
9
]0 14. Plaintiffs, in addition to their marketing coaching services, provide free advice
11 to thousands oFpeople an a daily basis via soda! media anc! their bldg.
12
15. Defendant owns and/or has an ownership interest in Killing~MyCareer.com {the
N
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a~~~
a•~~~ 13
~~~~ by COD.
a -o c M l4 "Website") and mmpiher.com, which offer services similar to those provided
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16. Defendant offers services that compete with the services offered by Plaintiffs.
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17. Defendant advertises her competing services through the Website and various
17
~ ~~~
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18 social media platforms, including Twtitter.com and FaceBaok.com.
19 18. Defendant has intimate knowledge of search engine optimization ("SEO")

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techniques that increase the visibility of websites on the Internet.
21
22 19. In addition to being on a crusade to destroy Plaintiffs' business for her own
23 personal financial gain, Defendant is clearly obsessed with Plaintiff.

24
20. Over the course of approximately seven months, Defendant has committed a
25
section of her Website to defaming Plaintiffs and has personally made approximately (1)
26
27
2$
3
l 30 posts/comments on the ~Vebsite about Plaintitts~; (2} ~U '1'witt~r posts about
2 ~~ Plaintiffs2; {3} four FaceBoak posts about Plaintiffs3; and (4) one past on
3
BusinessInsider.coit~4 (callcctively the "hosts"}.
4
21. Even though Defendant admits to have never spoken with Plaintiff or taken
S
6 (one of his classes,5 she repeatedly calls Plaintiff a fraud and accuses Plaintiffs of
7
engaging in fraudulent business practices in her Posts.
8
22. Defendant holds herself out to be some type of expert at spotting fraud and
9
10 claims to be "someone who writes about fraud every day."6
it 23. However, Defendant makes false, defamatory, and misleading factual
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r- statements and implications to support her primary .message that Plaintiffs are
a~~~~. l3
a~„~
W~ p 14 defrauding clients, and that. these clients should utilize her services because her business
z~,Na
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d y Q ~~.. 15 practices are ethical {notwithstanding her marketing via character assassin techniques).
a-~~~
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aZ o v 24. A portion of Defendant's Website is expressly and overtly dedicated to
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18 soliciting clients to employ Defendant as a consultant.
19
20
2l ~ These Posts shall hereinafter be referred to as the "Website Posts'' and have been attached as
Exhibit A hereto.
22 2 These Posts shall hereinafter be referred to as the "Twitter Posts" and have been attached as
Exhibit B hereto.
23
3 'these Posts shall hereinafter be referred to as the "F$ Posts" and have been attached as
24 Exhibit C hereto.
4~These Posts shalt hereinafter b~ referred to as the "BI Posy' and have been attached as Exhibit
25 D hereto
5 See Website Posts, Exhibit A hereto (Defendant states that, "I've not taken his program ....[
26
da nor know Russ, and am not qualified to diagnosis him , .. ,", and when asked if' Defendant
27 ever took Plaintiffs' course, Defendant admitted that she has '`never spoken to E~uss Ruftino, or
spoken to one of his minions ....").
28 6 See id.
~ See Exhibit E hereto (llttp://www.killin~mycareer.com/mmpiher-method-2/).
4
1 ~S. Adtli~ic~t~ally, while clefa►~7ing, Plaintiffs, Defendant mal es it point to promote
how she never charges money upfront ar~d that she dogs nat "take a dime until [shed
~~
makes] them money ...."g
4
26. Based on the beginning of the Website Pasts, Defendant appears to take issue
SI
6 I with the fact that Plaintiff is successful enough to be able to pay to advertise extensively
71
on Twitter, as well as afford the finer things in life.
8~1
27. Prior to Defendant's crusade to destroy Plaintiffs, Plaintiffs had a pristine
9~
10 ~ reputation, with no complaints posted online or lodged with the Better Business Bureau,
11 and Plaintiffs have been in business since 2011, have been offering these specific
12
marketing coach services since 2013 and have generated approximately $3.5 million in
N
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]4 saps since 2014.
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d a¢a' ~5 28. However, by making the Posts, Defendant manages to turn her jealousy of
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O °' Plaintiffs' success into her own marketing ploy wherein she portrays Plaintirf as some
17
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18 stereotypical "drifter" wha uses predatory tactics to defraud innocent consumers.
19 29. Defendant fails to acknowledge and/or attempts to obscure the fact that
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prospective clients are supposed to be established marketing professionals themselves,
~j
~~ are generally told upfront that they should not participate in the program if they do not
23 have an established business providing consulting services, and are required to sign a
?4
contract that specifically states that there are no guarantees and that they are responsible
25
for their own results.
26
27
28
g Sc~e Website Posts, Exhibit A hereto.
5
30. Defendant also fails to acknowledge and/or obscures the fact that Plaintiffs have a
1
2 substantial number of testimonials that explain how and why Plaintiffs have been so
3
successful and have enjoyed such a pristine reputation until Defendant began her smear
4
campaign.
5
6 31. Instead, Defendant falsely portrays Plaintiffs as having an expensive amount of
7
complaints.
8
32. To date, 75 comments pertaining to Defendant's allegations about Plaintiffs have
9
10 been made on the VJebsite.
11 33. Of those 75 comments, 25 were made by Defendant and only seven comments
12
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were purportedly made by Plaintiffs' former clients.
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rx vim" `° `"' l4 34. However, it is likely that only a fraction of these seven comments were
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,~za~ 35. Qn July 10, 2015, Defendant admitted on her Website that several of the
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17
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1$ comments were coming from the same IP address but were claiming to be made by
19 different people10; yet, Defendant still maliciously portrayed Plaintiffs as having an

2d
extensive amount of complaints on her Website.
~}
22
9 See icy. ("Thank you also for updating . , .accomplices turned victims ....";"he must operate
23
under his real name for a certain number of years as a means of preventing future victims"; "1'd
24 like to thank everyone who has come forward on this thread ... to expose the truth Russell
Ruffino . , , .";'`many clearly weren't and left with no recourse"; "it's very telling you say he's
25 concerned about his reputation (image) but from the reviews not concerned about the substance
of his company's work"; and "If yQu read the comments several people purchased the
26
~rogram based on the logos thinking he was actually an legitimate statians ....").
?~ ° See id. (stating that "comments coming from the same IP addresses with name change is also
unethical (Kevin 12:04pm &Alex 12:14pm today same IP) and just noted today- that
28 ',yesterday's comments from (Anonymous, Kevin and Jason all the same !P address but different
from today's comments)").
D
36. Although Defendant claims that "wane of the goals of this site is to expose
l
21 unethical people running unethical companies,"" it is clear that this is not the case; the
Website was designed to further Defendant's character assignation of the competition

a
method of marketing.
5
6 37. Defendant even acknowledges that her eFforts are harming Plaintiffs, and that
7
Plaintiffs are attempting to mitigate some of the harm by engaging in certain SEU
8 ;
techniques.1z
9
]0 38. By posting and then reposting the false and misleading statements about
11 Plaintiffs on the Internet in various places, Defendant is unlawfully profiting fran her
12
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a ~~°~
~. conduct by obtaining free advertising at Plaintiffs' expense, as well as diverting clients
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.-.
14 away from Plaintiffs.

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e a¢d: 15 39. Defendant repeatedly accuses Plaintiffs of engaging in deceptive advertising
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a~~ given that Plaintiffs pay for some their advertising (rather than getting it for i'ree by
17
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18 character assassinating others).
19 40.Throughout the various Posts, Defendant wrongfully calls Plaintiff a fraud,

20
unethical, and a liar.
21
4l , In addition to the foregoing, on or around June of 2015, Defendants, by and
22
23 through Lokosky, posted false, damaging, misleading and defamatory statements about
24
Plaintiffs on her Website, at http://~vww.killin~mycareer.co~n/the-sociopathic-business-
25
26
27
~ ~ See id.
28 'Z aS'~r~ id. ("Also, n4k~ khe deceptive Killing in the title to try and combat his truthful negative
SEO from this site, Killing My Carer,").
7
cnodelltwitter-ad-kingsrussell-russ-ruftino-the-sociopathic-business-model/, which
1
2 include the foliawing:
3
A. "Russell Ruffinn buys an ad in Inc Magazine (example of native
4
advertising).... At first glance it looks like Russ Ruffino was published in
5
6 both INC &Business Insider but its actually PAID native advertising."
7 i. The above contains literally false statements because no
8
compensation was provided or paid in order to have the article
9
10 published in Business Insider.
ll ii. The above also contains false and misleading statements because,
12
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a ~, ° ~. even if compensation was paid in order to have the article published
a~~~~ 13
a~,,,,~
14 in Inc. magazine, the statements imply that paying for advertising
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x°No
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e va~ 15 determines if the article being published has any merit, and that
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„ ~ such advertising is automatically deceptively fraudulent. However,
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18 because an editor's job is at risk, any article that is published,
19 whether or not paid for, must hold a certain level of integrity, and
20
respectable publishers would not publish certain articles no matter
~~
how much one was willing to pay. Moreover, companies have been
22
23 paying far subtle and subliminal advertising since before movie
24
stars were paid to smoke certain brands of cigarettes while in
25
movies. Defendant's characterization of Plaintiffs conduct as being
26
27 fraudulent is false, misleading leading and unlawful. Plaintiff is
28
8
simply utilizing a form of advertising, although somewhat evolved,
1
2 that has been deeply roaCed our society for decades. Defendant's
3
purported purpose for attacking Plaintiff is nothing more than a
4
cloak being used in an attempt to conceal Defendant's true purpose
5
6 and intent.
7
B. " Às seen in...' well that looks impressive but we've already learned
S
before that looks can be deceiving (and sometimes need a shower).. , ."
9
10 "Plaintiff engaged in the "false appropriation of major network logos used
lI to deceive clients ...." "Any guess as to how Russell {Russ} Ruffino fairs
12
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a ~,~~ with CNN, NBC, Fox and The Wall Street .tournai? Yep-goose egg.
a •~ 13
a~~~
14 Except fox this fram the Freaking Genius which state that Ruffino has been
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e vQd; 15 featured on Huffington Post, CBS and Fox despite being able to find any
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„a evidence to support such claims."
,~°°~'(— 17
i. The above contains literally false statements because Flaintif~ did
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1~
19 not appropriate the logos and legitimately paid to advertise through
20
major networks.i3 Additionally, if Defendant did perform various
21
22
13 See, e.g., CNN: http://ireport.cnn.com/docs/DOC-1038241, Fox:
~3
http://www,fox 14tv.com/story/29755131/marketingguru-russ-ruffinoshares-keL-principles-for-
24 achieving-success, NBC: http:l/www.nbcri~htnow,com/story/29755131/marketing;-guru_
russruffino-shares-key-principles-for-achieving,-success, Huftington Post:
25 http://www.huffin~tonpost.com/brianhorn/be-a-master-of-theweb-un b 5584955,html, CBS:
http:Uwww.cbs8.com/story/29755131/mar{ceting-guru-runs-ruffino-shareske~principles-for-
26 MarketWatch (was owned by WS.I):
achievin~uccess,
27 http://www.marketwatch.com/stor/marketing-authority-expert-russ-ruffinoexplains-
how"ieff-bezos-can-save-the-washin 7t~_post-bL- i~ vin massive-value-tocustamers-
28 2013-Q9-19, and Inc.com: http://www,inc.com/empact-/the-marketing-myth-that-is-kiliin~-
thisgeneration-of-businesses.html
"Google searches" as she claimed, she would have discovered the
HuffingtonPost publication at the very least. Such conduct
3
demonstrates that Defendant purposefully avoided learning and/or
4
discussing truthful facts.
S
6 C. "I did not save that riveting exchange {and lack the skills to find it my
7
Twitter history) with Russell (Russ) Ruffino but remember he made some
8
claim of bringing in $250,000 a month with no actual data to supporC that
9
10 claim. When I asked for him to substantiate the claim he was unable to
(shocker}."
12
i. The above contains literally false statements because PlainEiff was
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a~,~ ~~ able to and did provide Defendant with proof of income.
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D. "Right out of the gate that's not doing a lo# for Russell (Russ) Ru('fino's
3 ~~~
°'
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p. credibility which I suspected was lacking when 1 engaged with him several
~ o
17
►~'N~~
18 months ago on Twitter." "And right out the grifter's guide: 'l~ry and make
19 people jealous of your life sa they'll think you're successful. Also see
20
posing with Porsche."
21
i. The above contains false and misleading statements because
22
23 Defendant portrays Plaintiff as some stereotypical "grifter" who
?4
falsely publicizes his success for the purposes of luring and
25
defrauding innocent consumers. Plaintiff is indeed successful and
26 ~
27 does not flaunt a fraction of what he could flaunt, which is quite the
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10
~~ opposite of Defendant's "al! flash and no cash" portrayal.
2 Additionally, the fact that Plaintiff can afford to pay for all of this
~
3 advertising that Defendant attempts to criticize
expensive
4
demonstrates that Plaintiffs have attained a certain level of financial
S
b means.
7, ii. The above also contains false and misleading statements because
8
Defendant implies that sYte is aware of a litany of other items that
9~
10 demonstrate Alaintiff is a fraud and/or fraudulently induces clients.
11 E. "Great 1 could make up a spreadsheet too, I can also hand write my name j
~. 12
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a vac n on to The New Yark Times Best-Seller list, tell people I'm on it but it
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P
13
ate,;~
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doesn't make it truthful or ethical."
O ~"
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d~Q~ 15 i. The above contains literally false statements, as well as false and
~ v
~x~~ 16
ago°'~. misleading statements, because Defendant implies that Plaintiff
l7
~ ~~~
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artificially created a spreadsheet. E-Iowever, Defendant was
l8
19 provided with a screenshot from Plaintiffs' third party payment
24
processor (which is akin to a bank statement); it was not a simple
?~
spreadsheet that someone could just manually create. Moreover, all
22
23 figures can be supported by bank statements and documentation.
24
F. "But it's nice he phoned a Friend to white knight for him. , ..Hunter Hart
25
white knights for the proven unethical Russell(Russ) Ruftino"
26
?~ i. The above contains literally false statements, as well as false and
28
misleading statements, because Defendant implies that Plaintiff
1
2 arranged for a third party to come to Plaintiff's defense based on
3
how PEaintiff criticized by a thin! party for republishing Posts about
4
Plaintiff for purposes creating "link bait" her Website. Plaintiff did
5
6 not arrange for this individual to "white knight" for him.
7
G. "A true and ethical consultant would never charge ali the money up front."
8
i. The above contains literally false statements, as well as false and
9
10 misleading statements, because the general method by which a
it consultant charges far services does not determine whether they are
12
unethical or engaged in fraud. After Defendant was criticized for
N
1~ N y~j O~
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a~,~
a~CM 14 "bashing someone else's collection practice because it makes [her]
w o o,..
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a~•Coo
~- i5 look better," Defendant admitted that "[h]ow someone cgllects their
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ad ; T~ c
~~~~
16
a money is less relevant if customers are happy with service." And
azov
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~ N
l~ instead of providing any logical rebuttal, Defendant simply resorted
19 to falsely claiming that "many" of Plaintiffs clients "clearly

20
weren't" happy. I-Iowever, as discussed, it is likely that Defendant
21 ',
only knows of less than a handful of unhappy clients, if any at all.
22
23 H. "Unethical companies will often change names in order to distance from
?4
past unethical and or illegal behavior, Russell Ruf~no also operates under
25
The Art of High Ticket Selling and Russ Ruffino's Platinum
26
27 MasterMind."
28
l2
i. The above contains literally liaise statements, as well as false and
1
2 misleading statements, because it implies that Plaintiff uses
3
different names to confuse pepple and avoid having his alleged
4
nefarious practices discovered. Plaintiff has never been in trouble
S
6 with any governmental agency. Additionally, Plaintiff has never
7 owned or operated any companies with a history of consumer

8
complaints or regulatory issues. Moreover, Flaintiff has two
9
10 different Facebook groups that he maintains, one for clients and
11 another where he provides free advice for non-clients. Aiaintiff is

a 12
V N
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a ~ ~, ~. not trying to distance himself from past illegal or unethical '
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13
~" ~ G M 14 behavior, and it is common practice to have different ~acebook
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d yQ~. ~5 groups with different names as each serves a different purpose.
~~~~ 16
a~~~ I. "After Forced Accountability: Russell (Russ} Ruffino of Clients on
~w~v~~" 17
Demand changed the landing page of his website to his blog page (which
N
18
]9 no longer shows the fraudulent use of logos) but will remain here on this
20
site as tool to help potential clients make better informed decisions before
21
investing."
22
23 i. The above contains literally false statements, as well as false and
24
misleading statements, because it fails to acknowledge that Plaintiff
25
only had the TV logos on his website for less than two months
26
27 (April ls'Co May 27`x'); and (2) Plaintiff simply removed the logos
28
23
to avoid further attacks by Defendant even though Plaintiff
1
2 legitimately paid to advertise through major networks and could
3
have rightfully continued to use TV logos, along with including
4
hyperlinks to the articles. Defendant did not force Plaintiff to do
5
6 anything.
7 ii. The above also contains literally false statements because
8
Defendant is not simply retaining the screen shot of Plaintiff's old
9
10 landing page "to help potential clients make better informed
11 decisions before investing." Defendant retains the image on her

12
V N r Website so she can continue to harm Plaintiffs' business and divert
a a~ M 13
~ oo
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a ro ~' `'' l4 potential clients to her. This is evidenced by the fact that Defendant
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a ~,~ v
1 ~ ~
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l6
mention the limited timeframe in which Plaintiff' utilized the [ogo.
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1$ Additionally, one would think that Defendant would commend
19 Plaintiff for his removal of the logos —not continue to use the false
20
and misleading portrayal as fodder to divert business away from
21
Plaintiff. This is yet another instance where Defendant's
22
23 maliciousness is evident.
24
J. "Unethical companies will often change names in order to distance from
25
past unethical and or illegal behavior...." "This appears to be a growing
26
27 trend: Russ Turner pitched his services of helping others succeed with his
28
14
free book on his site RoadMap 2 Success on 7.13. 2015"
1
2 i. The above contains false and misleading statements because it
3
implies that Plaintiff and Russ Turner is the same person and/or that
4
Plaintiff is uses the name "Russ Turner'' to hide is identity in order
5
6 avoid having his nefarious practices discovered and prasccuted.
7
K. "Move along minion of Russell Ruffino's." "The fishy posts I might add
8
are also followed with an onslaught seam attempts in the last few days."
9
10 i. The above contains literally false statements, as well as false and
misleading statements, because Defendant falsely implies that

l2
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a v~~.
~ Plaintiff arranges for a third parties to post comments on the
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13
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34 Website in an attempt defend Plaintiff. Plaintiff has never arranged
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ad ~°~,.No
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l5 for any individual to "white knight" for him.
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ago°'
16
42. All of the above false and misleading statements will be hereinafter
17
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00
referred to collectively as the "False Statements."
1~
19 43. For the purposes of increasing the prominence of the Website Posts on the
20
Internet, promoting her business over Plaintiffs, and leading viewers to the Website,
2l
22 Defendant republished many of the False Statements in the Twitter Posts, including, but
23 not limited to, the following:

24 18, 2015, at
A. On November
2S
hops://twitter.com/MelaynaLakosky/status/6669032332$6139904,
26
27 Defendant "NOT an article but PAtD Native Advertising in ~Ine
~g
l5
#RussRuffina"...
1
2 B. 4n November 1 S, 2015, at
3
https•//twitter corn/MelaynaLokosk~/status/666902405510881280,
4
Defendant posted "Watch out for fraudulent native advertising designed to
5
6 look like an article in Inc for #RussellRuffino,,."
7 November l8, 2015, at

C. 4n
8
https~//twitter comlMelavnaLokosky/status/6670$0799854858240,
9
10 Defendant posted "When #native #advertising becomes #marketing
11 #fraud: #RussRuffino & @Inc...."
12
V N c~ D. On November 29, 2015, at
a~~°~ 13
a ~ ~ `~,
14 hops•//t~~~itter com/Mela~naLokasky/status/671 i 13387254915073,
W a
a ~' •~ o
po
e =Q:~ 15 Defendant posted on Twitter "#ItsPurelyPrapaganda As seen on tv or a
a ~v~
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aZ ~ a maga2ine #FakeAds..,"
"~ U ~
I,
~~/ ~ ~ ~ 1~
W N
E, pn November 30, 2015, at
l8
19 hops•//twitter com/MelaynaLokasky/status/671431947390947328,
20
Defendant posted "I wish a Inc would ban unethical &misleading
21
#NativeAdvertising..."
22
23 F. 4n December 13, 2015, at
24
htt s://twitter.com/Mela naLokask /status/67b 128]3793b 158720,
25
Defendant posted "Fraud Alert: Inc &Business Insider's AD for Russ
26
27 Ruffino looks like an article but is actually a paid Ad."
28
~~
G. On December 13, 2015, at
1
2 hops://ttivitter.com/MelaynaLokosky/status/676124373208530944,
3
Defendant posted "Don't fall for Russ Ruffino's latest marketing #fraud
4
via RAID @businessinsider @Inc ADS"
5
6 44. Defendant has two different Facebook pages, one personal:
7
https://w~~vw.facebook.eom/melayna.lakosky, and one that Defendant uses to promote
8
her business and Website; https://www.faceboak.cam/Killing-My-Career-
9
10 62$231533897687/
11 45. Defendant clearly states that the purpose of her business page is to
N
12
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a~~~
n
promote her "Consulting and Business Services."14
M
.~ ~ ~ 13 j
~ C/~ 00
a~~M 14 46. For the purposes of increasing the prominence of the Website Posts on the
~y ~o
,~~
° ~
a4
e~¢ 15 ' Internet, promoting her business over Plaintiffs, and leading viewers to the Website,
a'~ a v
~~ a
~,x~ l6
~Z O °' Defendant repu6dished many of the False Statements in the FB Posts, including, but not
17
~~~~
limited to, the following:
~~
19 A. On December 14, 2015, Defendant posted "Be sure and check the Killing
20 '
My Career website and read real customer reviews of Russ Ruffino's
21
22 Clients On Demand, buyer beware."
23 B. On December 13, 2015, Defendant posted "FRAUD ALERT: Business

24
Insider &Inc. Magazine are unethically posting this AD by marketing
25
fraud Russ RuFfno who falsely implies rhzs is an article in these
26
27 publications, it is PAID Native Advertising. Do your research (Google at a
2$
~a See FB Posts, attached as Exhibit C hereto.
minimum} before spending money on image-based marketing programs
1
and avoid being a victim of those who employ Tactics from
3 #TheMMpil-IerMethod
#TheSociopathicBusinessModet.
4
#MMpiHerMarketing"
5
6 C. 4n December 12, 2015, Defendant posted "Killing My Career via Russ
7
Ruffino Live.... #Fraud aEert"
8
D. On November 18, 2015, Defendant posted "If you're thinking about
9
10 buying any marketing program from #RussellRuffino Russ Rufftno Live
11 Russ Ruffino Elite VIP Coaching based on something fi-om Inc. Magazine
12
V N
a ~~~
n it's NOT an article but a RAID AD. #NativeAdvertising is deceptive much
a•~,~ 13
a. ~, ~, _
c~ M
W ~ Q M 14 i like #RussRufftno. http://www.kiliingmycareer.com/.../twitter-ad-king-
z~°,No
d v d is russell-r.../"
a~~~
_~~ o
~~`°s l6
a 2, o ~-
a a~ 47. far the purposes of increasing the prominence of the Website Posts on the
v y
17
"~+N N~
00
l~ Internet, promoting her business aver Plaintiffs, and leading viewers to the Website,
19 Defendant republished False Statements in the BI Post:

20
A. ~n December t 2, 2015, Defendant posted "Is Business Insider just as
21
unethical is INC, where this AD first ran? This is PAID native advertising
22
23 and deceptive Cowards potential clients, who if you Goggle Russ Ruffino's
24
name, will end many unhappy clients. #TheSociopathicBusinessModel"
2S '
48. Upon information and belief, Defendants have also pretended to be
2G
27 disgruntled customers of Plaintiffs and have posted false and defamatory statements
28
18
concerning Plaintiffs' services and/or business methods.
1
2 49. The Posts made by Defendants clearly demonstrate the Defendants'
3
malicious purpose and intent to destroy Plaintiffs' reputation given the type, amount,
4
nature, and scope of the Posts. The Posts clearly were not made to further any lawful
S
6 purpose.
7 50. Defendants have knowingly agreed to engage in a malicious smear
8
campaign against Plaintiffs, as well as encourage and solicit third parties to join in their
9
10 efforts, to defame and disparage Plaintiffs, interfere with Plaintiffs' Existing and
11 prospective business relationships, unfairly compete against Plaintiffs, and place
N
12
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a w ~~ n Plaintiffs in false light.
M
Y~~~ ~NC~
13
ate„_
1p M
14 51. Defendant routinely encourages others to share the Posts and to create
W p O ~
a~•~~
a ~ ¢ ~. l5 content so that the Defendants Website would appear and will continue to appear at the
a ~' v y
'n
.. ca ~ G
~x~s 16
a Z ~ °=
a
very top of any search engine results related to Plaintiff.
N
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17
W
18 52. Defendant routinely encourages existing clients of Plaintiff to cease
19 participating in Plaintiff's program, seek to have credit card companies issues

?p
chargebacks, and to sue Plaintiff.
21
A. Contact your credit card company and stop payment (for all future
22
23 payments) and fle to have the initial charge reversed."~s
24
B. "1 would call, record the call, and ask the person you're speaking with to
25
provide you with their name &email address and send along your wish to ~
26
?~ cancel and will need canfrmation back via email that you won't be
?g
15 See Website Post, attached as Exhibit A hereto.
t charged. 1'd also put a }sold on your credit card or lry to reverse tl~e
2 charges it any have been made."~~

3
S3. The False Statements made by Defendants tend to injure the Plaintiffs in
4
their business and accuse Plaintiffs of business misconduct anti/or attack the busi~ress
5
6 'reputation ofeaeh Plaintiff.
7
54. According to the Website Posts, approximately 13 prospective clients
8
posted comments and stated that they would likely have hired Plaintiff but for
9
10 Defendant's conduct.
55. Upon information and belief, Defendants, as joint tartfeasors, acted in

12
U~
a~~,~
~,
concert, conspired with each other, and encouraged and assisted each other, to defame
M 13
QI N ~ ~
W ~y Q M 14 Plaintiffs; and as a result, Plaintiffs have suffered and will continue to suffer indivisible
o
aa-''~o~o
e = ¢ ~, 1S harms.
~3
~~~~~ a 16
~w N cn F' ~7
COUNT i -- FALSE ADVERTISING AND UNFAIR COMPETITION
i1NDEit THE LAIVHAM ACT § 43(A)(y)(B), 15 U.Q.C.§ l l25
18
S6. All of the allegations contained within the paragraphs above and below are
19 ~!
7p hereby incorporated by reference as if fully set out herein.
21
57. Defendant directly compares her purported "ethical" consulting services
22
with Plaintiffs' services.
23
24 58. The Posts promote Defendant's services over the services offered by
25
Plaintiffs.
26
27
~g
16 See id.
59. For the reasons set forth above, the False Statements are Literally False, as
2 ~ well a~ misleading and deceptive.

3
By pasting the Posts in connection with other advertisements promoting
4
I b0.
Defendants, Defendants made false f~~ctt~~l stak~:m~nts in a commerci~.l advert~seinent

5
6 ~ about Plaintiffs' services.
7
b 1. The Posts have the tendency to deceive a suhstantia! segment of its
8
audience because, as explained above, the postings were literally false in several ways.
9
10 62. The Pasts are likely to influence the purchasing decision of readers
11 '
because no clients are inclined to hire Plaintiffs if Plaintiffs' program it is understood to
12
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a ~,
r~ be nat}~ing but a marketing scheme as portrayed by Defendant.
a 13
a •~,
~ ;;
~, o.
14 63. Approximately l3 prospective clients posted comments and stated that
w o o
aa•~~
evQ~ l5 they would likely have hired Plaintiff but for Defendant's conduct; therefore, Plaintiffs
a~~
~zros !6
a have suffered a direct loss of these client due to Defendant's conduct.
~z ~"
17
~N~~
18 64. By publishing the Posts on the Internet, Defendant caused the False
19 Statements to enter interstate commerce.

20
6S. As a direct and proximate cause of Defendant publishing the False
?~
22 Statements, which contain literally false factual statements, it is presumed as a matter of
23 law that C4D has been and/or is likely to be injured, either by direct diversion of sales
24
or by a lessening of the goodwill assa~iated with COD's services.
25
66. Defendant published the Posts with the intent to injure COD and/or with
26
27 conscious disregard of the rights of COD.
28
21
67. CQD is unable to quantify a great deal o~ the lost revenue or assign any
1
2! dollar value to the loss of goodwill associated with COD's services.
3 willfully deceptive,
68. Accordingly, because Defendant disseminated
4
comparative advertising, COD's actual damages are presumed, and Defendants bear the
S I
6 burden of demonstrating that its profits are not due to the Posts.
7 Defendants' acts, omissions, conduct and transactions alleged herein were
69.
8~
aggravated, outrageous, and guided by evil motives wherein Defendants intended to
9
l0 harm Plaintiffs and/or consciously pursued a course of conduct knowing that it created a
11 substantial risk of significant harm to PEaintiffs.
12
U~
a Y ~~
,.,, 70. To dissuade Defendants and others from pursuing a similar course of
.~ ~ C
M 13
~ N 00 ,_
W ~ p M 14 conduct in the future, an award of punitive damages should be awarded against

aa~N~
a v~~ IS Defendants in the sum of suEfcienC magnitude to punish Defendants and to deter similar
3~~~
;, —
~,xro,a 16
;zoo conduct.
°~'F' 17
~C
Plaintiffs are entitled to recover their reasonable attorneys' Fees and costs
N
!8 71.
19 pursuant to 15 U.S.C. § l 117.

2d
72. It is impossible to quantify and/or assign a dollar value to the harm caused
21
22 to Plaintiffs' reputation or goodwill, as well as quantify a substantial portion of the sales
23 or opportunities that were lost, as a result of the False Statements; accordingly, the harm
?4
caused by the False Statements is irreparable, and Plaintiffs have no adequate remedy at
25
law,
2b
27 73. Plaintiffs will continue Yo suffer irreparable harm if Defendants are not
28
22
enjoined from making the False Statements.
2 74. t~s a direct and proxim~t~ result of the pefendants' conduct, Plaintiffs
3
have sustained, and will continue to sustain, immediate and irreparable harm, including,
4
but not lir-rtited to, damage to reputation, losses in revenues, loss of profits, loss of
5
6 goodwill, loss of business relations with existing and future business prospects, and loss
7
of competitive business advantage, opportunity, and/or expectancy.
8
7S. Even after being informed of the irreparable harm that was being caused,
9
10 Defendant was given numerous opportunities to remove the False Statements but failed
]l and refused to do so.
N
12'
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COUNT Il —DEFAMATION AND DEFAMATION PER SE
a•~~~ 13
a~,~~
w ~ o ~.
ate•"cam
e ~ Q ~', 1S hereby incorporated by reference as if fully set out herein.
~x~~ 16
a 77. The False Statements made by Defendants are about and concerning Plaintiffs.
aZ o~
v j7
~~~~
cv
00
t$ 7$. Without privilege, Defendants communicated the False Statements to third
l9 parties via the Internet and/or intentionally made such statements on the Internet, which
20
were accessible to third parties without password protection.
21 '
22 79. Defendants' False Statements are and would be highly offensive to a reasonable
23 person and have been published to third parties with the apparent intent of causing harm !,
24
to the reputation and ecanomtc interests of Plaintiffs.
25
$0. In making and publishing the False Statements, Defendants had knowledge of
26
27 ' or acted in reckless disregard as to the falsity of the False Statements.
28
23
8 I , Defendants published the False Statements knowing that they would be widely
1
2 disseminated across the country,
3
82. As a direct and proximate result of Defendants posting the False Statements,.
4
Plaintiffs have sustained, and will continue to sustain, immediate and irreparable harm
5
6 and injury including, but not limited to, damage to reputation, losses in revenues, loss of
7
profits, loss of goodwill, Ioss of business relations with existing and future business
8
prospects, and loss of competitive business advantage, opportunity; and/or expectancy.
9
10 83. As a direct and proximate cause of the conduct by Defendants, Plaintiff has and
11 will continue to suffer humiliation, extreme emotional distress, anxiety, depression,
N
12
V N
a ~~~ n stomach aches, headaches, Zack of sleep, lack of a desire to eat, emotional pain and
M
M~ ~ ~ ~ 13
a~„~~
~~ 14 sufFering, anguish, and loss ofself-esteem.
w o o ~,
a~•~~
d a4 15 84. The False Statements made by Defendants impeach the honesty, integrity or
aTv~ C
'fir ~ ~ -C l6
a~~v reputation of Plaintiffs.
~~
lU 85.The False Statements made by Defendants constitute defamation per se and
19 general damages are presumed as a matter of law.

20
86. Plaintiffs have suffered general and special damages in an amount to be proved at
2l
?2 trial.
23 87. In making and publishing the False Statements, Defendants acted maliciously,
24
willfully, wantonly, and unlawfully.
25
88. For such willful and malicious acts, PlaintifFs hereby seek punitive damages in
26
?~ addition to their actual damages.
28
24
1 89. Defendants' acts, omissions, conduct and transactions alleged herein were
2 aggravated, outrageous, and guided by evil motives wherein Defendants intended to

3
harm Plaintiffs and/or consciously pursued a course of conduct knowing that it created a
4
substantial risk of significant harm to Plaintiffs.
5
6 90.To dissuade Defendants from pursuing a similar course of conduct in the future
7
and to discourage other persons from similar conduct in the future, an award of punitive
8
damages should be awarded against Defendants in the sum of sufficient magnitude to
9
10 punish Defendants and to deter similar conduct by others.
ll COUNT III —APPLICATION FOR PRELIMINARY AND PERMANENT
12 IN.IUNCTION
V N ~..
a ~~~. M
1~ ~~ ~ C~ l3 91. All of the allegations contained within the paragraphs above and below are
a~,~,~
~ M
W ro Q M 14
z ~~"~ hereby incorporated by reference as if fully set out herein.
~ ~¢~ 15
a~ v
;~~a
~~ 16' 92. As a drrect and proximate result of the Defendants posting the False Statements,
a
az~~'
u y
~7
Plaintiff's have sustained, and will continue to sustain, immediate and irreparable harm
18'
and injury including, but not limited to, damage to reputation, losses in revenues, loss of
19
2Q profits, loss of goodwill, loss of business relations with existing and future business
?~ prospects, and loss of competitive business advantage; opportunity, and/or expectancy.

22
93. The False Statements made by Defendants impeach the honesty, integrity ar
23
?4 reputation of Plaintiffs, Plaintiffs' businesses, and Plaintiffs' services.
25 94. The False Statements made by Defendants are defamatory on their face.
26
95. There is a substantial risk that unless Defendants' wrongful acts described
?~
?g herein are temporarily, preliminarily, and/or permanently enjoined, Defendants will
25
continue to irreparably injure Plaintiffs.
l
2 96. Plaintiffs have no adequate remedy at law; therefore, Plaintiffs are entitled to
3
injunctive relief.
4
COUNT IV —FALSE LIGHT INVASION OF PRIVACY
5
7
hereby incorporated by reference as if fully set out herein.
8
9$.In making and publishing the False Statements, Defendants caused Plaintiff to be
9
14 portrayed out of context and in false light.
99. The False Statements are about and concerning Plaintiffs.

]2
vN ~. I00. Defendants communicated the False Statements to third parties via the Internet ~
1~ ~ ~ M
N c 13
~ Cn o~0
W ~ p M and/or intentionally made such statements on the Internet accessible to third parties I,
'Z ~ ,N O
a 4, 00
~s C¢~- 15 without password protection.
3 ~~~
°'
,~~_
~,x~s 16
a z ~" 101. Defendants' False Statements are and would be highly offiensive to a
~,~~~ 17
~ °~
18 reasonable person and have been published to third parties with the apparent intent of
19 causing harm to the reputation and economic interests of Plaintiff.

20
102. In making and publishing the False Statements, Defendants had knowledge of
21
22 or acted in reckless disregard as to the falsity of the False StatEments and the false light
23 in which Plaintiff would be placed.

24
103. The False Statements pose a direct and immediate threat to Plaintiff's business
25
relationships.
26
27 104. [n making and publishing the False Statements, Defendants acted maliciously,
28
26
l willfully, wantonly, and unlawfully.
2 105. For such willful and malicious acts, PlaintiFf hereby seeks punitive damages in
3
addition to actual damages.
4
106. Defendants' acts, omissions, conduct and transactions alleged herein were
5
7
8
9
10 107. To dissuade Defendants from pursuing a similar course of conduct in the future
and to discourage other persons from similar conduct in the future, an award of punitivE
12
N
V N r~
a ~~~ 13
a•~~~
a~,~ ^
~~
W R q M 14 punish Defendants and to deter similar conduct by others.
0
ad
0
. h
''~ oo
~`x~ ~5 COUNT V — TORTI4US INTERFERENCE WITH CURRENT AND
~~~~~v PROSPECTIVE BUSINESS RELATIONSHIPS
~ x ~° -~ 16 ',
a
aZ ~ ~- o
~~~~
N
17 108. A(1 of the allegations contained within the paragraphs above and below are
00
18
herebq incorporated by reference as if fully set out herein.
14
20 109. Plaintiffs have ~xistir~~ business relationships with clients and other persons
?~ relating to their business.

~~
110. Plaintiffs have a reasonable expectation of future business relationships with
23 ~,
24 existing colleagues, prospective clients and employees, and others with whom Plaintiffs
~5 do business or with whom Plaintiffs may reasonably expect to da business. This

26
expectancy is based, in part, on the considerable time, energy, and resources it takes to
27
develop the goodwill and reputation associated with Plaintiffs' respective names.
28
27
111. At all material times hereto, Defendants were aware of Plaintiffs' existing
1
2 and/or prospective business relationships.
3
112. As described herein, Defendants intentionally and/or purposefully
4
interfered with Plaintiffs' existing and prospective relationships by unlawfully making
5
6 the False Statements.
7
113. Defendants communicated the False Statements to third parties via the Internet
8
and/or intentionally made such statements on the Internet accessible to third parties
9
1Q without password protection.
li 114. As a direct and proximate result of the Defendants posting the False
12
U N
~~~
a ~"
r., Statements, Plaintiffs have sustained, and will continue to sustain, immediate and
• N M 13
a~,~
a R C M ~ff irreparable harm and injury including, but not limited to, damage to reputation, losses in
a ~ 'O 0~9
~5 revenues, loss of profits, loss of goodwill, loss of business relations with existing and
~~~~
~, z 16
aZ o °~' future business prospects, and lass of competitive business advantage, opportunity,
U v
~7
~"N~~
l~ and/or expectancy.
19 115. In making and publishing the False Statements, Defendants acted maliciously,
20
willfully, wantonly, and unlawfully.
21
116. Far such willful and malicious acts, Plai~~tiffs hereby seek punitive damages in
22
23 addition to actual damages.
24
117. Defendants' acts, omissions, conduct and transactions alleged herein were
25
26
~7 harm Plaintiffs and/or consciously pursued a course of conduct knowing that it created a
28 ~I
28
1
2 118. To dissuade DeFendants from pursuing a similar course of conduct in the future
3
and to discourage other persons from similar conduct in the future, an award of punitive
4
5
6 punish Defendants and to deter similar conduct by others.
7 COUNT Vi ~-AIDING AIVD ABETTING
8
119. All of the allegations contained within the paragraphs above and below are
9
10 hereby incorporated by reference as if fi.illy set out herein.
120. Upon ~nforrnation and belief, Defendants posted the False Statements with the
N
12
V N
a v~,~.
~ assistance and encouragement of each other.
M 13
a ~~
14 121. Upon information and belief, Defendants have knowingly enabled each other
fsl m p M
z~~.Na
~~
~ ~a~ 15 to defame and harass Plaintiffs, interfere with Plaintiffs' existing and prospective
3~v~
~,xro= 16
a
a Z o a~ business relationships, cause Plaintiffs severe emotional distress, and place Plaintiffs in
~n °o `~ F- ~~
N
]~ false light.
19 122. As a direct and proximate result of the Defendants' conduct, PEaintiffs have
20
sustained, and will continue to sustain, immediate and irreparable harm and injury
21
~z
including, but not limited to, damage to reputation, losses in revenues, loss of profits,
23 loss of goodwill, loss of business relations with existing and future business prospects,
24
and loss of competitive business advantage, opportunity, and/or expectancy.
2S
123. As a direct and proximate cause of the conduct by Defendants, Plaintiff has
26
2~ i and will continue to suffer humiliation, extreme emotional distress, anxiety, depression,
?g
29
1 stomach aches, headaches, lack of sleep, lack o~ a desire to eat, emotional pain and
2 ~ suffering, anguish, ancf loss ofself-esteem.

3
124. Defendants' conduct was intentional, malicious and done for the purpose of
4
causing injury to Plaintiffs.
5
6 125. For such willful and malicious acts, Plaintiffs hereby seetc punitive damages in
7
addition to actual damages.
8
126. Defendanks' acts, omissions, conduct and transactions alleged herein were
9
11
N
12
V~+~n
a ~ „-, M substantial risk of significant harm to Plaintiffs.
F~ ~ ~ ~ l3
a~,,~_
l4 l 27. To dissuade Defendants from pursuing a similar course of conduct in the future
0 o `~'
w ~
a~~~~
e =¢d: 15 and to discourage other persons from similar conduct in the future, an award of punitive
~°'
3"
,~~
~,z~ 16
~~~~' damages should be awarded against Defendants in the sum of sufficient magnitude to
17
~N N~
co
l~ punish Defendants and to deter similar conduct by others.
19 COU1~T VII —CONSPIRACY

20
128. All of the allegations contained within the paragraphs above and below are
21
?2 hereby incorporated by reference as if fully set out herein.
23 129. Upon information and belief, Defendants have knowingly agreed to engage in
za
a malicious smear campaign against Plaintiffs, as well as encourage and solicit third
25
parties to ,join in their efforts, to defame and harass Plaintiffs, interfere with Plaintiffs'
26
existing and prospective business relationships, cause Plaintiffs severe emotional

~7 I
28
30
1 distress, and place Plaintiffs in false light.
130. As a direct and proximate result of the Defendants' conduct, Plaintiffs have
3
sustained, and will continue to sustain, immediate and irreparable harm and injury
4
including, but not limited to, damage to reputation, losses in revenues, loss of profits,
S
6 lass of goodwill, loss of business relations with existing and future business prospects,
7
and loss o~campetitive business advantage, opportunity, and/or expectancy.
S
131. As a direct and proximate cause of the conduct by Defendants, Plaintiff has
9
10 and will continue to suffer humiliation, extreme emotional distress, anxiety, depression,
11 stomach aches, headaches, lack of sleep, lack of a desire to eat, emotional pain and
N
]2
V N
ay~,M
~. sufFering, anguish, and loss of se3f-esteem.
~'~~rn 13
a~~,_
W ~y p M' 14 132. Defendants' conduct was intentional, malicious and done for the purpose of
x Q No
pG~•~. 00
~ ~ Q~ 15
causing injury to Plaintiffs.
~~ v
~ ~ ro ~
l~
~• X ~ -c
a Z o °~' 133. For such willful and malicious acts, Plaintiffs hereby seek punitive
17
~N N ~
18 damages in addition to actual damages.
19 134, Defendants' acts, omissions, conduct and transactions alleged herein were
24
21
?2 harm Plaintiffs and/or consciously pursued a course of conduct knowing that it created a
23 substantial risk of significant harm to Plaintiffs.

24
135. To dissuade Defendants from pursuing a similar course of conduct in the future
25
26 and to discourage other persons from similar conduct in the future, an award of punitive
~~ damages should be awarded against Defendants in the su►n ai' sufficient magnitude to
28
31
punish Defendants and to deter similar conduct by others.
1
WHEREFORE, Plaintiffs demand judgment against Defendants as
3
follows:
4
A. For a preliminary and permanent injunction compelling Defendants to
S
6 remove from the Internet all materia{ pertaining to Plaintiffs and their
businesses;
8
B. for a preliminary and permanent injunction enjoining Defendants
9'
10 I from publishing any false statements or defamatory material to any
11 third party;
12
For an order, pursuant to 15 U.S.C. ~ 1117(a), requiring Defendants to
N
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a ~~~
r. C.
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M
~ ]3
account to Plaintiffs and disgorge all profits that were and are derived
C/1 00 ^.
a -~+ C M
~ ~ O r.
~~ I
oo
z ~'C a
e vQ~: 15 ~ during the applicable period;
3;v~
~_
~,x~,~ 16 D. For general damages in an amount to be proven at trial;
`',zQ~ ~,
~w °`~~' l7
N
E. For special damages in an amount to be proven at Trial;
~6
19 F. For punitive damages in an amount to be proven at trial;
20 G. For Plaintiffs' cysts herein incurred;

21
H. Far Plaintiffs' reasonable attorneys' fees incurred herein;
22
23 I. For interest on the foregoing attorneys' fees and court costs at the
24 statutory rate from the date ofjudgment until paid;

25
J. ~'or prejudgment and postjudgment interest on all damages at the
26
highest rate allowed by law from the date of injury until paid in full;
27
28 and
32
K. For such other and further relief as the Court deems just and proper.
1
EZESPECTFULLY SUBMITTED this 22nd day of December, 2015

4
5 KELLY /WARNER,PLLC
6
By: /s/ Daniel R. Warner
7 Daniel R. Warner, Esq.
8283 N. Hayden Road Suite 229
8 Scottsdale, Arizona 8525$
9 Attorneysfor Plaintiffs
10
it
12
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17
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19
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22
23
24
25
26
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33
1
DECLARA"~'JONNERIFICATIQN OF COMPi.AINT
2
3
I, RUSSELL RUFFIN~, declare as follows:
4
1. I am named as a Plaintiff in the matter filed in the Maricopa County Superior
5
6 Court originally entitled RUSSELL RUFFINO, et al. v.; MELAYNA M.
7 Lt?K~SKY, et al. {the "Lawsuit"), and 1 am authorized to make this
declaration/veri~cation;
9 2. tam writing this Declamation to verify the accuracy of the Complaint to be filed in
10
this matter.
11
3. I have read and know the contents of the Complaint, and the matters and things
12
13 therein stated are true and correct to the best ofmy knowle.~ge and belief.
iq 4. All of the fore~aing matters and factual matters set forth in the Complaint are
15 within my pez~oz~af knowledge, and ail documents attached to the Complaint are
16 true and coz~rect copies of what the documents p~arpart to be.
17
J8 ['ursuant to 28 U.S.G. § 1746 and A,riz.R.Civ.P. 80{i~, i declare under pen;atty of
19
20
~~ perjury under the laws of the United States of America, in addition to Arizona law, that the
21 foregoing is true and correct.
22
~3 "" /...
24 Dated: t2~Z(lZatS~
25
26
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28
29
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12/9/2015 UPDATED: Twitter Ad King Russell(Russ) Ruffino Cilents on Demand 8 The Sociopathic BusEness ModelTM ~ KILLING MY CAREER
HOME ABOUT CHIP ON MY SHOULDER THE PRINCE THE SOCIOPATHIC BUSINESS MODELri THE MMPINER METHOD "' TRENpING
UPDATED: TWITTER AD KING RU55El.1.(RU55)

RU~~INO CLIENTS C1N DEMAND &THE
SOCIOPATHIC BUSINESS MODEL'
By Mcloyna Lokoclry - In Tho Sociopathic Ducinacs Modol"' 68 Commontt ~ 7AaA2 Vlews
UPDATED November 18, 201 S
The Marketing Myth That Is Killing This

Generation of ... - Inc.cam
inc.com ~ empact- >the-marketing-myth...
Mobile-friendly -Nov 2, 2015 -Advertisement.

Russ Ruffino. This is a guest post from Russ
Ruffino,founder of Clients on Demand.
Russei~ Ruffino buys an ad in tnt Magazin@ {example of native advertising}
UPDATED:Jufy 9, 2015 at the very bottom and please be sure an check out the honest
negative customer feedback about Russell(Russ) Ruffino of Client on demand
UPDATED:July 13, 241 S Russ Turner aka The Catalyst Kid owner of The Roadmap 2
Success states he's been on CQS News, Fox, NBC and ASC without showing proof with links
on website REp FLAG
UPDATED June 17, 2075 below original story, Russ Rufflno's high pressure sales tactics
recounted from an unhappy customer.
May 21, 201 S
#TvLogoScam
This Twitter trick comes up across my feed every day as a promoted ad. He claims to help
coaches(we kaory my foV~_of that~p~/de ojs~~rts_[eaml albeit not as bad as
~j~s nrles[ess(aka Money Map to FreedomTM)but I'm pretty sure i could forgo hanging
my entire wardrobe in a closet because t'd have more room on Plnocchlo's ever growing
nase.
httpJlwww.kill(ngmycareer.comlttie-sodopathio-bu&iness-modeUtwitter-ad-king-n+ssell-runs-ruffinathe-sociapattiio-business-modeii 1134
12/9/2015 UPDATED: Twitter Ad King Russell (f2uss) Rufffno Clients on Demand &The Sociopathic Business Model'*' ~ KIt,LING MY CAREER
Business Priestess/ Money Map Alexis Martin aka Aii 5hanti has a new business name Law
8uslne55 Mentors:
Famlly Wealth Planning Inskftute, LLC

Lift Foundation Systems,lLC
Its(sic) All Happening, LlC
Ryes Wide 4~pen I.I:C
New Law Business Madel aka Law Business Mentors
Personal Family l,awysr aka America's Personal Family l awyer
The Alexis M. Neely 2005 Irrevocable Trust
The AMN 2010 irrevocable Trus[
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YOURS Now! cards.twitter.comlcards
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teYs Start with the b+g~j~ of Russell(Russ)Rufflna which is just another reason that
makes him latest contender for the #GodsOfFrauds. As seen in..." weif Chat looks impressive
but webe already learned before that to k~ s can be ~ecelvin¢(and sometimes need a
Sh9lOC6LI•
Russ Rufflno and The Nev~York Times
http://www.kiilingmycareer.cam/tha-soaopathiabusiness-modeUtwitter-ad-king-russell-cuss-ruffino-the-sociopathic-business-model! 2134
12/9/2075 UPDATED: Twitter Ad King Russell (Russ)RuHino Clients on Demand &The Sociopathic Business Madel"" ~ KILLIlJG MY CAREER
HOR1E PAGE I TODAVS PAPER I V~OEO 14Dg? POPU./~A I U-$. ~dfUOfl ~
t'~hr~lrW~o~ic~imca
thn~sdn~.Jiay 2~.^_ay Movies ~ TV
11'ORLD , li.S \.l',/ REG10\ BLSL~'E$S ~ TFJCfR.'OI.00Y-_.. SCI~L'E t~iLTH SPORTS OPL`TQ~I
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Box Olitc~ Top'3 Go Od ~~K~ ~ap+Y ■
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a. diad~las:RuyRaad SeC Gon+pe~a F~roWW~~Y
3. A~xngers:.~e ~ Gtizop
Maybe 1 forgot how to Google or something.
Russ Raf~ino -The New York Times

www,nyttmes.comtmoviestper5o~••.~Rass•Ruffino The New York Times
Russ RuHino. About Thin Person • Sa~'aWiY- Bax 6tfite lop 5. About Eily •Ballet ...
Rusa Ruft3no Filmography: See CAmplete Filmograpfry .. Has Worked Wilh:.
Russ Ruffino -Biography -Movies &'N -The New York Times

www.nytirrws.cgmlmovlesl..JRusz-Itu~t4no/pbgraphy The New York Ttmes
Mara in Movies .. In Theaters • Co~ni~9 Som •pities' Picks • On DVD •Tickets &
Showtimes •Trailers MsBeat. Russ Rufl3no. Abae Triis Person • Biogra~y ...
WERDINGS/CElEBf2A710NS -Hope Wilson, Christopher ...

www,nyttmas,corru...~weCtlings-cekDratbns-hope-wi1... Tne New vorx times
Jun 1, 2003 -Russell G. 42uftlno performed Ilea ewemaiy at St. Peter's 6y~th~.Sea ...
for securities fimss in Mew York she as an admi+dstrative assistant at ...
WEDDINGS -Deirdre DGuglas, Daniel W. Carey - Tha New ...

~wrw.nyttrtus.coml..JwedCtngs-dettdre~ougLas-Oa... •The New York Times
Jut 21, 7996 - ... Gertrude C. Catey. The Rev. RusseN G. Ruffino performed the
ceremony at the Episcopal Church of St. Peter's by-thevea in i~3rtagansetE, R.1..
Amazon.com: Russell Rut~no's review of The 4-Hour ...

www.amazon.comlrevlewJiZ2t1xBH~ZWIAJFR ~ Amazon,com, lnc.
***** Rasing: 5 -Review by Russell RuHino -Jun 4, 2021
Find helpful custaner reviews and review ratings fa the 4-fiau Wakµ~eek: Escape 9~5,
Uve Arrywhera, and Jan the kew Rich (Expanded and Updated) at ...
Maybe iYs under Russell Ruffino:
http:/(www.kiilingmycareer.cam/the-sociopathicbusiness-modelltwitter-ad-king-russeli-rues-niffino-the-sociopathio-business-model! 3134
12/9/2015 UPDATED: Twitter Ad King Russell {Russ) Rufflno Clients on Demand &The Sociopathio Business Model''"'(KILLING MY CAREER
GOOSI~ the new york times russell nafhno ~~~~~ A T 0
Web News Inugea Shoppt~g Videos Mae ~ Srarch Iadx
HbaII 45,300 results(062 secwWs)
Russ Ruttino -The New York Tlmes

~Wvw.nyURMs comtmovleslp2r50N.../Russ-RUffino ~fhe NCW York ThnCs
Ru:a Ruflino. Abcwt This Person • Biography. 9auc OE(Ke Top 5. About Elly • Balfet ...
Russ Ruffino Fiimogrrpt~y: See Complete Filmography ~. Has Worked With:.
Russ Ruf~no -Biography -Movies & N -The New York Times

tvww.nyttm~a.com/mOviCsl..lRuss-RulTlnolbfogf8phy The NCw York Times
Akre in Movies s. In Theaters ~ Coming Soon • Gitict'Picks • O~ t7VD • Tickata d
5hawlimes ~ Trdlars • MsBeaL Russ Ruftfrw. About This Person • Bioga~try ...
WEQDtNGSICELEBRATiONS -Hope Wilson, Christopher ...

www,nytlm~s.caml.../weddhtps-celebratbnsnope-wU... The New York Thnes
Jw 1, 2003 -Russell G. RufOno perfamied tJre ceremary at St. F'etafs by~he•Saa ...
to securities times m New Yak ahe as an ~drrtinistrative assistant at ...
WEQOINGS - Detrclre pouglas, Daniel W. Carey -The New ...

ww~v.nytlm~s.come...lweddmgs-aeudreCougias-da... ~ The Nev+York Tunes
Jd 21, 1996 - ... Gartnde G Gvey The Rev. Rnsseli G Rufltno peAortned the
ceremary at the Episcopal C~uycf+ot St. Petefs by-the~Sea in karra~r~ses~. RE..
Amezpn.com: Russell Rufflno's review o1 The 4-Hour ...

w~m~.amazon.comlreviewlR2ttZBH725MAJFR • Amazon.com,lnc. -
*~k**~k Rating: 5 •Review by RusseA Ru(tira -Jun 4.2p11
Find helpf~ customer reviews and review ratings for The 4+bur Wakweelc: Escape 9-5.
1 i..n A1ww~4ur~ ~..A I..in Nan 4w.D~.h lL~wnM...~ ~.wA 1 Mh~MI +~
future tip:
Ijyou write a reviewfor a book
it does npt make you un author, writer ornumber-one best seller
Whoops nat under Russell Ruffirin elYher, There's no need to even Check the rest of the list
he posted 4n line. Guess what? If someone was realty {n The New York Tmes,theyd usually
link to the actual article they were mentioned in or that they authored or at the very least
screen shot that bad boy. Right out of the gala thaCs not doing a lot for Russell{Russ)
Ru~no's credibility which (suspected was lacking when !engaged with him severe! months
ago an Twitter. (!71 admit after my breaking point for someone who writes about fraud every
day red flags tend to jump out and some are 50 obvious you Just try and ignore them.}
Fucking Twitter wip not a11ow me ro forget or ignore, ~esplte hittfn~ the littEe x to dismiss
Russell Ruffino's ads it comes back like a dande{ion that no amount of Monsanto pesticide
can kill.
did not save that riveting exchange(and lack the skil{s to find it my Twitter history) with
Russell(Russ) Ru~no but remember he made some Claim of bringing in 525a,00a a month
with no actual data to support that claim. When I asked far him to substantiate the claim he
was unable to(shocker.
http:i/www.killingmycaresr.00mlthe-sacfopathiabusiness-modeUtwktter-ad-king-russell-russ.ruffino-the-sodopath(c-business-model/ 4134
12/9/2015 UPDATED: Twitter Ad King Russell(Russ)Ruffino CAents on Oemand &The Sociopathic Business Model ~" ~ KIIL[NG MY CAREER
Russell RuffinA y Follow

(a3RussRu~no
My view at breakfast.
4:13 PM - 16 Apr 2015 •Mandarin prigntal, New York, United States
1. t'i r3
And right oui the grlfter's guide: Try and make peoplejealous ofyour lije so theyll think you're
successful. Also see posing with Porsche. The next time Russell(Russ) Ruffino's promoted ad
tomes across my feed I will report his ad to Twitter and suggest anyone else who is having
this specific problem drone like it report It as a means to forte accountability an the
unethical. The false information about being seen !n The flew Yoik Times along with his
claims lacking fact based evidence regarding generating 5250K a month are enough forme
to-know that I would net work with or recommend as a consultant that any of my clients
ever work with give Russell(Russ)Rufflno any funding. And before anyone pulls the haters
or jealous card: H~tprs ~,Forced AccoynRability.
http://www.kiflingmycareer.comlthe-sociopathic-business-model/twitter-ad-king-russeli-toss-ruffino-the-sociopathicbusiness-medal! 5/34
1219/2015 UPDATED: Twitter Ad King Russell(Russ} Ruf€ino Clients on Demand &The Sociopathic Business ModelTM ~ KILLING MY CARER
Mac Roni y Follow

@caceawara
Dear Twitter: These constant Russell Ru~no prflmoted "make
money off coaching" tweets are gross. please make them stop.
(eww @Rus~Ruffino)
7:59 AM - 12 Feb 2015
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Melayna ~okasky y Fouow

~Metay~eLokosky
@nytimes RUsseil Ruftino is promoting his business using
the7imes fraudulently kiilingmycareer.eom/the-soclopathi...
atwitter
5:29 PM - 21 May 2Q15
•+ tZ 1 M
And if you need a good laugh after ail the fraud talk head pn over to pj~ps
~~, i~neu you many recognize the popular far alE the wrong reasons Ali S~q 1 xis
U?DATED:
@MefaynaLokosky Hey Melayna - here's a shot of our Stripe account for

March of this year. Over $250,000 processed.:) pic.twltter.com/vuYrWZCbOy
-- Russell Ruffino (@RussRuffino) May 22, 241 S
Great i could make up a spreadsheet too, I can also hand write my name on to The New
York limes Best-Seller list, tell people I'm on it but it doesn't make it truthful or ethical. Yet
no word on why he lied about being in The New York Times or in Forbes as 1t turns out. Any
ht1p:11www.kifS{ngmycareer.comltt~e-sociopaSt~{c-business-modeUtwitter-ad-king-russelS-russauflino-tYte-sociopathic-business-modeU 6134
Model"' ~ KltLiiVG MY CAREER
1219/2015 UPDATED: Twitter Ad Kfng F2usse1l (Russ)i2uffino Clients on Demand &The Sociopathic Business
guess as to how Russell(Russ) Ruffino fairs with s~,~(, ~($,~,~and The Waft Screei
journal?Yep-goose egg. Except for this from the Fr~~~a ' GenEus which state that Ruffino
has been featured on Huffington Post, CBS and Fox despite being able to find ony evidence
to support such claims,
So from my Count Russell(Russ) Ruffino has lied seven times verified by Google searches.
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Great i could make up a spreadsheet too,t can also hand write my name on to
York Ylmes BesaSeVer IKt fe~~ 1`reopte I'm on is but ~i doesn't make It vuthfu! ar etkdcal Yet
no word on why he Iled abau[ being to The New York rimes or In Farber a5 n turns out, Any
guess as m haw Russell(Russ)RuNino fain with CNM and Foz?
Melayna Lokosky ~S' Foslow

@Moiaynalpkosky
@RussRuffino Absolutely nat. You lack credibility. Are you

harming the reputations of @nytimes @Forbes?
7;23 PM • 21 May 2015
h t1 •1
ociopaihic.business-madeU 7134
http://www.killingmycareer,comithe-sociopathiabusiness-modeUtwitter-ad-king-nissell-russ-ruifiirto-the-s
1?J9/2015 UP~AT6D: 7witier Ad King Russel)(Russ)Ruffino Clients on Demand & 7'he SoGopathic Business ModelTM ~ KILLING MY CAREER
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Melayna Lokasky y Follow

@MelaynaLokosky
@RussRuffino Fact based evidence has already proven you're a

liar.
7:30 PM • 21 May 2015
1~ t"i r
As predicted when confronted with negative facts a company would rather remain hidden
they pull the professionf victim card of haters when It's really Just forced accountability:
@Melaynalokosky The face that you won't apologize shows you have no
incegriry. Another hater and hypocrite poser. Have a great life.
— Russell Ruffino(@RussRuffino) May 22.2015
Well that looks a Iot like monipularion of the facts, not recognizing the rights ofothers. lack of
shame,remove,gurR or accountability while pincirtg blame; and he clearly does not like to be
challenged on the jarn and prefers they remain hidden. Russell (Russ) Ruffina via proven
fact based evidence lacks cred'oblliry to call my lntegrtty into question. 't'hls exchange only
reconfirmed that I would never work with or recommend to a client that they work with or
support any company that supports Russett(Russo RuHinu, but iYs nice he phoned a friend
to white knight for him:
hunterfian nHun[arFian 23m

~RussRuflfno ~Me4aynaLokosky So why throw the "Socbpath"card. Perhaps
crack open a OSM-5 manual before pafroting Itnk bolt to your bldg.
7:35 PM - 21 May 2615 Details
~, '.,_J .. ... c, Hlaecnnversahon
Hunter Hart white knights for the proven unethical Russell(Russ) Ru~no UPDAtED June
17, 2015 When forced to be accountable for his false appropriation of major network logos
used to deceive clients, the unethical Russell Ruffino blocked on Twitter.
http:!lwww.killingrnycareer.00mtthe-sociopathic-business-modeUtwitter-ad-king-russell-rasa-rufflno-the-sociopaihic~business-model/ 8134
12/9/2015 tlPDATED: Twitter Ad King F2ussell(Russ) Rufiino Clients on demand 8 The Sociopathic Business ModaiT" ~ lCILLIIYG MY CAREER
Profile summary X
Russell Ruffino
~RossRurnno
You are Diocked from touowing (d~RussRutfino and viewing(~RussRumno's Tweets.

Learn mor8
few weeks ago one of his unhappy clients* reached out stating they felt they may have been
scammed (paid upwards of 410,04D for the program)eker high pressure sales tactics with
poor-to no customer service or follow up. Russ Ruffino's unhappy client also stated they
purchased the program based off the major network logos on his website which this site
proved were deceptive and fraudulent. A true and ethical consultant wou{d never Charge
all the money upfront and would offer clients cwo choices:% of what the client makes after
using the program for a certain period of time or a fiat fee paid out over three months but
always going with the choice thaYs most advantageous to the client. REd FLAG If a
consultant states that unless a purchase is made at that moment or else the price will
double at a later date: MANG UP THE PHONE AND DO N07 PURCHASE WNEN(NQTl~THEY
CALL YOU BACK PROVIDING A "SP~fIAL OFFER." Unethical companies will often change
names in order to distance from past unethical and or Illegal behavior. Russell Rufflno also
operates under,jhe Art of Hish Ticket Selline and $~~~ff'Ino's Platln~m MesterMigd.
* I wlkl not disclose the email in order to protect the victim who hopetu{ly takes legal action
against Mr. Rufflno; but, ECS crucda! to gel factual Enfarmation out so that others may make
better informed dedsions to prevent possible further victimization. Also one brave person
coming forward may prompt others to do the same which is a goal of this sEte. Updated
July 9,2 15 E3efore Forc~~ A~co~nE~bility: RusssU (Russ) Ru~no of Clients on Demand
fraudulently used network television and major publication logos as a means to unethically
attratt business.
After Forced Atconntabiiity: Russell(Russ) Ru~no of Clients on Demand changed the

landing page of his website to his blog page(which no longer shows the fraudulent use of
logos) but will remain here on this site as tool to fielp potential clients make better informed
decisions before investing.'fhankyou tothe anonymous reader who posted this change
and to all who have commented exposing the negative truth Russell (Russ) Ruffino of Clfenu
httpJlwww.killingmycareer.comltha-sociopathiabuslness-modeUtwitter-ad-King-russell-runs•nifffino-the-saciopathlo-business-mode!! 9/34
12l9f2015 UPDATED: Twitter Ad King Russell (Russ)Rutflno Clients on demand &The Sociopathic Business Model'*' ~ KILLING MY CAREER
on Demand would rather remain hidde~~.
° The Uncommon Reason Raising

Your Prices Will Make Your
Clients Happier
this appears to be a growing trend: Russ Turner pitched his services of helping others
succeed with his free book an his site FiOadMap 2 Success an 7.13.201 S
I Direct Messages ~ with Russ 'Turner ••• x
Hey Ma~ayna
Heipinp OthOfS Sucte9d Is my passion, A GIR f0i You Rry

book in Potversion no Catth I prom~sel J
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12/9!2015 UPDATED: Twitter Ad Ktng Russell(Russ} Ruffino ClfeMs on Demand &The Sociapathlc 6ustness ModelTM ~ KILLING MY CAREER
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~ Russ Turner(@MadHelp4~)luly 15, 2015
http://www.kiliingmycareer.comlthe-sociopathto-business-modeUtwitterad-king-russell-nass-ruffinathe-sociopathio-business-modeU 11!34
12!9!2015 UPDATED: Twitter Ad King Russell(Russ} Ruttino Clients on Oemarui 8 The Sociopathic Business Modei^'(KILLING MY CAF2EER
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recommended for this and sent a press r~leasa~ to Fox?
3:10 PM - 15 Jul 201 S
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7AGGE0: SCAM Alexis Martin Nccty Nexis Neely Haters vs.forced AccountahilitY lUiShanti
ForceAccountabiliry RussellRuffino RussRuHino Not seen in The New York Times

IsTwRter accepting ursethicaf ads Report unethical ads toTwitter
Russell(Russ) Ruftirro review Oistrupt Happiness Losen Feldman The FreakingGen(us
Hunter Hart white knlghtz for the proven unethical Russell(Russ) Rutfino
MoneyMaptoFreedom^ kWinnersOSSheWeakl~ay2t)15 ~FTvLogoScam
Customer Review The Art of High Ticket Selling
Russ Rutfino's Platinum MasterMind
htlp://www.klllfngmycareer.comJthe-sociopathio-business-modeUtwitter-ad-king-rtrssell-toss-rufftno-the-socfopathio-business-model! 12!34
9usiness Model"' ~ K11.l.ItVG MY CAREER
12/8/2015 UPDATED: Twitter Ad King Russell(Russ) Ftufiino Clients on Demand 8 The Sociopathic
Getmoremomentum.cam wlthlames Teale anct previously Lee MNntyrc.
Russ Turner states he's been seen on CBS News Fox NBC and AF3C The Catalyst Kid
RussTuracr The Cata4ysi Kid The Rnadmap 2Success Scam or Fraud
Alexis Martin aka AllShantl has a new business name Law Qusiness Mentors
FemilyWealthPf~nnirtglnstitute LLCIiftFour+dationSystems LLCIts(Sic)AIIHappening
November 2015 Russell Ruffino buys an Ad in Inc, Magazine
10 I6• SMn ~; 0 ~~ ~
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Are Venture tapitaf FDA Friday Fraud UPDATEp: A The 8igge5t Problem
Firms like A11y Bridge & Round•Up:Johnson & Conversation We All with the Pfizer
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68 R~SPONSfS TO "UPDATED: TWiiTER AB KING RUSSEIIiRUSSI RUffINO CUfKi'S 4N

DEMAND b THE SOL~OPAYHlC BifSIHESS MOQEL~'"
Catherine says:
June 29,2015 at 6:06 am
Yes, I would add that he uses false advertising in his free webinars to try to hook you in. He
states that if you sign up For a'free'45 minute consultation, he or another"team member"
will talk you through how to identify your target audience and several other actionable
things. I thought "Mey,free consultation that might prove useful" No,You're just signing up
for a sales pitch. You will literally get nowhere without paying $15,000(which the sales rep
then said "could" be discounted to $10,000)in cone-time-offer price. Uh, no. No.And again,
no. As a small business, that kind of cash is unfathomable to spend without thinking about it
and truly believing in the value. But they pressure you to pp 17 NQW.Don't even get me
started on his assumptions about how people want to live kheir lives ... So yes, I was taken in
by the ever-present Twitter ads,Lesson(earned.Terrible customer service. but then what
do you expect when he advises you "coach' your clients as a group to save YOU time,versus
one-on-one to, ah I don'{ know, make sure clients are comp3etely satisfied with the level of
attention and respect they receive? I should've known better based on how oken I found
myse{f ro1{ing my eyes duffing the webinar. He gets by on that"gffib"factor. Ugh. If you say
anything with enough fervor .., Mook,line and sinker.
RC.VLY
Melayna 4okosky says:

June 29,2415 at 10:57 am
Thanks so much for your response Catherine. It never feels great being deceived or
pressured especially at $10,OOp-$15,000 but speaking out may have Just helped
someone else.
Dan says:
Octpber 4,2015 at 3:32 am
13134
http:l/vwrn.killingmycareer.comlMe-sociopathic-business-model!twitter-ad-king-nissell-russ-nrffinathe~sociopathi~business-madeU
12!912015 UPDATED: Twitter Ad King Russell (Russ)Ruffino Clients on Demand &The Sociopathic Business Model^' ~ KILLING MY CAREER
Hi Melayna,can I please ask how do you cancel a initial call? or do I just not
answer? I have not given any card details to anyone.
REPLY
Melayna Lakosky says:

October 5,2015 at 10:16 am
Hi Dan-I've not taken his program but('d make sure. you don't give any
credit card information and not accept the call at its scheduled time.
L Rf.PIY
Victim of IMer says:

June 30,2015 at 9:43 pm
worked with Getmoremomentum.com wlthJames 7eaie and previousEy Lee McIntyre.

Paid $6k and they never delivered as promised.I followed their advice to a T and when
didn't get results it was my fault. l mention this because t think Lee was Russ's mentor.
These Internet marketers are stammers.James afro did a high pressure sale on me. I Feet
like an idiot for falling for their tricks. They just has so many great case studies.
If you find someone who pressures you into taking action on the spot and that you get a bad
feeling about. Don't walk, run!
N E.I~LY
Melayna l.okosky says:

Ju{y i,2015 at 6:20 am
Thank you for commenting,!know it's never easy to admit to getting scammed but as
y~i i mention with lamps TPale previnusly l.ee Mcintyte unekhical often change their
names or company names to distance from previous crimes or unethical behavior,
which makes it difficult for the honest to keep up with(by design.)Thank you for
giving readers more information so they may make better informed decisions.
---REPLY--
Stanley says:
July 8,2015 at 11:24 am
Same story as Catherine,except I was only on the line 10 mins before I said you know what?
Your wasting my time I have real work to do.
Essentially they try to size you up to see if you can afford there service, if you cannot,then
"You are not ready" LoL
W hat a joke!
Melayna Lokosky says:

Jufy 8,2015 at 3:59 pm
http:i/www.kiilingmyraraer.comlthe-sociopathip-business-modeUtwitter-ad-kfng-russell-cuss-rufflno-the-sociopathic-business-modeH 14/34
12/8/2015 UPDATED: Twitter Ad King Russell(Russ)Ruffino Clients on Demand &The Sociopathic Business Mafet`'" ~ I(ILLiNG MY CAREER
Thanks for adding to the story Stanley. Similar, I noticed on Twitter recently Russ
Ruffino insulted & demeanedsomeone who asked about the price of has program and
his response was something along the lines of if Yheywere looking for the"cheap"
solution his program wasn't for them.Trying to shame clients into feeling price fs an
indicator of quality without providing facts(real factr not manipulations of facts as we
saw with the network logos) is a tactic often used by those focused on "branding" or
"image" vs,actual marketing or substance.
Kevin says:
July 9,2015 at 12:15 pm
Hi Melayna,
Thanks so much for putting th(s up! One of tha tactics Russell Ruffino's sales people use is
saying"if you google R~sSelf's name,you won't find anything negative about him an social
media" - WeIl, my sincere hope is that this article makes it to page one of Google!
It's currently the first link on the second page ~o~
I was actually suckered into paying the $SOk with nothing to show for it. The only reason he
has some success stories is because those people actually had a large following to begin
with and they reached out to their network using the same high pressure sales manipulation
that Russell uses. As tar as his core webinar stuff. it doesn't work,especially if you're
relatively new to the caaGhing or consulting game with few contacts.
Even if f cant my money back, how can we get the word out about Russell's lack of integrity?
I'm going to start pitching my real story in his program to at least 3.0+marketing blogs and
high Yraffic websites.
I'm not going to be silent about the lack of results. A lot of other people in the program who
are dissatisfied won't speak up because they blame themselves for"not doing it right"
No more. Russell won't hive'clients on demand'when I'm done with him.
-- R EPCY--~
Me~ayna l.okosky says:

Iuly 9,2015 at 12:42 pm
Thank you so much for leaving your comment in the interest of helping others. Its
never easy to admit when we've been taken advantage of but exposing the truth
othars would rather remain hidden is the way to not only help others but allow
yourself to transition from victim to empowered survivor. Please let me know that
other sites you've alerted and I'll link them to this story! Thanks again fpr reading and
taking the time to cpmment-Melayna
RfPir
Kevin says:
)u1y 10,2015 at 12:04 pm
I'm not sure who to pitch first, but I'm figuring out how and who to approach.
Kudos to the other commenters on this thread! We're on page one of google if
you search "Russell Ruffino" -this will help potential buyers before getting on
hrip;//www.kiflingmycareer.comlthe-sociopathic-business-modeUtwitter-ad-king-russefl-rues-tuffino-the-sociopathicbusiness-model/ 15!34
12/9/2015 llPDA7ED: Twitter Ad King Russell(Russ)Ftuffino Clients on Dsmand 8 The Sociopathic Busi~ass ModelT'' ~ KILLING MY CAi2EE}2
the phone with his sales team! Great work Melayna.
'., REPLY
Mekayna Lokosky says:

July 10,2015 at 3:l)0 pm
A fundamental of this site is truth and transparency and while it is

recognized there are issues with Russell Ruffino's business model and
ethics,comments coming from the same IP addresses with name change is
also unethical(Kevin 12:04pm & Aiex 12:14pm today same!P)and just
noted today-that yesterday's commentsfrom(Anonymous,Kevin and
Jason all the same I P ad8ress butdifferent From today's comments).
understand the frustration and anger that comes with being victimized
by someone who appears to do th(s for a living; however,organically more
people will come forward in time and it's not "if" it's"when° they decide to
come forward because unethEcal behavior always creates a wake of
victims.
i do encourage people Yo come forward; however,stooping to tactics
Russell Ruffino uses to bait people witl not fix the problem.
Fact ba,ed evidence over time is the 6esY indicator of the future;and,
Russell Ruffino will only stop when forted accountable. If you are victims
and want to hold him accountable legal action is the best recourse. People
who employ tactics from The Socioapthic Business Model"'will demean &
insult their victims when challenged(asking for a refund)in the hopes they
do the easy thing and walk away, which allows them to continue to
victimize others without accountability.
A website can only do so much to expose the negative math he'd rather
remain h+dden; and, i cannot want far people what they do not want for
themselves. Candidly J was not a victim of Russell Ruffino's business (f was
victimized by another company)and is in part why I started this site.
Moving from victim to emppwered survivor isn't easy and that read is
different for everyone but no one victim should ever be dismissed without
the ability holder the abuser {s} accountable.
aercv
Kevin says:
July IQ,2015 at 8:23 pm
You're absolutely right, Melayna.The hurt from the incident made

me post twice, once as myself and once a5 Alex, who actually did opt
out of doing a session with Russell after talking to me,but I shouldn't
have posted on his behalf. I'm just going to let others come forward
naturally. Its hard to make this transition to empowered survivor,
but i will find my way.

July 10,7015 at 8:56 pm
Kevin-t appreciate your honesty and as I've sold anyone who has
been victimized by a companywill certainlyunderstandthe angar,
httpJ/www.kiAingmycareer.com/tha-soclopathie-business-model/twitter-ad-king-nasselhruss-ruffinathe-sociopathic-business-modeU 1fil34
12/9/2015 UPDATED: Twitter Ad King Russell (Russ)RuHino Clients on Demand & "fhe Sociopathic Business ModelTM ~ KI1.l.ING NfY CAREER
frustration and the desire to want to hold the abusive accountable.
Coming forward and sharing your experience is a step towards
becoming empowered-Hang in there-Melayna
lasort says:
Juiy 9,2015 at 12:29 pm
^same story as Kevin.So relisved this thread exists! I'm a financial trader and I dad make a
sale during the program but it was through reaching out to my current customer base,just
11ke Kevin says,The bulk of the program is useless. You could ga to stealth seminar's
website and just go through their free material from Geoff and do just as well as paying
Russell Ruffina and his chumps $10,000.
The team at Clients on Demand are like a cult.They want you to believe that you can do six
figures a month from scratch 7f you just "invest(n yourself", excuse ma, I mean, pay them
enough money.Just another case of if it sounds too good to be true, it is. Don't make the
same mistake Kevin and I slid folks.
RfPLY

luiy 9,2Q15 at 12:50 pm
Hi Jason-thank you for adding to the story.!'ve said before{and th;s is not a sales
pitch but what I do with client5l I don't take a dime until i make them money{both
people h2ve to have skin in the game); but, unethical "coaches"who want to mass
market an image apposed to building a sustainable business for themselves and their
clients wh+ch takes longer,is not their goal. Mave you al! thoughk about a class action
to get sors~e or all of your money back?
', RfPIY
A~onympus says:
July 9,2Q15 at 1:05 pm
You're right -it's not ethical or ask for so much upfront and then not even have
a refund policy! You know there's some people in his program that go into debt
to jpin his program because his numb-skull safes team is trained to get everyone
to buy no matter what.They only hang up on you if you're smart enough to
question them. Now I know that Russell Ruffino is smart enough to know that
his 4tuff doesn't work For 99.9~'a of his clients so he says you can't refund even if
you don't have enough money to feed yourself because of him.
like how you screenshot his use of media labels,called him out on it, and now
hefat rid it and now fias a comp4ete4y different website to cover his ass that
highlights his'success stories"(which are from years ago because he doesn't
have any recent success).
It used to be russruffino.com whlchnow re-directs to a re-designed

clientsondemand.com
don't know much about litigation and the cost of it, but if there's a way to shut
Russell Ruffino down ASAP so that no one else has to fal! for his tricks, I'm open
to hearing about it.
JusC so everyone knows,Russell was an out of work actor/bartender tfiat got

http:!/www.kiilingmyc~►eer.comfthe-sodopathio-business-modetltwitter-ad-king-russeU-Hass-nrffino-the-sodopathic-business-modeV 17134
MY CAREECt
1?J9120i5 UPDAYEp: Twitter Ad King Russell(Russ) Rutfno Clients on Demand &The Sociopathic Business Model^' ~ KfI.LING
caught up in this scammy Internet marketing game because it really is a quick
buck for him. Me believes he gets great results, but ff you bring up actual stats
for his clients, he won't pay attention because that would mean he would have
to face the fact that,'gasp', he won't be in business for long.
hEPIY

Ju1y9,2015at2:16pm
"I like how you screenshat his use of media labels,called him
out on it, and now he got rid it and now has a completely
different website to cover his ass that highEights his"success
stories"(which are from years ago because he doesn't have
any recent success)."
First, thank you for letting me know I'll update that later to highlight
what's called on this site Forced Accountability. Itsupports my
observations and fact based evidence that Russell(Russ) Ruffino was
fraudulently using thane logos to generate businessunethically. Unethical
and or illegal behavior wi11 continue to escalate and only stopwhen forced
accountable.The changing of names(both personal)and business is
common of those who employ tactics from The Sociopathic Business
Model"'as a means to distance from previous unethical and or illegal
activity.
Thank you also for updating readers and potential clients(accomplices

turned victims)to the fact that the site russruffino.com now redirects to
clientsandemand.com.1'm votfamiliar with that area of law but if an
attorney does take it there should be some provision that he must operate
under his real name for a certain number of years as a means of preventing
Future victims.
q~e of the goals of this site is to expose unethical people running

unethicat companies as a means #o prated consumers who then
understand their purchases have power-supporting ethical and starving
the unethical, I'd like to thank everyone who has came forward on this
thread(or contacted my privately by emai{)to expose the truth Russell
Rufftno would rather remain hidden.
Cbass says:
November 13,2015 at 12:59 am
Your definition of"Unethical practices" because the person took a1) the money
up front is misleading.
It's not unethical at all.
A car deader gets their money upfront.
A home Seller gets Yheir money upfront.
You have to pay a full months rent before you can move into an apartment.
You don't get to lake your groceries home before you pay for them.
http://www.killingmycareer.comlthe-sociopathicbusiness-modeUtwitter-ad-king-n~ssell-cuss-ru(fino-the-sociapalhi~business-modeU 18134
ModetTw (KILLING MY CAREER
1219/2415 UPDATED: Twitter Ad King Russell (Russ)Ruffino Clients on Demand &The Sociopathic Business
You pay for your airline ticket before you ever get on the plane.
can keep going if you'd tike.
It's one practice to get paid after the fact and if you get burnedYOU lose out
and have to then pay more money to try and geY your pay.
It's another practice to accept aN your money up front.Then you don't have to
worry about chasing someone down if they stop paying, or decide not to pay.
Neither practice is more ethical than the next.
Ethics come in if the person doesn't deliver on their promise. Plain and simple.
You you're bashing someone else's collection practice because it makes you
Zook be#ter. Not cool.
Melayna i.okasky says:

November 7 3,2015 at 1:27 am
Unethical refers to fraudulently using tv Iogos to lure clients, as many on

this thread have clearly stated thaYs why they signed up with him. How
someone collects their money is less relevant if customers are happy with
service, many clearly weren't and left with no recourse. Offering solutions
to the problems the unethical have created, +s usually only a problem for
unethical people.
REPLY
Anonymous says:
November 15,2015 at 8:52am
Cbass writes in the styEe Russell writes,so if the only defense coming to
Russell's aid is Russel0, that says a lot..!was in Russell's course(Spring'15).
Now Cbass,you say,.. "Ethics come in if the person doesn't deliver on kheir
promise. Plain and simple."
This whole thread is about how Russell doesn't deliver on promises...

You're right, who cares if the money is taken upfront or not?
But in the case that the money is taken upfront, the ethical thing to do
(and standard practice)is tooffer a money back guarantee to protect the
consumer. This balances out the risk that the consumer takes in trusting
someone like Russell with $10k.
So what does Russ decide to do in addition to taking money upfront?

Makes everyone sign a contract upfront saying that regardless of if Russell
delivers, he gets to keep the ckienYs money.
Go home Cbass.
RF'PLY 1
ess-modeU 19!34
http:(lwww.killingmycareer.comlihe~soeiopathic-business-mpdeiltwitter-ad-king-russell-cuss-tuffino-the-sociopaihfo-busin
12J912015 UPOATEQ: Twitter Ad fUng Russell(Russ) Ruffino Clients on Demand 8 The Sociopathic Business ModelTM ~ KILLING MY CA~2EER
Alex says:
July 10.2015 at 12:14 pm
Thank the lord of this thread. i was about to do a'strategy session" with RusseU's team, but
now i know to cancei it! I'm going to see if I can submit a query to the New York Times and
these other pupliCations about this blatant abuse of media sYmbots. Y'mwifling to be an
active contributor to bringing this dude down.
_...RCPLY.~
Gabriella says:
~~ July 13.2015 at 11:12 am
was minding rnY own business{On Twitted when I saw one of Ruffino's adverts come
across my stream,.. needless to say I Googled "Russ Ruffina clients on demand scam" and
found your post as #1 an Page 1! Well done G
R(PLY

July 13.2015 at 11:36 am
Thanks for adding to the story Gabriella; and,I'm shocked/not shocked that ?witter
doesn't have a policy against such advertising.You make a great point,if ever thinking
about buying an online marketing money Pmgramalways type in the name of the
person (People)linked to the business,the business name,and the words fraud or
scam to tfY and pull up reviews that are noY likely generated by the company.Also
look for company name change and eventually the removal of personal names to the
programs(or again personal name changes) as a means to distance from past
unethical and or iliega{ behavior.This site posted the story but you a!I have given and
continue to give it life with each petsa~ that comes forward to share their experience.
f2LPLY
Anonymous says:
Julylb,2Q15at4:10am
am currently in the middle of Russ's program and I think i have been 10096 scammed. i was
swept up with the idea of the program's success and i signed up.Towards the end of the call
started to feel a little uneasy but there was real pressure to pay by credit card there and
then. i decided to be dishonest(I'm not proud]and i gave my address wrong,thinking that
the payment would not go through. It didn't straight away but was successful over the
weekend and I Was so upset. f thought I would try and make the best of the situation and go
ahead with the course, but it has been pretty useless.
The whole premise is geared towards coaches. I am noY a coach and emphasised this on the
initial call as I was concerned that webinars,courses and FB groups would not suit my
business but 1 was told it would be fine. i have emailed far support and got pretty brusque
responses back or complete and utter nonsense(just more empty sales speak).
signed up to pay in 2installments and the 2nd payment is due next week. I am so stressed
about it.
l REPI
http:/Mrww.kilEfngmycareer.00mlthe-sociopathio-busfness-madeUtwitter-ad-king-njssetl-cuss-n~Hinathe~sociopathio-business-model/ 20134
12/9/201 & UPpAT~D: Twitter Ad King Russell(Russ) Ru~no Clients on Demand 8 The Sociopathic Business ModelTM ~ KILLING MY CAREER
Melayna Lokosky says: ~
July 16.2015 at 8:47 am
CantaCt your credit card company and stop payment((or a!i future payments)and file
~to have the initial charge reversed.
Anonymous says:
July 22,2015 at 13:16 pm
Russ makes you sign a contact that states your results are your own,so there's no going
back on credit card payments or it becomes a legal issue.
Best thing to do for anyone in a high pressure sales call situation is e€they hang up and
collect your thoughts, or demand that you speak with at least 3 people!n Russ' program at
different skill levels (i.e. beginning of career, middle, established etc.)
That way you don't have to take anyone's word for it. You'N know firsthand that anyone
claiming that he can help you create six-figure businesses from Scratch in a matter of weeks
{s a total scam.
Do your research,don't get 8motionai,and don't sign ANYTHING that is legally binding,
especially when the risk is all on you. Why would Russell Ruffino not offer a money back
guarantee if he is"world class at what he does"?
The answer? He's a master marketer and knows he can't deliver on his ridiculous promises
99.99% of the time,
I've worked with him and have seen the financial havoc he can wreak if you're a newbie or
easily cajoled. Once again, dp Your research, make informed decisions, and dan't lock
yourself into a contract that puts you fn financial danger.
_eerir ~'
Mef ayna Lokpsky says;

July 23,2015 at 10:33 am
Thank you for adding to the story and helping consumers make better informed
decisions.
Raven Davis says:

July 25,2015 at 12:42 pm
saw Russell's ads on 7wittet and Yhought his site and stories were very compelling but I'm
glad this article breaks down the facts.
I too got caught up in the shiny promises and superficial marketing.
Thank you to all of Ehe above commenters and to those who were ripped off, know that
you've helped many many more people who would've been taken advantage of.Cheers ~`.~
http;l/www.killingmycareer.comlthe-sociopathic-tiusineas-modeUtwitter-ad-k{ng-russet!-toss-ruffinathe-SoclopathiGbusiness-model! 21!34
12/9/2015 UPDATED: Twitter Ad King Russell (Russ} Ruffino Clients on Demand 8 The Sociopathic Business Modei"' ~ KILLING MY CAREER
Anonymous says:
July 26.20I5 aC 10:46 am
I'm almost dyne with RusS~ program and even though he taught some decent stuff,it was
maybe worth a $200t1as5, NO7$10K"
What really gets me is he makes you sign ~ c~nti aU up fl•a~t that allows him to Just say,"oh
well 1 guess you just didn'k get the results:'
Russell won't {ast long playing his little con man game. He's persuasive and a hard seller. but
in the end enough of us w111 speak aut about the fact that less than 196 of clients get any
measurable results.
aFrty
Anonymous says:
July 31,2015 at 5:46 pm
Recently had a call with one of the reps from Russ' program.First pff this caU was nothing
but 45minutes worth of good sales profiling and preparing for a hard close.The first thing
the young lady said was she would appreciate it if I could make a Yes or No decision at the
end of the call. She stated they don't like people to be in between or indecisive. That whale
we only want to work with real leader's type of speech.In my head I'm thinking she really
doesn't know she is talking to someone that has a sales background.Throughout the 4Smin
she's just asking me tons of questions that I can tell she is not really paying attention to my
answers.Then she starts Co drop financial psychology sales questions like, doyou have to
check with your significant other before making a financial dacis(on or are you the man in
charge...lol. I'm thinking are you kidding me.J played along though to see where all of this
was going. After 45min she tells me that I made the cut and I fit the type of client they would
love to work with because if I didn't she would have stopped the call a long time ago.YEAH
RIGHT LADY.The next 5 minutes of the caU was a brief run through of the program with
very little detail. Its an 8 Week prpgram with 2 webinars per week.Then she tells me after
that they have a master's program that can cost $2500 per month plus there is a $1000 per
month fee to test to see if your ads work and truly attract clients, Wait,what do you mean if
my ads work? You guys are making six figures per month off this strategy right,so why the
hell do I have to pay an additional $1Q00 per month to test your "prgven"strategy.Then she
drops the real bomb and says the initial price to get started is 15k and asks me what type of
card 1 will be payingwith. Are you fucking serious? If i were to pay someone i5k I am not
giving a stranger my card Number over the phone without seeing any documentation at alt.
Who do these people think they are dealing with? I told her well judging from what you said
in the beginning that you need a solid ycs or no answer...my answer is a firm NO.The phone
went silent.Then aI{ of a sudden the price dropsfrom 15k to 10k...and just because she
thinks I'm awesome she can do it right now and only right now for 9k..,so you will take a 6k
lost just forme? I'm shaking my head and this point. f tell her NO firmly again and then she
goes into the tactics that she has been preparing for the entire call buk none of that crap
works on me. I am a real coach, a real speaker,and I really love helping people. i hate these
scam artists out here that give the self help industry a bad name.People like this prey on
your vulnerability with promises to malts you rich. Run Far away from this nonsense.
REPLY
Melayna Lokpsky says:

July 31,2415 at 6:08 pm
"The first thing the young lady said was she would apprec(ate it it t could make a Yes
or No decision at the end of the call"
h2tpJ/www.kil(ingmyeareer.com/the-sociopathiGbusiness-modelltwitter-ad-king-russell-cuss-n~ffino-the-sociopathio-business-modeU 2Zl34
1219/2015 UPDATED: Twitter Ad King Russell (Russ)Rufflno Clients on Demand 8 The Socfapathic Business Model*" ~ KILLING MY CAREER
Say you can make your decision immediately and hang up! Gaining someone's
business is a privilege that's earned via veri6fable fact based evidence over time. Any
company not willing to build that trust isn't worth your time and certainly not your
money.
"i rnade the cut"
C:om~anies kh~t aper2te this way usa this type of laii~ud~~ to try and create the
appearance of Qxclus~~~ty,Truthfully do we think they'd turn down any money?
Ethical consultants have and will walk away potenYiai clients for a host at reasons
(examples:over-booked or difference in philosophy). Unethical wi►I #ocus on the
imageof being selective but never ethically backing it. This is a manipulation offacts
Thanks for taking a bullet and fiste~ing to the entire pitch and for adding more insigfit
into Russ Ruffino's unethical sates model.
RfPLY
Kate says:
September 22,2015 at 11:52 am
Thank you all so much for this information and confirming my gut feeling about
this group. I had my "breakthrough" session with one of Ruse's people yesterday,
and was fed exactly the same lines you were. Red flags,everywhere!The kicker
was that if I didn't sign up RIGHT NOW,it was because I was afraid and had
mare inner work to do to get over my money issues—and,of course,that #hey
can help me with that.Then she started in with something about even khough
really couldn't afford to pay that ridiculous sum of money for an S•week course
(!)) I'd make the money back—and more—in a matter of weeks. I told her that if
she had to have an answer now,it was no and that t needed 24 hours to
"process"the information.She kept pushing and pushing but finally said I could
have the 24 hours. I'll be interested to see whether she calls me this afternoon!
If she does, my response will be an emphatic"na!"
HF.PiY
Anonymous says:
September 22,2015 at 8:56 pm
As I suspected,his coach didn't call me back as promised. Heilp?Complete

lack of Integrity, if E had any doubts about saying no-which idon't-this
would be the final straw. Russ and his keam have no integrity.
RF.PI Y
Jeremy says:
August 1,2015 at 12:Ob am
Thanks very much for this. I was checking out the testimonials an his site, and came across
this guy, his student, who also claims to have been featured on all those networks.
http://www.j(mk rautkremer.<om/
Sic him'
R[PLY
bite:/iwww.kilfingmycareer.com/the-sociopathic-business-modeNtwitter-ad-king-russell-toss-rufflno-the-sociapaihio-bustness-mode!! 23!34
1219!2015 UPDA7E0: Twitter Ad King f2usseil(Russ)Ruffino Clients on Demand 8~ The Sociopathic Business ModelTM ~ KILLING MY CAREER
Anonymous says:
August 7,2015 at 11:18 am
agree with everyone's experience on the phone.It is not a free consultation ~ it is Russ
Ruffino's safes team going for your jugular until you pony up thousands of dollars.!was told
that i wasn't a good fit for the program after i mentioned that I didn't have 5k to pay an the
spot. I wanted to do more research and have more time to think about working with them,
but t think the lady on the phone realized that if i actuafiy did my homework,I'd stumble on
this site and realize how their game works, If you're signed up far a call,save yourself the
time and headache and CANC~I IT.
REPLY
Marni says:
How do you cancel it? I just signed up today and luckily found this site...
REPLY
Melayna l.okosky says:

i would call, record the call, and ask the person you're speaking with to provide
you with their name &email address and send along your wish to cancel and wil!
need confirmation back vfa email that you won't be charged. I'd also put a hold
on your credit card or try to reverse the charges if any have been made.
IMPLY
A~ionymous saysc
^ Alsa, Russ Ruffino reminds me of one of the guys you'd find on that show Àmerican
Greed'on CNBC.There's alot of similarities -the sales call tactics,sweet talking,glib
promises,superficial charm, high prices,and no customer support.Desp(cable behavior.
FF.PLY
Candice valencia says:

August 11,2015 aY 6:25 pm
just cancelled my initial Cali thanks to this thread. I knew it was too good to be true but
was curious.Thankfully i won't be wasting my time now.Thx!
IiF.PLY
Candice valencia says:

August 11,2015 at 6:25 pm
just cancelled my initial Cali thanks to this thread. I knew it was too good to be true but
was curious. Thankfully I won't be wasting my time now.7hx!
aEr~v
http:/lwww.killingmycareer.com/the-Socippathiabusiness-model/twitter-ad-kin~russeA-rues-niffino-the-sociopathiGbusiness-modeU 24!34
CARER
12/9!2015 UPQATED: Twitter Ad King Russell(Russ) Ruffino Clients on Demand 8 The Sociopathic Business Mode1TM ► K{ILING MY
Akash says:
Last night I signed up for a cell with Russ tomorrow evening. My beEoved showed me this
SItA.
Sorry to read about the people who were ac#wally scammed Hope you all wil4 be able to
leave all this behind you snon!
did download his Free pdt end started reading it. My eyebrows were frowning here and
there but not enough to cancel the appointment yet. I still had the mindset to listen to his
story and make up my mind later. After reading all this i will cancel the appointment.
Thanks everybody.
Safe travels and never let yourself be pushed into anything.
REPLY
~~n.u~ii' Veronica says:

~ August 23,2015 at 2:47 am
Thanks to everyone for their posts. Fortunately,!did not sign upfor the programme as the
'strategy session' after listening to a webinar is similar to the post by Anonymous on July 31,
2415 at 5:46 pm.
In my case, however,it was ~ Suy who called me,and the requirement for the'YES'or `NO'
answer was stated upfront. I was impressed with the safes approach and was drawn to the
'promise'that the support during the programme will be not Just from Russ, but also from
his team of experts -marketing,copywriting, etc. My answer was NO to the instant one
time offer' to sfgnup.
Somewhat surprising, I was 5tili an the mailing list for regular updates and invitations to
webi~ars with other offers. Now,however,with the pasts on this website,f wi14 stay clear of
this programme.
__ RFPLY...:
Channing says:
August 25,2015 at 2:52 Pm
I'm indebted to this site for exposing the il{ business practices of RussetI Ruffino. My wife #s
an actual business coach and got on the phone with these guys(I listened along of course)
and they've perfected the art of seeming to be genuine and experienced, but every time my
wife pushed For more specifics on the program and asked to speak with someone like her
who has succeeded in the program,they would give her the run around.
There w!I! always be those who prey on people's dreams -they might make their sites
fancier, case studies more compelling,and interject some new-age 4Curnbaya woo woo to
make you feel special, but as someone with 15+ years sales experience and who has seen it
all, I cal! Russell Ruifino and his team far what they are -charlatans and snake oil salesmen.
REPLY
Sebastian says:
http:l/www.killingmycareer.comlth~-sociapathiabusiness-modeViwitter-ad-king-russeli-cuss-ruffinathe-so~iopathio-business-modeU 25134
121912015 UPDATED: Twitter Ad King Russell {Russ) Ruffina Chants on Demand &The 5ociopath3c Business ModelTM ~ KILLING MY CAREER
Dodged a bullet by cancelling my call with these people.Thank you to all of the commenters
here!
N F.PIY
Graham says:
Thanks for this website, you have saved rt e a lot of rtioney and grief,!had the same
experience as many others. it just didn't feel right.
Thanks again.
I Ff:PLY
l_ _ __
Simon says:
hi i just saw this was going to go through strategy session with him
after reading all this! NO WAY!!!! QMG I CANT BELIEVE THIS PERSON IS DO(NG THIS
ME SEEMS SO REAL!
how can we bring him down? i saw his group

https:!/www,facebook.com/groups/highiicketselling/891728670920272/?
notif t=group_aCtiviry
do you think can go in there and post maybe join itor somethfngigot email from him long
time go
he is ripping people off frPm what I have seen oer $20k thrpugh this comments on here amg
Dan says:
Hi, Candice valencia and everyone eEse who maybe able to help. I have received a email
confirmation for a pfione caN booking. E came across this site. There is nothing on tfie email
with cancellation information. Can someone please tell me how to cancel this appointment
or do I just not answer the call. Thanks
Rcr~v
Anonymous says:
signed up for a caf I for him to help me with my Web Design company. After reading this
thread I know that I won't buy into the program. However,I would like a good laugh,so
think I'll go through with my cal! on Monday lol,
Rl:t'lY
http:/lwww.killingmycareer.com/the-sociopath(ahusiness-model/twitter-ad-king-russelhruss-nrffino-the-soc(opathi~business-modeU 26/3~l
1219/2015 UPDATED: Twitter Ad ICing Russell (Russ} Ruffino Clients on Demand &'The Sociopathic Business Model'*' ~ KiLL1NG MY CAREER
Anonymous says:
October A7, 2015 at 4:33 pm
} took his course this year(2015). From a post I saw on his personal FB page,I thought that
for the $10K,they built the funnel far you.They charge $70K for that.
1 sigi~td anyvray. I coufd~7t find any bod reviews about him onUne and I searched for hours.
was led to belive that I could make rtiY 2nd and 3rd payment from my sales,so who could
turn that down???
did'+n't even know they hit my card for the 2nd paymen#,as 1 never got a receipt and i have
no idea why my card allowed ft since I was at my limit. I could not remotely afford this,but
they speak to you as if iYs an absolute that you wil! get 10 clients for $SK,which they
promise and then contradict in the contract, but I was sold.
What I know now,vs what I knew then..,.is this. You watch videos and set up your funnel.
and they review you every step of the way. f was told mine was great,and got very little
constructive criticism.
What fell short for me during my time there, was the F8 ads experi.She grazes over how to
pick an audience. For $10K,i feel that she should be giving you at least a full hour of one on
one helping ynu choose your audience.Thare is so much to it.
►'m not a copy writer and again, they should spend at least an hour with you doing that. They
give yuu a vague guideline and you write it yourself and they go aver it.
had one sale during my time For $3,~,and in the last four months I've had 3 more for
$1,500. I have hope that I will find my right audience but they did very tittle FOR me.
like this model because it weeds oUt time wasters who want what you do, but Geoff at
Stealth Seminar does the exact same thing for $2500.
There is a lot to learn about Interneti marketing and from what I see of tiffs supposed success
stories,they are o~ky from people who basically do what he does. When I was in the group
there was about 90 paid members and some of them were coaches for the wackiest shit you
know they will never make one dims coaching anything that while I was on group calls,
could hardly keepfrom laughing.
don't get the sociopath vibe from him. He is very concerned about his reputation and
seems to want to help you but then teas ADD about it. I will say that what he teaches is
remedial compared to what I know r+ow. Its worth a grand at best.
~. REYLY

October 17,2015 at 9:16 pm
Thanks for sharing with readers the more information people have to make educated
purchases the better.7o clarify The Sociopathic Business Model"'refers to businesses
taking on the characteristics of asociopath. E donot know Russ,and am not qualified
to diagnasis him; however,it's very telling you say he's concerned about his
reputation {image) but from the reviews not concerned about the substance of his
cpmpany's work.
Anonymous sots:
Qttober 19,2015 at 1:43 pm
hitp://www.killingmycareer.00mJlhe-sociopatfiiabusiness-model/twittervad-king-russell-russ-ruffino-the-sociopathic-business-model! 27134
12/9/2015 UPDATED: Twitter Ad King Russell(Russ)f2uffino Ctlents on Demand &The Sociopathic Business ModelTM ~ KILLING MY CAREER .
What made you create this? Did you take the course or just find him offensive?
~• Melaynatokaskysays:
Qctaber 19,2015 at 4:29 pm
Funny you should ask,iYs a popular question today. His ads on Twitter
were unrealistic and when I did a little research found they weren't only
unreal istic they were fraudulent & predatory in na#ure. One of the
purposes of the is site is to help consumers make decisions based off facts
as a means to avoid becoming victims of unethical &illegal corporate
behavior. I've never spoken to Russ Ruffino,ar spoken to one of his
minions; but, I do get regular calls and emails thanking me and more
importantly to the brave commenters who exposed the negative truth
Ruffino would rather remain hidden.Thanks far reading! Melayna
NCPLY ~I
Anonymous says:
November 5,2015 at 10:06 pm
i was a student of his course.'To make a long story short, I was very dissatisfied. l once asked
far a 5 minute cakl to ask a question one an one,and I was turned down.His strategy will
work for those who do not value an ethical way to do business. His business model he
teaches is stammy,he uses high pressure sales tactics,and does not offer any guidance
other than watching his videos and having you atkend group sessions with 90 people on at
once. IYs not easy to get any true coaching• I invest in self development as much as I can
because I am a learner and am always seeking to grow at a rapid pace. f feel more sorry for
people who are coughing up money that they don't have, putting that lOk bill on credit to
try to learn practices that are unethical. As for me,I will take the little I learned and say it
wasn't worth the money. I would never recommend his course to anyone.
------
Rer~v

' Thank You for taking the time to comment and helping people make better-informed
decisions.
Job says:
There's alwaystwo sides to every story.
Mefayna Lokasky says:

http://www.killingmycareer.com/the-Sociopathiabusiness-modeUtwiUer-ad-king-tassel!-toss-ruffino-the-sociopathic-business-model/ 28!34
MadelTM ~ KILLING MY CAREEF2
't2/912015 UPDA7Ep; Twiger Ad King Russell (Russ)Rutfino Clients on Demand &The Sociopathic Business
Only one side of truth and this guy appears the on the opposite side more often than
not.
REPLV
Anonymous says:
Yes, Joe -there are two sides.let's review:one side says Russell misleads a majority
of his clients f~to paY~ng too much money for false promises and the other side
(Russell)is making a dot of money doing it and doesn't like that the other side speaks
honestly about theif negative experiences with him.
Transparency is everything and the only recourse people have having been abused by
Russell's scam-y tactics is to speak out so that no one else fails prey.
REPLY
James says:
Hmm....A lot of Russ bashing going on here. I'm not nearly as jaded as others though...
read his article in 1 NC magazine last week and that was the first I've ever heard of him.
Since then I've read his posts,listened to webinars & podcasts,and just had a sales call
today with a woman from his Clients On Demand company. I liked most of the info and
found the strategies, processes and ideas generally pretty good. Even the sales call was
decent and helpful. Yes,it was overly scripted... Which is probably why It lasted 90 mins
instead of 45, but I did learn things and was offered real feedback.Yes,there was the typical
"buy now'and save $5000 at the end, which I found dumb but understand why they do
ihat... They want your commitment,they want the sale! It's $10k if you buy within 24hr,
otherwise the price goes up to S 25k,That technique isn't my style, but to each his own.
didn't buy the course since our company is crazy busy this time of year. I've been a partner
in a marketing agency for tfie last 12 years and we are already successful doing regular
strategy,design,digital m~d~a,advertising management,etc.like normal companies in our
industry. But we are stuck on a hamster wheel of working by the hour. Business owners are
always frying to improve Shings, and making more money AND working less are pretty high
on the {ist, Russ'teaching on leveraging your expsrc knowledge and packaging it up as high
quality onifne courses,supportecE by group Q&A sessions,smalls,and private Facebook
groups seems like a great way for our company to gofrom revenue of 5 figures a month to 6
figures a month. it struck a chord with our 3 agency partners. We plan to implement the
ideas with or without his course. I do wonder ff we should buy the course in the winter?
Would we reach our goals that much faster? Not sure. As an agency we already know how
to run Facebook/Twitter/Google ads,set up landing pages,and f've had 1000s of sales calls.
Webinars are a bit new since we don't really use them now,but they seem simple enough,
As for building an online cpurse, we do stuff like that everyday.I'd be curious to know from
those who have been through the course if they'd recommend it to us?
1 am pretty sure about anC thing... His course isn't for startups or people looking to break
into Internet marketing,or change careers. You have to be already an expert in something
and used to selitngyour services to people one at a time. He says this in the very first
webinar actually, If you or your company isn't generaking at least $10k/mo.+n old fashioned
consulting services, I don't see how any of his strategies will help. Maybe this is part of the
negative feedback - it was a mismatch from the start?
As for the fake "as seen on ~~W York Times° etc. l have no idea. IY could have been a bunch
hrip:l/www.killingmycareer.comlthe-sociopathlo-business-model!twitter-ad-king-russeil-toss-tufflno-the-socEopathic-business-modeU 29!34
12/9/2015 UPDATED: Twitter Ad King Russell(Russ} ftuffino Clients on Demand 8 The Sociopathic Business ModelTM ~ KILLING MY CAREER
of free directory I istings he was listed in. Stupid to try to use national news website logos to
build credibility when the I istings are mostly empty pages. i could probably go create a
Wikipedia page all about myself too,then claim on my website,"as seen on W iklpedia, the
world's 2nd largest website."Maybe people would think I'm someone special?; ). I've seen
much shadier khings in business though. kooks like he doesn't use the logos anymore.
Anyway,2sides to every story.
RFPIY...
Melayna (-okosky says.

i will certainly give It to you on the shameless front:" I read his article in tNC magazine
last week and that was the first !'ve ever heard of him."
It's not an article IT'S AN ADVERTISEMENT
The Marketing Myth That fs Killing This

Generation of ... - Inc.com
Inc.com > empact- > ihe-marketing-myth...
Mobile-friendly -Nov 2, 2015 -Advertisement.

Russ Ruffino. This is a guest post from Russ
Ru~f~n~, founder of ~fi~nts on Demand.
This is known as native advertising designed to trick readers into thinking it's an
article. Also, note the deceptive Killing in the title to try and combat his truthful
negative SE(7 from this site, Killing My Career.Shameful and transparent.
"Anyway.2 sides to every story," again only one side to truth and he's still not on it.
Why wau3d someone who claims not to have taken the course come here and defend
him,especially when so many comments are to the contrary? It's also very teilin$ that
all of a sudden thre6 people within the last Few days have come here to defend him.
Move along minion of Russell Ruffino's.
~- --
REPL'/
Anonymous says:
Hi lames,I took Russ'course Spring'15 as a newbie.
I'd say if you already know how to run FB/TwitterlGoogle sdsand direct to a fancfing
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12/9/2015 UPDATED. Twitter Ad King Russell (Russ)Rutflno Ciienis on Demarsd &The Sociopathic Business ModelTM E KiLIlNG IutY CAt2EER
page,you don't need Russ'course. As mentioned above,the actual trafficcoach and
ads training is incredibly basic.
They do a sales module toa where they give you a script for how to self someone and
it's literally the script they used on you when you called in - Lpl.So just call in again
and record the tali G~
You're also right that the webinar system is simple and i was a bit disappointed at how
simple Russ'webinar module was.
It's basically one video of him going through his webinar that you probably watched
from his landing page (it's publicly available and runs on autopilot every hour} and
explaining how you should also use his framework and language - "just adapt it to
what you do" is their guideline.
Anyone can do that regardless of if their In Russ'course.
This has been mentioned in this thread before but Geoff at Stealth Seminar is a Sreat
resource for free and fairly priced webinar personal toachingwithout too much hype.
1 haven'tused his paid service personally (because I didn't have any money leftover
after Russ was done with me), but his free webinar training was just as he(pfui as Russ'
paid stuff.
t don't mean to be harsh, but looking at the content of Russ'course objectively it

almost feels like an Udemy course that would be priced at $299 and only purchased if
bought at a huge discount. I say that because their apAroach to sales,copy,ads,
webinars feels so surface level and generic. Almost like an intro course to a real
marketing program.
Russ and his team seemed like good people on the sales cal!for me too, but iYs only
after you've forked over $10k+and signed their contract that guarantees that they
keep your money Yhat the holes in their system become apparent.
All of a sudden you can't actually get one on one time with Russ or any of tine coaches
besides their sales team. You become less of a priority because nothing is an the {ine
for them (they have rto skin in the $ame as Melayna says)and you feel I ike you're
getting generic gu Idelines without any customer service at the level you would expeet
at this price point.
When I was in the course there were about 90 members and about 2-3 got a reef
return on investment during the course, I noticed that those 2-3 were the ones that
kind
Russ blasted out Co his FB followers and email I ist, while the rest of kind of us just
of silently suffered so I think you're right there's a huge mismatch in messaging and
expectations.
observed that the 2-3"successes" in our group had established businesses(real

estate and financial services)to begin with. Not to say a newbie can't make 1-2 sales,
it's just not going to come from the ads-webinar model.It usually comes From just
what
directly reaching out to your current network and testing the market.But again
part of this can't be done for free?
That
If you have any questions feel free to comment here and I'd be happy to answer.
goes for everyone who has a question about Russ' stuff (:
REPiY
James says:
November i8,2015 at 12:16 pm
Thanks for your review and break down. Very helpful for us!
eU 31f34
http;Rwvrx.kiUingmycareer.com/the-sociopathio-business-modeUtwitter-ad•king-russeli-n~ss-ruffino-the-sociopathfo-business-mod
12!9!2015 UPDATED: Twitter Ad King Russell ~F2uss) Ru~no Clients on Demand &The Soc(opathic Business ModelTM ~ KILLING MY CAREER
Cheers,
lames
James says:
Wow,are you ever quick to judge Melayna! I'm not a"minion"of anyones. l just a guy calling
it as I see it. Go to my agency site,.. http:1/www.twincreekmedia.com. I am who I say I am.
Sometimes people really are telling he truth - amazing eh?
Ya,it's weird I suppose that 1 commented on your site but it's because of the overwhelming
negativity that seemed one-sided, when 1 have had a(very short) but good experience so
far. That's it.
AEPIY
Anonymous says:
November 18,2015 at 1Q:49 am
Hey James,I just responded to your above post,so I hope that was helpful.
With regards to NEelayna,she's right that there was some fishy posts in succession the
past few days that were written in the way Russ writes himself,so there was a good
chance you were part of that crowd. No hard feelings(:
And thanks for keeping up the good work,Melayna.7his is the first site of iYs kind
that I was able to come to after feeling abused by Russ' program. You're commitment
to keeping up with how service providers online are changing tactics etc does not go
unnoticed and is much appreciated.
actually though that INC article was a real guest post! Hah!
REPLY

The fishy posts I might add are also followed with an onslaught Spam attempts in
the last few days. I'm not saying anyone that posted is linked to Spam,I have
Spam attempt tPs but 1 don't believe in coincidence,fact based evidence over
time has taught me not to.Thank you very much for your kind words and
support,it is greatly appreciated-Mafayna
ueP~v

James, you're confusing fact, which differs from your opinion or your exper~errce. w+th
negativity. The facts are he's deceptive. He doesn't use the "logos" anymore because
he was called out about it. If you read the comments several people purchased the
program based on the {ogos thinking he was actually on legitimate stations, he wasn't.
Yau refer t0 the latest as an "article" as do people on twitter and he NEVER once
http:!lwww.kiUingmycareer.comlthe-sociopathic~business-mode!ltwitter-ad-king-russell-nass-ruffinathe-sociopathio-business-model! 3?J34
12/9/20 5 UPDATED: Twitter Ad King Russel!(Russ) Ruffino Clients on Demand 8The Sociopathic Business Model*" ~ KILLING MY CAE~EER
~
corrects them. I write about fraud it's not negative it'S reaiity.
Anonymous says:
December 3, 20~5 at 12:57 am
Thank you so very much for ali of this information.Thank you to Melayna as well as
everyone who commented with their honest experiences. You all saved me a boat load of
money and I appreciate it. t was just about to follow up on this as a potential avenue for
business growth.When I typed clients on demand"into Google,this page was the third
result that came up.i read every word and now know to look elsewhere.Thank you again!
RL EP~Y J
Y,lfi'~j~~'~f ^~\ ..
li~~'i ,.::~ ~J . ~
Anonymous says:
'`;ik.
December 8,2015 at 2:49 pm
feel the same way as the above comment.Thank you so much to this site and to ail of
commenters. I was on Russ'ema{I list and he has been sending out yet another "inc article" :.,..
of his, but Because of this article 1 know that he's just another slick Internet marketer who
promises the world with nn substance to back those promises up. l just unsu6scribed from
Russ'list and I suggest everyone reading this thread get as far away as possible from Russ'
marketing as possible. It is evident that it is all smoke and mirrors anyway. Good riddens!
'r;.
REPLY i.f'~,~ l ~,i
;~,~..~pL
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12/9/2015 UPDATED; Twitter Ad King Russell (Russ) Ruffino Clients on Demand &The Sociopathic Business tNodel^' ~ KILLING MY GAREER
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SUBSCRIBE HERE! ~ q Search... , RECENT COMMENTS

your cma~i; Anonymous on U PDATEQ:Twitter Ad
i Enter emaii address..,
pemad &The Sociopath Blusnesn
Model'"
~~
Melayna Loknsky on FC1A Friday Fraud
Round-Up:Johnson & Johnson, NxThera,
Allergan &Pfizer
derek stocker on FDA Friday Fraud

Round-Up: Johnson &Johnson, NxThera,
Altergan &Pfizer
Lana Keeton en FAA Friday Fraud

Round-Up: Johnson & Johnson, NxThera,
Allergan &Pfizer
hitp:!lwww.killingmycareer.comJthe-sociopathiGbuS!Hess-modeUtwitter-ad-king-russeil-russ-ruffinathe-soc(opattiic~business-model! ~J~
;~~ "• ~, clients an demand ya
AI! News imac~e5 Shopping Videos Mare - Search toa15
About 218,000,000 results tA.39 seconds)
Clients on Demand: Home

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THE RlGFiT CLIEtdT5. Attract 15-~0 potenti~f cttents a day withauf bfogging, YouTube,
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... about working at Clients On Demand. Join Linkedln today for free. See who you
knave at Clients On Demand, leverage ypur prgfessional neiwork, and get hired.
Russ Ru~na
https://rvssruffino.coml
Let me ask you ~ question, Do you want to dramaticAlly raise your prices and have your
cEic+nts THANK YOU you for i3? Sounds fantastic, right? Well, what ii they ...
UPDATED: Twitter Ad King Russell(Russ) Ruffrno Clients ...

www.kitlingmycareer.comJ..Jtwitter-ad-king-russell•russ-ruffino-the-soci..,
Jul 7, 2015•Updated Jufy 9, 2015 Before arced Acxountability: Russell {Russ) Ru~na
of Clients on Ommand fraudulently used network talevislon and ..,
Clients On pemand review - YouTube

https:/Jwww.youtube.com/watch?v=88NoPQBYb_A
a ~ Mar 5, 2015 - Uploaded by Russell Rufiino
! htlp:/h+~vw.russtuftino.Gom Jason reviews Muss Ruftino's Clients
On Demand workshop.
Clients on pemand Manual(no fluff included)

darkpostproflts.com/fb-adslcUents-on-demand-manual-no•fluff•includedl
Got something REALLY cool for you... i've wriUen up the EXACT system I use in my
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Clients on gemand ~ ~runch~ase

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Clients on Demand is the most relia4le Giant attraction system in the world, wHh
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Tn.~sted Advisor ~ When Clients C?emand Pace Cuts

irustedadvisor.romlarticleslwhen-clients-demand-price-cuts
"A long-standing ci3ent came to us and said our price was too high for a job we quoted.
They said one competitor was priced 20°!o below us, and another 30% ...
Clients - Camerstone OnDemand ~ CSOD

https:JMnrnv.comers2oneondemand,coMcUe,.. - Cornerstone Qnbemand, tnc.
Happy Clients. • ^Cowa~VCers engage in self-directed learning on their own schedules."
View story ~ "Comsrstona helps our staff understand where ...
'r ~• 1 N5S CUffIT10 y :::
a
Afl News Shopping Videos Images h♦ore • Search toots
About 82.900 results (0.29 seconds)
Russ Ruffina
hitp5:1/ruseruNino.coml
Let me ask you s queslion. Do you want to dramaticcslly raise your prices and have your
Gients THANK YOU yov for lt? Sounds fantastic, rigM7 WaEI, what iS they ..,
Russell Ruffino (QRussRuffino) f TwiEter

hitps:Ntwitter.camlRussRuffino ~
2 days ego - Viow an 7wiitor
t,IVE on #Periscope: How to create a webinar that SELLS {pars 3) akatch
www.periscopo.tvhvlaTwBFT...
UPDATED: Twitter Ad King Russel!(Huss) Ru~no Clients ...

www.killingmycareer,comJ...ltwitter•ad•king•nisaell-ruse-roNino-the-soci,..
Jur 7, 2pt5•UPDATED; Juty 9,7015 at the very bottom end pieaso be sure an check
nut the honest negative customer feedback about Russoli (Rusa~ ...
Russ Ruffina Dive - Facebook

httpsJlwww.facebook.com/RusaRuHinoLive!
Russ RuHino Live, Los Angeles, California. 70301 tikes ~ 252 talking about phis. We
show coaches and consultants I~ow to command premium prices, attract...
Russefl Ru~no ~ You7ube

https:lMrvrw.youtube.com/userlRussRuftino
welcome to lno otflcial Russ RuflSno YouTube channel! Here, 1 shsrg my bu5inoss
oxpurtise on sales, Uaff+c, and leads, as well as testimonial videos from th...
Russ Ruffino Tells Entrepreneurs ko Go an "Autopilot" for the ...

finance.yahoo.cnm/.,./rasa•ruffino-teils~antrepreneurs•au... ~ Yahuo? finance
Jun 20, 2014 -From Yahoo Finance: Internet marketing expel Rues Ruftlno was
recent3y featured on Influencers Radio to discuss h15 success in taming ..,
Russell Ruffino ~ i~inkedin

https://www.ilnked in.co~r~Jruasn+ffin o
Greater Los Angeles Area • Owner at RuKno CI(ents On Demand - www.tussruNno.c~m
Viaw Russep itutflno's professional profile on t„inkedln. l,inkedln is the world's largest
business naiwork, helping professionals Ilke Russell CiuHino rfisoovcr .,.
HON~Sl' REVIEW:The Money Tree Methoc{ by Russ Ruffino ...

www.waniorforum.com ~ Warrior Forum Classified Ads
Apr 12, 2013 -27 posts • 11 authors
My honest review ol't'he Money 7tee By Ruas RuNino For those that don't know ttis or
my twsiness, I design, bulltl and than seq websites in my ...
Mow to Build a 5250,000* Into-Markeling Empire This .,. 5A posts Apr 1, 2013
Rasa Rufiino ~ndioss Troffic Tap? -Warrior Forum 3 posts Dec 30,7412
More results from www.warciorforum,com
Choose your appaEntmenttime -Russ Ru~no

www.clientsondemand,cc~mllp/appointment)
Hero's What Our Ciaents Have Been Able To Achieve."For God's sake, these results
L
TimeEine
_.~.........o
Killing My Career
december 13 at 11,59am • b~
FRAUD ALERT: Business Insider &Inc. Magazine are unethically posting

this AD by marketing #r~ud Russ Ruftino wn~ falsely implies this is an article
in these publications, it is PAID Native Advertising. Do your research
(GoogOe ai a minimum) before spending money on image-based marketing
programs and avoid being a victim of those who ~mplay tactics from
#TheSoCiopathiCBusinessModel. #TheMMpiHerMethod
#MMpiHerMarketing
My str~.t~~ ~~or turning $~5,oc~o into $2oc~,000 ~v~r~

monfih
target p~apl~ based on ~~rhether they have the specific problem that my product
solves.
BUSSNESSINSIDER.COM
~;~
''~
i Like Comment r~ there

`~ Killing My Career via Russ Ruffino Live `
~ Dumber 14 a15:~5prn
Be sure and check the Kitting My Carer website and read real customer
r~vievws of Russ Rut(ino's Clients t7n Demand, buyer bewarE.
#TheSociopathicBusinessMadel
Ho~v fio Attract New Clients, Anytime You Wand

Flow to attract 5 new clients by the end of Ehis week... (without spending a DIME on
adv~riising+}
VWd1tiJ.Cl.I EN7SON DEPAAN~.CUIVI
~~
ib l~k~ Comment ,c~ Sh~r~e

Kjiling My Career via Russ Ruffino Llve ,'
Osc~smber 12 at 9:a4arn ~ ~
#Fraud alert
~~vv ~o attract I~ew Clients, Anytime You Want

HaYr to attract ~ neav clients by the end of this creek... (without spending a DIME on
advertising!)
W4~lW.~LIE~JTSON D~f~A~N~.C()1vl
t
~u
cb L1ke ~ Comment ~ Share

Kitlln$ My Career
November t ~ at 12:43am • ~
If you're thin~~ng about bu}+ing ~r~y marketing program from #Ru~s~ellF{uffino

Russ Ruffino Live Russ Ru~no Eli#e VIP Coaching based on something
from Inc, Magazine it's NOT an artiste but a PAID AD. #NativeAdverlising is
deceptive much fike #RussRu€fino. httpJlwww.killingmycareer.com!
.,.ltwitter-ad-king-russell-r.../
The Marketing Myth That is Killing This

Generation of ... - Inc.com
lnc.com > e~npact- > the~marketing-myth...
Mobil-friendly w Gov ~, X015 - Adverti~em~r~t.

Russ ~tu#~~no. This is a guest past from Russ
Ruf#ino,founder ~f Clients an Oem~nd,
~-
ib dike ~ Camrnent ~ Share
r
7 211612015 My strategy (or turning $15,000 into $200,000 every month -Business Insider
Recommended For You

Comments
Eton Music just made an incredibly
Insiders Q Alf Comrllents Q ~ '~~ important point about solar ener9Y
~~
'Mark ~n a9r, 38 ~ tài
12, 11:19 PM said: ~~~
It's a business that gets people to pay money to learn how to business,
just like he businesses. You know it works because his business is
teaching business to people who dnn't knew h~nv to tyusiaaess. I.ear~i
how to start a business teaching people that don't know how to
business how to business.
Reply
killingmycareer on Dec 12, 11.32 PM said: qq ~' 1 '~

t~
Is Business Insider just as unethical is INC, where Videos You May Like
this AD firs# ran? This is PAID native advertising and deceptive
towards potential clients, who if you Goggle Russ Ruffìno's name, will ~ )~ F ~" ti
find many unhappy clients. #TheSociopathicBusinessModel ~ r
Reply ' /~
•- ~ The model who quit Jim Cramer reveals

Instagram says she the secret to
RebeccaNY on Dec 13, 9:45 AM Said: ', 21 ~ ~ ``~ felt pressure to flaunt surviving on less
her sexuality ai age than 4 hours of sleep
Wow this Russ Ruffino guy is a total fraud.. ~ --
~,,,._
And shame on BI for nit placing an advertising disclaimer on this pile ~~,,,~.
of crap.. could you at least *attempt* an effort at journalist ethics? ''~~
Reply ~ An Iranian actress There is a secret US

who posted government airline
. . ... .. .. .. ......•.. -. instagram photos of that flies out of
17 ; ~ ~ ,,;~ herself without a commercial airports
AdamF~ on Dec 13, 10:71 AM said:
L-~-.~~ by Taboola
This sounds like that old newspaper ad scam.

"Send in $5 and I'll show you how to make $i,000s advertising in the Sponso~vd Uy
newspaper." The buyer would then get instructions that said "Place an ~ Markets INDICES ~~~~~~~~.~~.r ~t~s
ad in the newspaper that says: Send in $5 and I'll show you how to
make $i,000s advertising in the newspaper." srocKs
Reply . ~~`N 17,698.41173,501.00%

Jones
Nasdaq 5,051,50 56,141.10%
Imo Ponzi on Dec 13, 11:04 AM said: ~
g in
I ~~ S&P 500 2,066.43 23.021.10%
=~
FTSE 100 6,061.19 43.4Q 0.70%
Send in $5 and I'll show you how to make $i,000s
a~ _ 10,469,26 18,$3 Q.20%
advertising in the newspaper.
112
http:l/www.businessinsider.comJmy-strategy-for-turning-15000-inta200000~very-month-2015-12
72/16/2015 My strategy for turning $15,000 into $200.000 every month -Business Insider
Note my scheme is totally legit. CAC 40 4,624.67 10.270.20%

Yours sincerely Nikkei 19,n49.914$4,Q12.60%
MrI.M.A. Ponzi. Hang 21,701.21426.$42.00%
Seng
Reply 5.830.20%
3,516.19
CortlpoSite
Zau on Dec 13, 11.43 AM said: g ^~
YVhat a crock of shit!!t Russ Ru~no is the new MORE IN MARKETS ~%~e~~~~~~~+~'
I7on I..apre! The ONLY person that'll make money off of his bullshit
advice is himself. Anybody that listens to him is a foal!!!!!
,.—.--,
Reply
• '•
i r j~~ ~~:~'`.
This Startup Wants
To Tum Your $5K
Into $2.5 BilEion
Businoss ins~dcr ~ Fundn:x~
http:/Iwww.businessinsider.coMmystrategy-for-turning-15000-into-200000-every-month-2015-12 zl2
12!9!2015 The MMpiHer Method TM' ~ KILLING MY CAREEf2
,. ;:. ,.... ,
HOME ABOUT CHIP ON MY SHOUIQER THE PRINCE THE SOCIOPAiNIC BUSINE4 MODEI"' THE MMPIHER METHOD T° TRENDING
---~ W~_____~.~_...__. _.._ __. ~..,_.......__-.._.__.- _ ___.- ___._
THEMMPIHERMETHODr'"
The Solution
Having identified the problem it's equally important to recognize and support those who are part of the soluSon . Social Activism Marketing to bring
awareness to worthy cause's ume has come; and,society tl red of fraud the hopelessness it treates has the ability m hold both b1g business and big
government accountable like never before with social media and chose who hel p orchestrate i[ ,like Jane Akre. Change truly can start with one person
who can enlist the help of many.
My experience, as I've said is much bigger than me; and, prompted the creation of my own company m work with (nor for-a subrte yet r+ecessory
distinction) to hold those responsible for fraud accoun[able while being partofthe solutlon through positive change.
MMpfHer Method T•(pronounced Empire, i, a three month sales, marketin g and management program designed to Increase your companys
accountability, productivity, marketability and profitability--ethlca!!y. in short, nobody wins untll everybody wins, which is also the company motto.
MmpiHer Method's'" proprietary system, working with your entire taam, dete rmines the necessary changes (first month), helps to fully Implement
tho se changes(second month ), and provides the necessary cool s for your Ueam to become self•sufflcient while successfully replicatlng the process
(tni rd monm ). Our dam is a resource for life, and the quarterly tune ups, will help your oeam quickly identl fy, and ~x potenu al weaknesses before
they become problems,
The MMpiHer MethodTM permanend y and drasd tally improves the overall work environment, regardless of Industry or tie size of the company. The
beta test* 1.5 years after the prpgram:
0 40% Total employee accountability increased

0 2546 Tocai employee productivity increased
0 45% Company marketability increased
0 3096 Total revenue increased
0 9746 Total employee retention
0 45% Positive customer feedback
0 10096 Current employees recommend their company as a great place to work
*Results from hard data and or Independent anonymous empl

Q oyee survey from large medical provider group multiple offices muliple providers.
MMpiHer Methodr"
o Recognizes the Importance of properly trolnJng manages,

a Addresses, reduces and prevents the high cost ofemployee turnover.
o Reduces and eventually eliminates negative or iJlega! behovior wirhin the company.
http:/lwww,kiliingmycareer,comlmmpiher-method-2/ ~~2
12/9/2015 The MMpiHer Method T"" ~ KILLING MY CAREER
o The design of the program protects. both employees and empfoye~s by adding mutual increased accountability, ethically.
o Continually and quickly Incorporates changes while testing the webstte during each phase of the three month build. This process ensures aif areas of
the business will be able to support the website, quickly adapt to changes, and identify and Flx problems as they arse,
o Proprietary program quickly Identifies areas of pro~tgrowth, while uniquely engoging al! employeesfor implementation; and providing the
necessary tools to replicate successfully.
Contact: Info@mmpiher.com or visit the site for more details www.mmpiher.com
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Your email: Anonymous o~i UPDATED:Twitter Ad
King Russell iRuss) Ruffina Clientson
1 Emer email address,.
~_.~
` J
pemand &The Sociopathic Business
Model'°
Melayna Lokosky an FDA Friday Fraud

Round-Up: Johnson & Johnson, Nx7hera.
Allergan & Pfizer
dcrek stocker on FOA Friday Fraud

Round-Up: Johnson & Jolmson. Nx7t~era,
Allergen &Pfizer
Lana Keeton on FDA Friday gaud

12o~nd•Up: Johnson & Johnson, Nx7hera,
Allergen &Pfizer
http:l/www.kiliingmycareer.comlmmpiher-method-2/ 2~2

Filed Complaint and Application For Injunctive Relief

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MICHAEL k.

19 herein. ABC PARTNERSHIPS I -10; XYZ CORPORATIONS 1-10; and DEF

19 18. Defendant has intimate knowledge of search engine optimization ("SEO")

23 personal financial gain, Defendant is clearly obsessed with Plaintiff.

18 soliciting clients to employ Defendant as a consultant.

19 different people10; yet, Defendant still maliciously portrayed Plaintiffs as having an

Website was designed to further Defendant's character assignation of the competition

14 away from Plaintiffs.

19 40.Throughout the various Posts, Defendant wrongfully calls Plaintiff a fraud,

HuffingtonPost publication at the very least. Such conduct

l~ instead of providing any logical rebuttal, Defendant simply resorted

19 to falsely claiming that "many" of Plaintiffs clients "clearly

7 owned or operated any companies with a history of consumer

11 another where he provides free advice for non-clients. Aiaintiff is

11 decisions before investing." Defendant retains the image on her

misleading statements, because Defendant falsely implies that

23 not limited to, the following:

7 November l8, 2015, at

23 B. On December 13, 2015, Defendant posted "FRAUD ALERT: Business

19 Defendant republished False Statements in the BI Post:

18 52. Defendant routinely encourages existing clients of Plaintiff to cease

19 participating in Plaintiff's program, seek to have credit card companies issues

2 charges it any have been made."~~

55. Upon information and belief, Defendants, as joint tartfeasors, acted in

2 ~ well a~ misleading and deceptive.

Defendants, Defendants made false f~~ctt~~l stak~:m~nts in a commerci~.l advert~seinent

19 Statements to enter interstate commerce.

22 Statements, which contain literally false factual statements, it is presumed as a matter of

W ~ p M 14 conduct in the future, an award of punitive damages should be awarded against

19 pursuant to 15 U.S.C. § l 117.

lU 85.The False Statements made by Defendants constitute defamation per se and

19 general damages are presumed as a matter of law.

2 aggravated, outrageous, and guided by evil motives wherein Defendants intended to

?~ prospects, and loss of competitive business advantage; opportunity, and/or expectancy.

99. The False Statements are about and concerning Plaintiffs.

19 causing harm to the reputation and economic interests of Plaintiff.

23 in which Plaintiff would be placed.

?~ relating to their business.

~5 do business or with whom Plaintiffs may reasonably expect to da business. This

2 ~ suffering, anguish, ancf loss ofself-esteem.

19 COU1~T VII —CONSPIRACY

existing and prospective business relationships, cause Plaintiffs severe emotional

23 substantial risk of significant harm to Plaintiffs.

19 F. For punitive damages in an amount to be proven at trial;

20 G. For Plaintiffs' cysts herein incurred;

24 statutory rate from the date ofjudgment until paid;

EZESPECTFULLY SUBMITTED this 22nd day of December, 2015

UPDATED: TWITTER AD KING RU55El.1.(RU55)

UPDATED November 18, 201 S

The Marketing Myth That Is Killing This

Mobile-friendly -Nov 2, 2015 -Advertisement.

Russei~ Ruffino buys an ad in tnt Magazin@ {example of native advertising}

May 21, 201 S

Famlly Wealth Planning Inskftute, LLC

(a!awbizmentors ~■~ PlaiNlff~

SF.MNP nMf.N(>F.P C(1MPIA1t

~FH~~!] How To Buid a Miilipn wd

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Russ Rufflno and The Nev~York Times

HOR1E PAGE I TODAVS PAPER I V~OEO 14Dg? POPU./~A I U-$. ~dfUOfl ~

p °:~`•' ~'8t SOFT SKIN

Box Olitc~ Top'3 Go Od ~~K~ ~ap+Y ■

~. Pitth Perfect ftU55 RUFI~WO FILMOGRAi~l1Y: HAS WORKED WfTN:

Defendants, Defendants made false fcttl stak~:m~nts in a commerci~.l advert~seinent