• Report: #1172076
Complaint Review:

GoDaddy Operating Company LLC

  • Submitted: Mon, August 25, 2014
  • Updated: Mon, August 25, 2014

  • Reported By: Costa Rica Whistleblower — Heredia Arizona
GoDaddy Operating Company LLC
14455 N. Hayden Rd., Ste. 219 Scottsdale, Arizona USA

GoDaddy Operating Company LLC Domains by Proxy LLC Pepperball Technologies, Inc. Fraud Websites Hosted With Full Knowledge of Fraud - Then Owners' Identities Protected for a Fee - Co-Conspiracy to Defraud the United States Government Scottsdale Arizona

*Author of original report: Qui Tam Warning - Looking For Attorney

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Federal Bureau of Investigation
Phoenix Field Office
21711 N. 7th Street
Phoenix, AZ 85024
Homeland Security Investigations
SAC Phoenix
400 North 5th Street
11th Floor
Phoenix, AZ 85004
The United States Attorney’s Office
District of Arizona
Two Renaissance Square
40 N. Central Ave., Suite 1200
Phoenix, AZ  85004
Federal Trade Commission
Office of Inspector General
Room 1110
600 Pennsylvania Ave., N.W.
Washington, D.C. 20580
Internet Crime Complaint Center
FBI Headquarters
935 Pennsylvania Avenue, NW
Washington, D.C. 20535-0001
Federal Communications Commission
Office of the Inspector General
445 12th Street, S.W.
Room 2-C762
Washington, D.C. 20554

In Re.:  Criminal Complaint of Knowing and Willful Co-Conspiracy by GoDaddy Operating Company LLC and Domains By Proxy LLC to Defraud the United States Government and All Worldwide Customers of Advanced Tactical Ordnance Systems LLC (ATO) (the impersonator of the Defunct Pepperball Technologies Incorporated). [continued below]....


To Wit:  Company Policies Constitute Federal Criminal Felony Offenses in the Continuing Domain Registration, Website Hosting, and Concealment of the Registrar of the Fraud Website www.pepperball.com

Criminal Offenses: 18 U.S.C. § 2. Principals, 18 U.S.C. § 3. Accessory after the fact,18 U.S.C. § 4. Misprision of felony, 18 U.S.C. § 371. Conspiracy to commit offense or to defraud United States, 18 U.S.C. § 1343. Fraud by wire, radio, or television, 18 U.S.C. § 1956. Laundering of monetary instruments

August 11, 2014

Dear United States Government Officials:

We are writing to complain that the services rendered and the company policies of Go Daddy Operating Company LLC and Domains By Proxy LLC constitute criminal offenses as they pertain to their customer Advanced Tactical Ordnance Systems LLC (ATO).  Those companies do not enjoy immunity in any fashion, and their policies represent a threat to the public welfare and security of all victims of website dependent criminal schemes.


The company PepperBall Technologies, Inc. (PTI) began operations in 1999 and ceased operating on January 9, 2012.  We were their reseller in the Republic of Costa Rica beginning in mid-2009.  Last year a public tender was issued by the Costa Rica Ministerio de Justicia y Paz for $ 600,000 in non-lethal weapons for the prison guards at La Reforma prison.  It turned out to be a disaster due to a fraudulent bid submitted by a Costa Rica business.  In a lengthy public comment period we learned that one of our USA suppliers in the bid had decided to support the Costa Rica fraudulent bidders.  In the end the bid was won by the fraud. A Costa Rica business known as Industrial Fire and Rescue Equipment, S.A. (IFR) then sold 162,000 counterfeit PTI projectiles supplied by ATO to the Ministerio de Justicia y Paz of Costa Rica.

This experience caused us to do extensive research into the USA suppliers in preparation for a fraud lawsuit.  During that research we learned the following:

  1. The company PTI did not manufacture their own products.  They used Perfect Circle Projectiles LLC in Lake Forest, IL to make the pepper balls.  They used Tippmann Sports LLC and Tiberius Arms LLC in Fort Wayne, IN to make their launchers, as key examples.
  2. PTI was in financial trouble and had a lot of debt with insufficient cash flow.  They had lenders who wanted out.  It came to an end in January 2012 when their notes were allegedly foreclosed upon.
  3. As part of a very detailed conspiracy to criminally impersonate the defunct PTI, two former employees in San Diego, CA, and the owners of Perfect Circle Projectiles LLC and Tiberius Arms LLC did the following:

(a) Fraudulently renewed PTI’s GSA Advantage contract.

(b) Maintained the Yellow Pages phone book listing.

(c) Formed a new legal entity “Advanced Tactical Ordnance Systems LLC” to receive sales proceeds under the Assumed Name “Pepperball Technologies” in Indiana.

(d) Made false USPTO trademark applications and renewal applications.

(e) Renewed and revised the website www.pepperball.com.

(f) Continued to use the credit card access device of PTI for sales transactions.

(g) Registered the closed PTI in the US government SAM System.

(h) Made numerous entries in the Dun and Bradstreet system to create false affiliations of ATO with the closed PTI (this continues to be done now in response to our reports).

(i) Registered ATO in the SAM System to create the deception of competition in government bidding.

(j) For around 6 months kept the old PTI office open on Nancy Ridge Drive in San Diego until a new tenant moved in.

(k) Personally impostered as PTI employees to sell and conduct training to law enforcement.

(l) Personally impostered PTI employees to make sales and training at the Republican National Convention in Tampa, Florida in 2012.

(m) Personally impostered PTI employees at a booth at the 2014 SHOT Show.

(n) Personally impostered PTI employees to travel and make sales efforts in Egypt, Panama, and Peru.

The items are ordered, the order is paid for and shipped, and no one knows that (1) the “no bid sole source” PTI sale is being filled by an entirely different legal entity, (2) con-artist impersonators are posing as current employees of the closed PTI, (3) The products are counterfeit, (4) The prices are highly inflated, and (5) The products are available from other suppliers.  The perfect con has succeeded for over 2 ½ years.  The US Federal Bureau of Prisons is the largest victim in terms of sales according to sales data from the website www.USASpending.gov.


We have filed numerous Whistleblower Reports and Criminal Complaints regarding the ongoing criminal conspiracy and counterfeiting operation of ATO in Fort Wayne, Indiana.  Our website at http://imgasa.com/PepperBall_Fraud_Alert.html has complete documentation based on public records.

A number of investigations of ATO at the federal level are in progress.  For example, the FBI and the US Attorney General in Indianapolis, Indiana; the Inspector General’s Office of the General Services Administration; and the US Department of Justice (as a criminal investigation referral from the Inspector General’s Office of the US Department of Commerce (IGDOC)).  The IGDOC complaints are related to fraud upon the US Patent and Trademark Office and / or illegal exports of controlled “pepper spray powder”.


  1. On December 16, 2013 we emailed GoDaddy and WY Technologies informing them of the fraud and including attachments.  Please see Exhibit A.

  2. On December 17, 2013 GoDaddy responds to our information by stating they do not allow illegal activity but it is not their place to determine if illegal activity is happening with website content.  They recommend a report that the WHOIS information is incorrect.  Please see Exhibit B.  We wonder would GoDaddy recognize illegal fraud if the website we reported was www.FreeEbolaCure.com?

  3. On December 19, 2013 we electronically report an invalid WHOIS to GoDaddy on their website form.  Please see Exhibit C.

  4. On December 19, 2013 we send GoDaddy a few pages of our report to California law enforcement with a DVD of all reports to date, with delivery confirmation.  Please see Exhibit D.

  5. On December 23, 2013 our information with DVD is delivered to GoDaddy.  Please see USPS delivery confirmation as Exhibit E.

  6. On December 27, 2013 we received an email from GoDaddy stating the domain is correct because it is registered with Domains By Proxy.  Please see Exhibit F.  The problem with this response is two-fold.  First, the registrant was not concealed when we made the WHOIS complaint.  It was moved to Domains By Proxy as a result of our complaint.  The second is that GoDaddy and Domains by Proxy are the same owners, at the same address, with the same fax number.  (Please see the public records at the Arizona Department of Corporations website).  So with GoDaddy, the public exposes a fraud, they recommend to report it to them, then they offer to the owner concealment for a fee through Domains By Proxy.  The result of the report is that there is, of course, nothing wrong at all.  Below is the offer to conceal, and what happens after the public attempts to report a WHOIS problem.

  7. On January 3, 2014 Domains By Proxy LLC received a DVD from our company with complete evidence of the fraud.  Please see the delivery confirmation at Exhibit G.

  8. On February 20, 2014 we sent an email to GoDaddy, Zions Bank and Tower Bank in another attempt to stop aiding and abetting of the conspiracy.  Our hope was that with no website and no bank processing of payments they would not be part of another public tender in Costa Rica.  Please see Exhibit H attached.  GoDaddy responded to our threat to file a criminal complaint by stating they are “unable” to do anything about the fraud without a request from law enforcement or a court order.  Please see Exhibit I attached.

  9. On August 3, 2014 we notified GoDaddy and Domains By Proxy that the trademark pepperball had been reassigned, that they have criminal liability for the fraud, and that we intended to name them as defendants in a Qui Tam lawsuit.

  10. On August 5, 2014 we received more excuses from Domains By Proxy and GoDaddy.  Obviously they are now fully aware there is an ongoing fraud, that they are making it possible to continue, and that they have no intention of doing anything about it until law enforcement get involved.  Please see Exhibits K and L attached.

  11. On August 6, 2014 we received Exhibit M from ICANN by email.  As you will note, they are useless and have no power to stop the fraud despite the WHOIS information being completely wrong. 


This is a textbook example of internet fraud.  A fraud that is only possible with the “deliberate indifference” and company policies and services of Go Daddy Operating Company LLC and Domains By Proxy LLC.  Who can imagine a business operating in the present day without a website? 

Our research into laws and regulations of the internet found many references to the web being unregulated or self-regulating.  We disagree.  The criminal statutes relating to conspiracy and the civil Qui Tam laws apply in this case to Go Daddy Operating Company LLC and Domains By Proxy LLC.  They deserve prosecution for knowingly protecting the ongoing fraud of ATO.  On Go Daddy’s website they are very proud of how big their operation is (see graphic below).  Are they above the law?  How many more frauds are they protecting?


The fraud is in many countries other than the United States.  We have found resellers claiming to sell PTI products in Argentina, South Africa, Australia, Peru, Chile, and Panama.

Starting with Costa Rica the fraud and counterfeiting must be exposed.  Thus far one question has been common in Costa Rica when we discuss the fraud:  If the fraud has been reported, why are they still in business in the USA?

Our answer has been to point out that the legal process in the USA can be slow.  We point out that the Ponzi scheme of Bernie Madoff continued for 3 ½ years after the first reports to the Securities and Exchange Commission, and that the PTI fraud may involve as many as 35 people in 6 states.  But another reason is the website that deceives the world that PTI is an ongoing business since 1999.

Therefore, we respectfully request the following:

  1. That the website www.pepperball.com be shut down.

  2. That the primary domain name “pepperball” be seized so that no alternative like “.biz” can be used as a replacement by the criminal conspiracy or any potential successors.

  3. That within the present legal framework Go Daddy Operating Company LLC and Domains By Proxy LLC are held responsible for their role in aiding the conspiracy.

This will set an example to aid criminal prosecution in Costa Rica of IFR, and hopefully every country in which ATO has a reseller of their counterfeit PTI products.

This report was posted on Ripoff Report on 08/25/2014 05:48 AM and is a permanent record located here: http://www.ripoffreport.com/reports/godaddy-operating-company-llc/scottsdale-arizona-85260/godaddy-operating-company-llc-domains-by-proxy-llc-pepperball-technologies-inc-fraud-we-1172076. The posting time indicated is Arizona local time. Arizona does not observe daylight savings so the post time may be Mountain or Pacific depending on the time of year.

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Updates & Rebuttals

#1 Author of original report

Qui Tam Warning - Looking For Attorney

AUTHOR: Costa Rica Whistleblower - ()

This Qui Tam warning was sent.  We are seeking a Qui Tam law firm.  If we do not locate a law firm we will file a Qui Tam action in proper person.  We are also seeking to be lead defendant in a Class Action.  How many fraud websites are protected?  How many frauds continue because of the concealment of the owner and refusal to take down the website?


Go Daddy Operating Company LLC
14455 N. Hayden Rd., Ste. 219
Scottsdale, AZ 85260
Attn.: Mr. Blake Irving, CEO
Fax Corporate Headquarters: (480) 624-2546
Domains By Proxy LLC
14455 N. Hayden Road, Ste 219
Scottsdale, AZ  85260
Attn.:  Ms. Nina Kelly, Manager
Fax Compliance Department: (480) 624-2546

In Re.:  Legal Notice to Go Daddy Operating Company LLC and partner Domains By Proxy LLC of Inclusion In List of Defendants in Qui Tam Action for Co-Conspiracy and Other Criminal Offenses

Cause of Action:  31 U.S.C. § 3729. False claims.  (The False Claims Act)

Criminal Offenses: 18 U.S.C. § 2. Principals, 18 U.S.C. § 3. Accessory after the fact,18 U.S.C. § 4. Misprision of felony, 18 U.S.C. § 371. Conspiracy to commit offense or to defraud United States, 18 U.S.C. § 1343. Fraud by wire, radio, or television, 18 U.S.C. § 1956. Laundering of monetary instruments

August 6, 2014

Dear Mr. Blake Irving, CEO and Ms. Nina Kelly, Manager:

We are writing to advise that your companies have been added to the list of defendants that we intend to sue under the False Claims Act.

 On several occasions we have notified your companies that the internet domain www.pepperball.com is a fraud portal used by a criminal cabal to impersonate the defunct Pepperball Technologies Incorporated (PTI), in order to sell counterfeit PTI products to the government of the United States.

Your responses consist of mere assertions that you have no responsibility.  However, under United States conspiracy statutes your companies have criminal and civil liability as a co-conspirators.

You have (1) knowledge of the criminal fraud conspiracy, and (2) you have engaged and continue to engage in overt acts that aid and abet the conspiracy and further the criminal goals of the conspiracy.  You have no immunity under any legal theory whatsoever by virtue of your “business model” as web domain registrars, hosts, or concealers of identities for a fee.

Our legal position is that you have civil liability under 31 U.S.C. § 3729. False claims., and criminal liability for 6 of the 13 federal felonies of your customer Advanced Tactical Ordnance Systems LLC (ATO).  A chart of ATO’s crimes is attached.

We have also attached the first page of the criminal complaint we are preparing to send to every conceivable US government official with jurisdiction over your “business model”.  The full criminal complaint will be posted on our website at http://imgasa.com/PepperBall_Fraud_Alert.html and you will be mailed a courtesy copy.

Finally, we have also attached your companies’ most recent responses to our WHOIS abuse complaints.  This may be helpful for you to internally investigate your automated response system with its boilerplate answers to public complaints.

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