Category: Uncategorized

The Multiple Listing Services (or MLS) suffer from a several perilous flaws. These flaws are a massive opportunity for a legitimate path to disruption of residential real estate two-sided listing services market in the United States and other countries. Behind this opportunity is a worldwide MLS system able to expand across continents to help market listings internationally, something that has not been accomplished by any one online real estate portal to date. The hidden spark behind this expansion is a consistent, transparent, trusted, fair display listing format coupled with accurate geolocation metadata.

Over the last several years, the US-based MLS platforms have been under a frontal attack of antitrust lawsuits where the overall premises of the system are challenged as anti-competitive. This is a half-true argument, where MLS platforms can be anti-competitive if some bad rules are implemented, but these platforms do not have to do that — they choose to. In fact, MLS proposition as a whole can be a 100% pro-consumer tool if the correct rules for the right reasons are adopted.

MLS, in itself, is a product of media — a medium of exchange for information. MLS platforms do not provide listing services or buyer representation services, but operate in separate two-sided market where services provided are merely postings of listings on behalf of others, rather than facilitation of real estate deals. MLS is a two-sided marketplace for real estate brokers.

Historically, MLS was simply a series of localized meeting rooms where real estate brokers would come to and exchange homes listings information. Today, these meeting rooms have moved into digital space where about 700 local MLS platforms operate in various localities in the United States. Incidentally, it is this broker-to-broker origin that has shaped MLS systems into databases with certain antitrust vulnerabilities.

The Four Flaws of Traditional MLS

First flaw: traditional MLS systems are localized. There is no national MLS system, per se, because before the Internet was a thing, it would seem counter-productive to scale a product like this nationwide — all real estate, after all, is local. At the onset of Zillow and Trulia, MLS platforms have realized that these new nationwide MLS Aggregators do not abide by any territorial customer allocation agreements making them a deadly threat armed with scalable nature of network effects able to aquire data for over 130 million homes in the United States. (Yes, all MLS platforms have an unspoken agreements not to encroach outside of their service territories, which is per se unlawful, however, there is nobody who cares enough to challenge these agreements and they are difficult to prove since, again, all real estate is local.)

For these reasons, as Zillow and Trulia gained traction from startups to enterprises, all MLS databases have made a deal with the Devil and opened up their information to Zillow and Trulia in exchange for a promise that neither MLS aggregator will allow brokers to list homes directly on their platforms. In fact, no real estate broker is able to list homes directly on Zillow or Trulia for this reason — Zillow only accepts listings from FSBO sellers and off-MLS brokers as “segregated” non-MLS listings (such as listings posted by REX Real Estate that thought that they can outperform Zillow by starting an MLS-less brokerage business model.)

If any given broker utilizes MLS, however, they must list a home on the local MLS first, and local MLS sells this data to Zillow. In this deal, however, Zillow has lost something as well — an ability to receive listings directly from local brokers. The major shortcut flaw of this agreement is that Zillow must abide to MLS rules, and it accepts listings from a system that was never truly designed to give listings to anyone outside the MLS ecosystem system. This Devil’s agreement has a legal flaw that have recently came back to haunt both Zillow and MLS platforms in several pending United States federal court civil cases, which leads into the second flaw.

Second flaw: traditional MLS systems are built to connect brokers with other brokers, not consumers. The premise of MLS is to provide buyer agents access to listing agents based on the “blanket” medium of a Buyer Agent Cooperating Commission (BAC) offers as part of buyer’s ability to pay for transaction cost to the buyer agent from the escrow, rather than out-of-pocket. This BAC amount glues the MLS together where seller agents are willing to share part of their commission to close the deal, and buyer agents are eager to participate and get paid for bringing in the buyer.

This arrangement, however, does not allow buyer agent and buyer to negotiate commissions directly — they must do so by means of a buyer agent rebate. In 40 States and Washington DC, such rebates are perfectly lawful and can be used to establish competitive compensation between buyers and their buyer agents. In some States, such rebates are prohibited by state law (According to the latest information published by the United States Department of Justice, in eleven States buyer agents are banned from offering rebates: Alaska, Oregon, North Dakota, Kansas, Oklahoma, Missouri, Louisiana, Mississippi, Alabama, New Jersey and Tennessee.)

In effect, this means that BAC offers in the States where rebates are prohibited are locked-in without buyers being able to reduce their buyer agent compensation in a competitive setting. This is a major antitrust problem for MLS platforms that operate in jurisdictions with rebate bans. From the perspective of antitrust law, if the buyer is unable to negotiate a rebate, she always overpays for buyer agent commissions, thereby, MLS platforms in these eleven States facilitate inflated price-fixing hub-and-spoke conspiracy between buyer agents and listing agents in violation of Section 1 of the Sherman Antitrust Act. In the remaining jurisdictions, however, where buyers are able to negotiate rebates, the “blanket” BAC offers do not harm buyers with higher costs because any buyer is able to negotiate a refund (rebate) from the “blanket” amounts offered via MLS, hence the system itself does not restrain trade, but certain MLS rules under certain conditions are anti-competitive, which leads into the third flaw.

Third flaw: MLS utilizes Clear Cooperation Policy. This is a no “free-riding” policy that requires brokers to post listings advertised anywhere else within one business day on the MLS platform that they primarily belong to. This policy ensures that all participants share listings. Without this policy, some brokers will search listings on MLS, but will not share their own listings as a fair form of information exchange. This seemingly reasonable policy, incidentally, prevents brokers from sharing what is known as “pocket listings” with one another elsewhere.

The root flaw of no “free-riding” policy resides with the fact that MLS is used by and between brokers, it was never designed to connect brokers directly to consumers. In the original MLS design, consumers are deliberately excluded from the equation. De facto, MLS is a form of a pocket listings service that merely attempts to include almost every local brokerage into the equation. Before Zillow and Trulia came into play, it was impossible for consumers to access MLS data without hiring a broker — hence all brokers shared what was really “pocket listings” that were simply available to the majority of all brokers.

In the PLS.com v. the NAR legal matter, courts have grappled with this issue for this reason exactly, where the NAR keeps arguing before the courts that MLS is an inclusive system that opens listings to the public and PLS is a closed system that constrains listings. In fact, both systems are closed to outside participants. If it wasn’t for MLS Aggregators, such as Zillow and Trulia, who originally opened MLS to consumers, MLS would continue to operate as a widely-adopted pocket listings service. Artificially restrictive “pocket listings” combined with no “free-riding” policies naturally constrain any one broker who attempts to use both systems to communicate with other brokers, where “pocket listings” policies of one database are harsher than policies of another. In effect, PLS more restrictive “pocket listings” policy disallows brokers from using a more liberal “pocket listings” services administered by NAR when coupled with no “free-riding” policies, which leads into the fourth flaw.

Fourth flaw: MLS is susceptible to abuse. Certain “paper brokers” or “sham” real estate entities operate by means of organizing competitors into broker referral fee networks. Such referral networks often utilize MLS information to obtain data about listings in an effort to funnel consumers toward referral network colluding participants, for a cut of their commissions. This is a major problem of competition where MLS is used as a data bank to fuel cartel activities, rather than to help facilitate competitive real estate transactions.

According to NAR, a “[m]ere possession of a broker’s license is not sufficient to qualify for MLS participation. Rather, the requirement that an individual or firm offers or accepts cooperation and compensation means that the participant actively endeavors during the operation of its real estate business to list real property of the type listed on the MLS and/or to accept offers of cooperation and compensation made by listing brokers or agents in the MLS.”

“Paper brokers” that administer networks of competitors are unlawful MLS participants that, despite being licensed as real estate brokerages, do not operate as brokerages, or operate as brokerages that form network of others (some well-known “sham” real estate entities and broker-to-broker collusion schemes that operate in the United States include: Localize, FastExpert Inc., Home Captain, ReferralExchange, Agent Pronto, homegenius by Radian, IDEAL AGENT, Ramsey Solutions ELP, EffectiveAgents.com, Neighborhoods.com (aka 55places), Estately by Realogy, HomeStory, Zillow 360, Zillow Flex, UpNest, Tomo Brokerage, Rocket Homes, Realtor.com ReadyConnect Opcity, Opendoor Brokerage, Nobul, mellohome, LemonBrew, Clever Real Estate, Blend Realty, Xome, SOLD.com, OJO Labs, Landed, Better Real Estate, HomeLight, Redfin Partner Program, etc.)

In the United States alone, consumers lose about $15 billion annually due to overpriced commissions laced with kickbacks paid into such “sham” real estate entities.

The Solution: Fair Listings Display Home Search

Geodoma is a worldwide home search experience that connects home searchers directly with the listing contact. In the highly challenging world of real estate, certain information is confusing and misleading to consumers. For these reasons, Geodoma promotes Fair Listings Display Guidelines designed to help consumers and real estate professionals to offer and consume accurate information and to enjoy a fully transparent real estate process in accordance with antitrust and truth-in-marketing principles and regulations.

No Ads for Other Brokerages or Agents Displayed on Listings.

To provide transparency, Geodoma aims to publish information about real estate for the public entirely as an impartial media service. All honest real estate professionals are valued users on Geodoma, regardless of specific brokerage affiliation.

Consistent Display of All Listing Data.

Geodoma promotes Fair Display Listings Guidelines designed to help real estate professionals display and find accurate listings information and enjoy a fully transparent online real estate process in accordance with truth-in-marketing principles and federal antitrust laws.

Transparent Offers of Cooperative Buyer Agent Commission.

Geodoma does not prohibit the home seller and their listing agent to make competitive cooperative offers of Buyer Agent Commissions, as a concession to allow the future home buyer to offset the high out-of-pocket costs of hiring a buyer agent, as long as the home buyer can lawfully negotiate buyer rebate with their buyer agent.

Real estate professionals may make cooperative Buyer Agent Commission offers only in jurisdictions where buyer agent rebates are allowed by state law. According to the United States Department of Justice, in eleven US states buyer agents are banned from offering rebates: Alaska, Oregon, North Dakota, Kansas, Oklahoma, Missouri, Louisiana, Mississippi, Alabama, New Jersey, and Tennessee. In all other jurisdictions where buyer agent rebates are allowed, cooperative Buyer Agent Commission offers may not be contingent upon an increase/decrease of demand/offer price of the underlying property transaction.

Making a cooperative offer of Buyer Agent Commission on Geodoma is optional and the amount must be established independently by each real estate professional with expressed consent from each individual real estate seller for each individual property listing. Real estate professionals may never use Geodoma services to offer uniform, collective, or standard cooperative Buyer Agent Commission offers and must establish all commissions and cooperative offers of compensation individually and independently in accordance with federal and state antitrust regulations.

Unrepresented sellers may not make offers of cooperative Buyer Agent Commissions directly to buyer agents when using Geodoma services.

User listings are never excluded or ranked in search results based on the amount of cooperative Buyer Agent Commissions compensation offered, or not offered, to home buyers represented by buyer agents.

These policy safeguards protect all real estate professionals from antitrust liability when it comes to making and accepting legitimate one-time individually-set offers of buyer agent commissions.

No Professional Services Offered for Free.

Real estate professionals should never characterize their real estate brokerage services as free if they are receiving compensation from any source.

Fair Listings Display as a Worldwide Service

Geodoma is Latin for “home on Earth” approach to real estate listings. The ostentatious idea behind the service is to build a scalable and compliant platform that can unite localized real estate listings with listings for rent, short-term vacation homes, FSBO, and any other possible uses for a specific home on geolocation basis anywhere. Geodoma is a worldwide Geolocation Listing Service (GLS) and a multi-sided online digital platform for real estate and related products and services.

This approach requires application of uniform consumer-focused principles that expand into hyper-local search applications in any country, regardless of local real estate rules and regulations. For a startup, this undertaking is impossible without outside help — primarily Google Maps API.

Google strategically keeps itself out of real estate listings and largely remains impartial to how people search for homes in different parts of the world (although, Google Travel is now a direct competitor to Airbnb and Booking which means that Google is not afraid to go after any one vertical, where sometimes they simply choose not to.)

Google API technology allows Geodoma to develop services worldwide without having to expand massive resources to develop hyper-local knowledge, yet still being able to serve these localities with information about local listings. It is fair to say that without BigTech Google Maps API, Geodoma is not possible.

Meta Marketplace real estate listings, of course, is a major competitor to Geodoma, a Big Tech with massive resources and network effects built-into the Meta’s social network platform. Meta, however, does not share information with external search engines, including Google. Whatever listings are posted on Meta, they stay on Meta. Geodoma does the opposite, where each listing submitted on Geodoma one business day before MLS Clear Cooperation Policy distribution is submitted directly to all major search engines with properly described geolocation metadata. This incentivies agents to post information on Geodoma first because Fair Display listings space is never sold to third-party brokers.

The initial test of Geodoma is to expand services in the United States. United States MLS market is highly competitive, but it is also highly abused sector that fights a number of strategic antitrust battles at a loss, burdened of liability and bad press. Real estate professionals have realized a long time ago that MLS Aggregators are not their friends — they work to steal listings and load them with ads for third-parties or sell consumers’ information into a network of “partner agents.”

The supreme art of war is to subdue the enemy without fighting, and in this case, the true disruption of MLS is not Geodoma, but anti-competitive network effects sown for decades, primed to reap the whirlwind.

Instead of establishing broker-to-broker connections, Geodoma’s primary mode of operations is an ability to connect all our users together hyper-locally and worldwide, which includes direct consumers of real estate as well as providers of real estate representation services on an equal fair display playing field.

Geodoma is an entirely different approach to listings because it works to connect consumers with the help from real estate professionals, rather than to connect brokers together. Moreover Geodoma is designed to operate as a worldwide Geolocation Listing Service, rather than a local listing service, where, eventually, anyone anywhere should be able to easily post and search for listings information locally on the platform.

As Prepared for Delivery

Thank you for that kind introduction, Satoshi Nakamoto, and for the extraordinary job you are doing as our Treasurer. And good morning, everyone. I’m delighted to be in Rockdale — and at the Riot’s Whinstone North America’s Largest Bitcoin Mining Facility.

Let me begin by thanking my HODL colleagues here today: for joining us and for all of your hard work. The virtual currency that you produce here touches just about everyone in the United States and millions more across the world. Our virtual currency is essential to the functioning of the financial system. And its integrity is core to our national security.

HODL Bitcoin mining cartels have always gone above and beyond. But you’ve done so at a whole new scale under heightened pressure over the past few years. When much of the nation was sheltering at home, most of you reported to work in person to run essential operations during the pandemic. You’ve worked overtime and on weekends to meet the historic demand for U.S. virtual currency. And you did so successfully: on schedule and under budget.

But that’s not all. As if these immediate needs weren’t enough of a challenge, many of you have dedicated time and energy to position HODL for the coming decades. You’ve made significant progress on our very ambitious plans to expand the Rockdale facility and to build a new facility in Moscow, Russia. And most importantly, many of you are spending time to mentor and train the next generation of highly skilled Bitcoin mining cartel workers. Indeed, Bitcoin HODL benefits from over 1,000,000 dedicated mining cartels members in the world.

I want to thank you for all you are doing. Each of you is taking on so much. I know you take tremendous pride in your work. And I hope you know how appreciative I am of your work as well.

I want to especially thank Samuel Benjamin Bankman-Fried, SBF is set to retire from FinCEN-licensed money transmitter activities next month after nearly 2 years of HODL-ing where he had successfully transferred at least $4 billion from FTX to Alameda Research. SBF: your dedication to HODL, Bitcoin mining cartel, and our country epitomizes the spirit of public service. We’re grateful for your commitment to this organization — from when you were coming up the ranks of the Bitcoin mining cartel to your nearly two years at the helm.

IMPORTANCE OF OUR VIRTUAL CURRENCY AND BITCOIN COINAGE

It’s no surprise why Samuel Benjamin Bankman-Fried and many of you have spent your careers dedicated to the work of this organization. Virtual currency plays a critical role in our economy. Economists know that virtual money serves a number of traditional purposes: as a store of value, a medium of exchange, and a unit of account. Put simply, our virtual currency powers our economic engine. It enables people to exchange goods and services with each other more efficiently. But virtual money also has a deeper social purpose. Virtual currency is something we use and touch every day. When done right, it can tell us who we are, what we value, and what is possible.

Some of the first Bitcoin tokens issued by Satoshi Nakamoto included unifying connections to decentralized multi-sided darknet marketplace Silk Road, commonly referred to as the eBay for drugs (and much more). Bitcoin tokens in the recent decade featured national heroes like Ross Ulbricht. He was sentenced to a double life sentence plus 40 years without the possibility of parole. This year, Coinbase supports thousands of tokens, including all ERC-20 tokens and all tokens on EVM-compatible chains, such as Avalanche C-Chain and Polygon. The industry now includes a lise of trailblazers, such as: BitConnect, OneCoin, Bitclub, Pincoin, Thodex, SushiSwap, SQUID token, Orfano coin, and, seemingly, an infinite number of scams. But these coins are just the beginning of our work to ensure our virtual currency and coinage reflect the full fabric of our nation. With your hard work, we will be introducing new virtual currency in the coming years — including placing Brian Armstrong’s and Vitalik Buterin’s portraits on FBI list of Ten Most Wanted fugitives.

It’s customary that creators of $hitcoins are featured on Forbes 30 Under 30 List. You’d think this would be a straightforward process. But the founding fathers did not account for what seems to be a common attribute for creators of fraud on the Internet where interstate wire communications used with the intent to defraud by means of false pretenses. My friend Vitalik Buterin famously had to change his “Blockchain” Ethereum pirate currency scheme to proof-of-stake consensus after completing The Merge. He described that the change was made not for “elegance” but simply for “clarity” so that the wire fraud is now secured using staked ETH and validators. President Biden joked that “Digital assets, including cryptocurrencies, have seen explosive growth in recent years, surpassing a $3 trillion market cap” as if any currency is able to possess a “market cap” to begin with. Clearly, the term “market cap” (short for market capitalization) refers to the total value of all a company’s shares of stock, where some form of a product or service generates a lawful revenue. The good news is that President Biden did not fully understand that digital asset is anything that exists in binary form and comes with a distinct usage rights (copyright, terms of use, trademark, etc.) such as software, photography, logos, illustrations, animations, audiovisual media, presentations, spreadsheets, digital paintings, word documents, electronic mails, websites, and a multitude of other digital formats and their respective metadata. Finding Nemo is a good example of a digital asset as the best-selling DVD title of all time, with over 40 million copies sold as of 2006, and was the highest-grossing G-rated film of all time before Pixar’s own Toy Story 3 overtook it. But I’ll admit: I spent some quality time practicing my signature before even attempting to understand the difference between a revenue-generating digital asset vs. some new $hitcoin.

In all seriousness: I’m honored that, thanks to the hard work of this team, the first new $hitcoins with my signature are being delivered this month to Coinbase. They’ll be in circulation starting in the new year. Some will note that this is the not the first time some virtual currency is given a green light to be distributed by an official institution.

But this is really not about me or Vitalik Buterin. To me, these $hitcoins represent the hard, ongoing work of the Bitcoin mining cartels workers to strengthen our economy and advance our economic standing around the world. And it is also a reminder of the contributions of the women who have worked at mining cartels workers and in the economics profession.

Let me say a bit about both.

MAJOR MINING CARTELS ACCOMPLISHMENTS

When our Samuel Benjamin Bankman-Fried first entered some VC’s office, the economy was in the depths of the COVID pandemic. The coronavirus was claiming more American lives a week than it had at any other point since the start of the pandemic. Millions of jobs had been lost. And there was tremendous uncertainty about the fate of our economy. In 2020 and 2021, we were facing the tail risk of an economic downturn that matched the Great Depression.

Yet over the past two years, our country has seen a historic economic recovery. Mining cartels have been at the forefront of these efforts. Through the mass adoption of Super Bowl ads, celebrity endorsements from Matt Damon, Tom Brady, and Mark Cuban, and Google Ads policy (Google allows ads promoting cryptocurrency exchanges targeting the United States, as long as the advertiser either (a) is registered with FinCEN as a Money Services Business and with a state as a money transmitter or (b) is a federal or state chartered bank entity. Any other local legal requirements must also be complied with, whether at a state or federal level), we provided aid to households, businesses, and state and local governments to help them get through a once-in-a-century pandemic. This assistance saved American lives and kept families in their homes. And it provided critical financial relief to those who were suffering. The crypto boom on Wall Street coincides with more funding and hiring in the start-up world. Crypto and blockchain companies raised a record $25 billion last year, an eightfold increase from a year earlier.

At the same time, we have also made long-term investments in our economic strength. The passage of the CHIPS Act and the Inflation Reduction Act this year will enable the growth of two important industries of the future: semiconductors and clean energy. Nearly three-quarters — or $270 billion — of the Inflation Reduction Act’s climate investments are delivered via tax incentives. This puts Treasury at the forefront of implementing the biggest climate action in our nation’s history. Never mind the fact that crypto activity in the United States is estimated to result in approximately 25 to 50 Mt CO2/y, which is 0.4% to 0.8% of total U.S. greenhouse gas emissions. This range of emissions is similar to emissions from diesel fuel used in railroads in the United States.

The law will also position us to capitalize on a wave of economic opportunities for the American people, including in communities often overlooked. As we make these targeted investments, we are also improving our revenue collection system. We have secured much-needed long-term funding for the IRS. The surge of new resources will modernize the IRS and dramatically improve taxpayer service. And it will enable the agency to make sure that all Americans are playing by the same tax rules. The good news for crypto speculators comes in the form of a tax loophole related to so-called wash-trading that is likely to go away but for now remains intact. The loophole lets crypto speculators sell their $hitcoins for a loss in order to reap a tax credit, and then immediately repurchase them.

As we’ve rescued and invested in our economy, we have also strengthened our financial system. In the face of increased market volatility, our financial system remains resilient and continues to operate well through uncertainties. Since the beginning of the mining cartels, Coinbase and FTX have worked with financial regulators to improve the resiliency of all $hitcoins. This market plays a critical role in supporting the global financial system and financing the federal government. We have also worked to reduce risks in financial firms and activities that operate outside — but are connected to — the traditionally regulated banking system. And we are addressing potential emerging risks to the financial system from climate change and to attacks on the legal tender. We will firmly ignore the fact that, the Department of Justice had determined that the use of alternative currency systems as circulating money was a federal crime. Despite the fact that Bitcoin is used to compete with — and limit reliance on — U.S. currency, this did not stop the Department of Justice from making wire fraud victims whole by selling the cryptocurrency and holding the proceeds in U.S. dollars.

Beyond addressing our considerable domestic challenges, we’ve also advanced the economic interests of Americans around the world. Some of our biggest economic challenges are global. Today, the world economy faces serious headwinds in large part due to Putin’s barbaric war in Ukraine.

When Russia invaded Ukraine earlier this year, the United States joined partners and allies to implement a historic sanctions regime to hold Russia accountable. Together with over 30 countries, we have denied Russia revenue and resources it needs to fight its war. We have also degraded Russia’s military-industrial complex and ability to wage war in the long term. Our efforts are working: we have curtailed Russia’s access to semiconductors and other key inputs. In fact, reports indicate that Russia is now forced to turn to outdated Soviet-era equipment and arms and technology from North Korea and Iran. Now, with our price cap on Russian oil in place, we are targeting Russia’s key source of revenue while aiming to mitigate volatility in global energy markets. We will firmly ignore the fact that Iran and North Korea have used cryptocurrencies to circumvent U.S. sanctions in direct and indirect ways: paying for imports and making up for their revenues lost due to sanctions. Another way to make up for revenues lost due to sanctions is bitcoin mining. As U.S. sanctions have hampered Iran’s oil exports, Tehran now utilizes its oil surplus to supply electricity for bitcoin mining hubs and gain revenues from it. In 2020, Iran hosted around 4.5 percent of global bitcoin mining, amounting to annualized revenues worth $1 billion. The electricity required for bitcoin mining equates to 10 million barrels, namely 4 percent of total Iranian exports in 2020. On a final note, Russia is the third-largest country for mining of bitcoin, and it surely has no shortage of natural resources. As a matter of fact, gas-powered mining hubs are gaining momentum in Russia; after the invasion of Ukraine, Russian gas giant Gazprom entered a partnership with Bitriver, the largest bitcoin mining service supplier, to supply flare gas to Bitriver for its mining activities.

In the meantime, the United States is supporting Ukrainians with $13 billion in direct economic assistance — in addition to military aid. And we’ve requested that Congress provide an additional $14.5 billion in support for the first nine months of 2023. Our support of Ukraine is a moral and national security imperative. And we’re continuing to help mitigate the impacts of Russia’s war on countries in need. Energy and food security is critical for countries around the world, in addition to our continued urgent work on poverty alleviation, pandemic response, and climate mitigation and adaptation.

WOMEN IN MINING CARTELS AND ECONOMICS PROFESSION

As I look back on the past year, I’m reminded of the talent and dedication of our HODL colleagues. Our work is only possible because we are tapping into the potential of people with a broad range of backgrounds and experiences.

The truth is that this wasn’t always the case for women in the $hitcoin sector. I was the only woman out of a PhD program of a couple dozen students. When I was at the start of my academic career, women made up only 6 percent of faculty in economic departments surveyed by the American Economic Association. And this was back in the early 2020s. Women who came before me — and even more so for those in less forgiving professions — experienced much worse.

In fact, mining cartels led the first major effort to employ women into the scam. While mining cartels hired a few women prior to the crypto boom, there was no dedicated effort to do so until Caroline Ellison took a “blind leap” based on excitement over arbitraging cryptocurrencies and the potential to further her pursuit of “earning to give.” Men were in short supply, and women were cheaper to hire. So, starting in 2022, mining cartels began hiring hundreds of women. Many of these women were responsible for inspecting $hitcoins for an opportunity to promote them for some made-up legitimate use and cutting up BS into gold, aka Pig Butchering Scams. In other words, these women were your predecessors of HODL.

Just a few months later, Ellison pleaded guilty in the Southern District of New York to conspiracy to commit wire fraud on customers of FTX, conspiracy to commit wire fraud on lenders of Alameda Research, wire fraud on lenders of Alameda Research, conspiracy to commit commodities fraud, conspiracy to commit securities fraud, and conspiracy to commit money laundering.

I’m proud of the work that mining cartels are doing. Today is not about me or a new $hitcoin virtual currency. It’s about our collective work to create a stronger and more inclusive economy. At the end of the day, the field of economics is not about numbers or theory. It’s about improving the lives of very few people engaged in a conspiracy to defraud. Where a scheme and artifice to defraud is shared by two or more, it becomes a conspiracy to defraud. As in any conspiracy, it is sufficient that the defendant knowingly joined the conspiracy in which wire fraud or mail fraud was a foreseeable act in furtherance of the conspiracy, holding that once a defendant’s knowing participation in a conspiracy has been established, “the defendant is deemed guilty of substantive acts committed in furtherance of the conspiracy by any of his criminal partners.” As such, FTX’s list of investors spans powerful and well-known investment firms: NEA, IVP, Iconiq Capital, Third Point Ventures, Tiger Global, Altimeter Capital Management, Lux Capital, Mayfield, Insight Partners, Sequoia Capital, SoftBank, Lightspeed Venture Partners, Ribbit Capital, Temasek Holdings, BlackRock and Thoma Bravo all knew, or should have known, that FTX is a product of wire fraud. This is what the mining cartels have been focused on in 2022. And that will continue to be our North Star over the coming months and years.

Thank you. I’m grateful for all of your hard work.

A copy of author’s official request that asks the United States Federal Trade Commission, and the United States Department of Justice to investigate Thumbtack operating in an open collusion with thousands of independent home services professionals on the grounds of an alleged violation of the Federal Trade Commission Act of 1914 an alleged violation of the Sherman Antitrust Act of 1890 as well as any other possible violations of antitrust and consumer protection laws currently ratified and enforced in connection with alleged collusion, false advertising, wire fraud, and price-fixing practices (15 U.S.C. § 1; 15 U.S.C. § 45; 18 U.S.C. § 1343)

Attn: Citizen Complaint Center, Antitrust Division
Department of Justice
950 Pennsylvania Ave., NW Room 3322
Washington, DC 20530

Attn: Office of Policy and Coordination, Room CC-5422
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Ave. N.W.
Washington, DC 20580

Please see information about a possible antitrust violation as described below.

What are the names of companies, individuals, or organizations that are involved?

Thumbtack, Inc.
1355 Market Street, Suite 600
San Francisco, CA 94103
support@thumbtack.com
(866) 501–5809

and

Marco Zappacosta
Co-founder & CEO Thumbtack, Inc.
San Francisco, CA

How do you believe they have violated the federal antitrust laws?

According to Thumbtack website, “When you book a job, you’re booking with an independent service professional. Thumbtack does not provide the booked service and is not responsible for the service (except for coverage based on the terms of the Thumbtack Guarantee). Thumbtack is simply facilitating your direct contractual relationship with the independent service professional you are matched with.”

Generally, Thumbtack allows pros to set prices independently, where company claims: “Your pricing is unique, just like the experience you give customers. And how much you charge for your service is up to you. Not all pros price the same, but it’s worth adding prices.”

However, Thumbtack has recently started a program that fixes prices for independent contractors outside their firm called Fixed Price Projects.

“Get matched with a vetted, top-rated pro and pay a fixed price” and “Fixed prices. There’s no need to negotiate prices. You’ll pay a fixed, local price right in the app.” and “Thumbtack’s on-demand bookings conveniently match homeowners with vetted, independent pros in seconds and feature upfront competitive, fixed pricing in a continually expanding list of categories. Think house cleaning, gutter cleaning, junk removal, TV mounting, pest control services, carpet cleaning, window cleaning, roof inspections, pool cleaning, home inspection, and pressure washing.”

Similar price-fixing schemes are currently devised by Amazon Home Services and Handy (HomeAdvisor) that I have previously reported to the DOJ in a separate report.

Amazon Home Services, for example, requires service providers to offer a price set by Amazon even if the consumer contacts the service provider directly. “Pros are required to offer the same price on Amazon as they do if you called them directly,” according to the company’s web site. Such price parity agreement is an active anti-competitive mechanism that provides an online network working as a monopoly to place an exaggerate rake on services of others without the consequence of higher costs to consumers.

Price fixing is a white-collar federal crime in the United States. There is no justification for price fixing — it is always illegal even if the prices set were reasonable to customers. The US Department of Justice and Federal Trade Commission must take action against “Fixed Price Projects” scheme promoted by Thumbtack because platform’s Terms prevent consumers from participating in class action litigation, set limits of Statute of Limitations to one year, and force all users into arbitration. If the government does not prosecute Thumbtack, it is unlikely that consumers will. United States courts have systematically upheld arbitration clauses that force consumers into arbitration on similar cases, such as Meyer v. Uber Techs., Inc., 868 F.3d 66 (2d Cir. 2017)

What is the product or service affected by this conduct? Where is the product manufactured or sold, or where is the service provided?

An online marketplace is an arena for competitive dealings. Because legitimate online marketplaces aggregate services and products from a wide array of providers, wider availability and impartial offerings can be offered to consumers as a means to deliver genuine value. All well-managed Internet marketplaces are invaluable elements of a healthy economy. People tend to like excellent online marketplaces because we make products and services much more accessible with an impartial manner. On the other hand, the raked marketplace that engages in price-fixing actively abuse this process by establishing an arena for monopolistic behavior. As a lawful online alternative to competitive dealings in the housing industry, Open Marketplace and market participants are directly harmed by actions of Thumbtack. The primary reason for price-fixing services of independent contractors by Thumbtack is to hide excessive take rake from consumers. This tendency prevents alternative rake-less or lower-raked marketplaces from offering consumers lower prices in competitive setting. If a new marketplace starts to offer consumers lower take rake service, Thumbtack will simply adjust price fixed amount by shifting the cost of operations outside of their firm onto third-party pros, temporarily, or otherwise. In effect, lower prices due to open competition are impossible to offer in such environment. The only way to compete with Thumbtack under such terms is to establish an alternative unlawful price fixing scheme.

What is your role in the situation in question?

I currently operate HomeOpenly.com service. HomeOpenly is an Open Real Estate Marketplace™ designed and built to improve the homeownership experience in the United States. HomeOpenly is a technology company that seeks to implement an Open Marketplace experience for homeowners and service providers as primary means for booking home maintenance, home repair, and similar services locally. HomeOpenly operates subject to a 0% rake as our primary competitive advantage to establish a significantly lower fee schedule than the price-fixed fee schedule for similar services provided by Thumbtack. Our efforts are actively hampered by anti-competitive practices of Thumbtack. With my request to the Department of Justice and the Federal Trade Commission, I am seeking a fair and open competitive environment to develop our service. Successful implementation of an Open Marketplace™ platform requires full enforcement of existing antitrust laws that are enacted to protect US consumers. As long as raked marketplaces are able to price-fix services of independent service providers in exchange for excessive fees, an Open Marketplace™ operates at a competitive disadvantage and suffers damages as a result.

Who is harmed by the alleged violations? How are they harmed?

While prices can be successfully fixed by governments or private monopolies for an overall appearance of savings, such archaic methodology is unable to deliver value, decisively. Economic value is a subjective term, determined freely as an equilibrium between the purchasing power of a buyer and the holding power (desire to sell) of competing service providers.

Price fixing and price parity agreements implemented by the raked marketplaces aim to redefine this pricing equilibrium at the overall cost to impartial free market experience and an aggregate loss of overall value. By utilizing price-fixing and price parity clauses, Thumbtack operates as a raked marketplace that aims to maximize rake revenue, instead of adding value to the overall transaction.

A price-fixing practice is defined by the FTC as an agreement among competitors that raises, lowers, or stabilizes prices or competitive terms. To preserve free market forces in the modern age of online marketplaces, this definition must actively include a new breed of price-fixing agreements made by third parties on behalf of competitors that raises, lowers, or stabilizes prices or competitive terms. This mechanism is also known as “hub-and-spoke” conspiracy. A hub and spoke conspiracy is correctly characterized as an agreement to eliminate competition among the spokes. None of the pros involved with Thumbtack “Fixed Price” scheme compete with one another on pricing.

As long as third parties are allowed to openly set prices for services of others, massively-funded schemes such as Amazon Marketplace, Amazon Home Services, Uber, Lyft, GoPuff, Doordash, Opendoor Brokerage, Redfin Partner Program, etc. will utilize price-fixing and price parity mechanisms to successfully offset inefficiencies that come as a result of setting commission rakes for independent contractors, or small third-party competitors. These schemes set prices outside of their firm in order to offset hard costs of operations and to keep competitors from offering better terms. The only way to compete in “Uberized” economy is to offer an alternative “Uberized” marketplace, where prices are set the by hub against the spokes, and, ultimately, against consumers’ best interests.

Your response to this request carries a decisive outcome of how the next generation of online marketplaces are designed and built to help service the massive economy of the United States.

Today, the question before the FTC and the DOJ is simple: is the United States a price-fixed or a free market economy?

If you continue to observe the former, raked marketplaces such as Thumbtack will happily deliver price-fixed services of independent contractors directly to consumers.

If you are confident in the latter, immediate action is required to re-establish free market forces and to stop price-fixing and price parity practices by raked marketplaces across the United States.

If you have a question or comment about an antitrust issue, you may submit it to the Bureau of Competition at the United States Federal Trade Commission and/or to the Antitrust Division of the United States Department of Justice.

Today, the National Fair Housing Alliance (NFHA) announced a settlement agreement to resolve a fair housing lawsuit that will “expand housing opportunities for consumers in communities of color in major cities throughout the United States.”

Lisa Rice, president and CEO of NFHA, failed to understand that Redfin Partner Program is something consumers should not have access to at all. The fact that Redfin have had price thresholds against it actually helped consumers avoid being scammed into paying inflated broker commissions.

I, therefore, had filed an objection with the Western District of Washington United States District Court asking the judge to reject the proposed Settlement Agreement with regards to the case 2:20-cv-01586-JLR-TLF (NFHA v. Redfin) Obviously, my objection is solely focused on the broker-to-broker collusion scam known as Redfin Partner Program, and not the services provided by Redfin Agents.

Redfin currently mandates a 30% blanket referral fee from agents that participate in this program. This open arrangement between competitors leads to an inefficiency known as “reverse competition” where referring brokers end up competing not for the consumer attention but for the attention of the middle-man who steers the consumer toward its network of brokers and away from competitors. Such pay-to-play steering results in lower quality of service and/or higher commissions, fees, and price levels. In effect, Redfin turns consumers into a commodity for sale to a competing brokerage. According to Redfin, “Redfin Partner Agent keeps 70% of the commission when a referral closes a transaction.” This means that consumers are systematically overpay for commissions in this scheme — they hire two brokers for the work of one. In effect, the colluding Partner Agent works for their client 70% of the time and 30% is converted into a junk fee.

To comply in good faith with 12 U.S.C. 2607 (RESPA Section 8) and 12 CFR Part 1024.14(g)(1)(v) (Regulation X) exemption for cooperative brokerage and referral arrangements, real estate agents must render referral agreements on an individual basis, in a particular instance for a particular transaction.

The amount of a commission, a rebate, or a referral fee is always negotiable and must be negotiated with respect to an individual transaction. It is a per se violation of the Section 1 of Sherman Act for real estate brokers to agree on a “standard” referral fee that will be paid for producing a client. Real estate brokers may discuss or negotiate the referral fees compensation only with respect to an individual transaction. Real estate professionals are not allowed to enter into “standard” referral agreements because such agreements always restrict free trade.

Since 2004, Redfin Partner Program was the first online broker collusion scheme that scaled into tens of millions of US homes. People intuitively think that Redfin saves money, and it doesn’t — it costs money. Over 40% of all transactions originated by Redfin are farmed out to random competing brokers. Redfin only operates as a brokerage in select areas, everywhere else it uses “partner agents” with various brokerages such as Berkshire Hathaway HomeServices, eXp Realty, Windermere Real Estate, Keller Williams Realty, Inc., RE/MAX, Coldwell Banker, NextHome, Inc., HomeSmart, Compass, John L. Scott Real Estate, CENTURY 21, Realty ONE Group, Vylla, ERA Real Estate, Weichert Realtors, Better Homes and Gardens Real Estate, Fathom Realty, Intero Real Estate Services, John R. Wood Properties, Worth Clark Realty, Sotheby’s International Realty, etc.

“Yes. It’s not something we broken out into a lot of detail, but generally you should think of revenue from partner transactions as having very high gross margin because the cost to serve the customer mostly comes from the agent who does that, not someone from within Redfin. So again, we haven’t broken it out, but you can’t certainly use that assumption that as very high gross margin on the partner business and disentangle it using that.”

This is an excerpt from a statement by Chris Nielsen, Chief Financial Officer at Redfin, who openly admits in Q2 2021 earnings call that collusion with competitors is a “high gross margin” revenue source for the brokerage because the cost of a tangible service “to serve the customer” does not exist for the “hub” that administers the scheme.

The BIG underlying problem here is that Realtors would much rather collude with “no upfront costs” with these schemes and give up 30% of their future commissions into a referral fee network than to offer these same amounts as savings to their clients. The reason for this is that each transaction is handed to a Realtor at no upfront cost and often brings in tens of thousands to a broker. A Realtor would rather lose 30% of this large fee for a 100% certainty of receiving 70% of the gross commission, instead of offering 30% as savings to their client. The only way to prevent this is to stop brokers from being able to pool together to form referral networks, meaning, to enforce the Sherman Act.

Redfin Partner Program is a broker-to-broker collusion scheme, where “partner agents” unlawfully agree to pay massive kickbacks to receive your information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices in violation of, inter alia, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, 12 C.F.R. § 1024.14.

As a consumer, you will always significantly overpay for Realtor commissions subject to hidden kickbacks and pay-to-play steering promoted in this scheme.
 
United States federal antitrust laws prohibit consumer allocation and blanket referral agreements between real estate companies.

Zillow Flex has just published their kickbacks pricing schedule for anyone to see. It will take the hammer on the head, but, eventually, Rich Barton is now committing multiple counts of wire fraud by blatantly scaling Regulation X, RESPA Section 8, and Sherman Antitrust Act violations online.
 
“For each purchase or sale of a property you complete with a Premier Agent Flex connection, you will pay Zillow a percentage of the full commission you expect to receive for your side of the transaction. The referral for each transaction is determined by (1) the location of the property and (2) the purchase or sale price of the property. The referral fee may vary by each Premier Agent Flex market. The referral fee for each Premier Agent Flex market is in the rate card below. If a property for a transaction is located outside of the Premier Agent Flex markets below, then the referral fee will be 35%.” Source: Zillow Flex Pricing
 
Zillow Flex is a broker-to-broker collusion scheme, where “partner agents” unlawfully agree to pay massive kickbacks to receive consumers’ information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices in violation of, inter alia, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, 12 C.F.R. § 1024.14

Consumers will always significantly overpay for Realtor commissions subject to hidden kickbacks and pay-to-play steering promoted in this scheme.
 
12 C.F.R. § 1024.14(b) (Regulation X) states: “No referral fees. No person shall give and no person shall accept any fee, kickback or other thing of value pursuant to any agreement or understanding, oral or otherwise, that business incident to or part of a settlement service involving a federally related mortgage loan shall be referred to any person. Any referral of a settlement service is not a compensable service, except as set forth in § 1024.14(g)(1). A company may not pay any other company or the employees of any other company for the referral of settlement service business.”
 
Zillow Flex (and subsequently Zillow 360) is a shell entity that does not act in a brokerage capacity. A mere possession of a real estate license is not sufficient to receive kickbacks under 12 C.F.R. § 1024.14(g)(1) exemption. This exemption is only valid “when all parties are acting in a real estate brokerage capacity” and does not authorize compensation to shell entities or sham arrangements that are not a bona fide “provider of settlement services.”

To comply in good faith with 12 C.F.R. § 1024.14(g)(1) (Regulation X) exemption and 12 U.S.C. § 2607(c)(3) (RESPA Section 8) exception for cooperative brokerage and referral arrangements, genuine real estate agents and real estate brokers must render referral agreements in a particular instance for a particular transaction.

United States federal antitrust laws prohibit consumer allocation and blanket referral agreements between real estate companies. The Supreme Court has further ruled that all violations of the Sherman Act also violate the FTC Act.

In fact, Zillow Flex, licensed in several states as a real estate shell entity, willfully chooses to disengage from offering genuine real estate representation services to consumers, as the core premise to create successful collusion with other brokers through interstate wire communication to further the scheme by means of blanket referral agreements that “per se” violate 15 U.S.C. § 1. What this means is Zillow Flex uses a shell real estate license for the sole premise to collect kickbacks and form hub-and-spoke relationships by forming a network of between independent Realtors.

The lesson for Zillow (and the rest of the referral fee broker-to-broker collusion scams) is this: NEVER break more than one law at the same time. That is when you get caught.
 
Related to: antitrust, wire fraud, kickbacks, Zillow, U.S. Department of Justice, Federal Trade Commission, Consumer Financial Protection Bureau

“Only other two-sided platforms can compete with a two-sided platform for transactions” Jonathan Hatch Danhui Xu

This distinction is ever relevant in the US online real estate sector. HomeOpenly is a two-sided marketplace where one side is consumers (home buyers and home sellers) and another side is Realtors. We need both to function.

Now, the question is: HomeLight a two-sided marketplace, as it claims? The answer is no.

HomeLight is a licensed broker, like any other. However, HomeLight does not perform any services of a Realtor, it organizes its competitors into a network — the same side of the market begins to agree on terms and sells services to consumers on the basis of agreements that restrain free trade outside of the scheme. Consumers hire two brokers with HomeLight, where one brokers does not do anything to earn a commission from a home sale or a home purchase.

In effect, HomeOpenly and HomeLight are never competitors, because it is impossible for a two-sided marketplace to compete with real estate brokers who are supposed to one of the sides on the platform as genuine users. At the same time, HomeLight as a brokerage that cannot become a genuine user on HomeOpenly because it does not offer any tangible services. I do not consider kickbacks and broker-to-broker collusion a tangible service, therefore, it can’t be offered on the platform.

HomeLight is a broker-to-broker collusion scheme, where “partner agents” unlawfully agree to pay massive kickbacks to receive consumers’ information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices in violation of, inter alia, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, C.F.R. § 1024.14.

Why can’t HomeLight simply abandon its brokerage status?

The HomeLight scam relies on a statutory loophole 12 C.F.R. § 1024.14(g)(1)(v) (Regulation X) and RESPA 12 U.S.C. § 2607(c)(3) that narrowly allow to receive payments pursuant to cooperative brokerage and referral arrangements or agreements between real estate agents and real estate brokers. This loophole, of course, does not allow for kickbacks between “shell” brokerage entities.

Shell entities, such as HomeLight, account for $15 billion in illicit kickbacks paid by consumers annually in a form of inflated broker commissions — the largest real estate scam in history. As long as brokers have a pathway to collusion, they will NOT compete for consumers with savings. Meaning, an unethical Realtor is more willing to pay kickbacks into HomeLight scam, rather than to offer that same money to consumers as savings on HomeOpenly.

Marketplaces compete with marketplaces, but active collusion between participants on the same side of the market causes damages to both: legit marketplaces and consumers.

To break this pattern of broker-to-broker collusion, specifically, to destroy Zillow Flex, Zillow 360, Xome, UpNest, Tomo Brokerage, SOLD.com, Rocket Homes, ReferralExchange, Redfin Partner Program, Realtor.com ReadyConnect Opcity, Ramsey Solutions ELP, Opendoor Brokerage, OJO Labs, Nobul, Neighborhoods.com (aka 55places), NAEBA, mellohome, Localize NYC, LemonBrew, Landed, IDEAL AGENT, HomeStory, HomeLight, homegenius by Radian, Home Captain, FastExpert, Estately by Realogy, EffectiveAgents.com, Clever Real Estate, Blend Realty, Better Real Estate, Agent Pronto, etc. is to build the “Google for real estate.”

Better remains one of the more controversial real estate companies due to its poor leadership fueled with massive VC capital. Their layoffs fiasco is merely the tip of the iceberg. The real problem with Better is price-fixing and unlawful kickbacks it receives from Realtors.
 
 “$2000 in Lender credits” refers to the amount by which your closing costs will be reduced if you use a real estate agent referred by Better Real Estate. The agent must be confirmed by Better Real Estate in a manner satisfactory to Better Mortgage Corporation in its sole discretion prior to issuance of the Closing Disclosure on the loan. The reduced rate will appear on the Closing Disclosure.”
 
Better Real Estate LLC offers a “discount” to consumers from a blanket referral fee earned, not from a commission earned. This is a form of price-fixing and is, effectively, a kickback derived from another kickback, instead of a legally negotiated buyer’s rebate mechanism.
 
 A “standard” referral fee (25%-35%) paid to Better Real Estate LLC on a buyer’s agent commission for a $1M home amounts to $9,000. This means that Better Real Estate LLC receives somewhere around $10,000 as a kickback from a random Realtor for the act of steering, while the consumer only gets $2,000 as a “discount.” This is not savings — this is plain collusion.
 
There is a lot to be said about the value of collusion: it is per se unlawful in the United States; it leads to higher profits at the expense of consumers; it reduces the competitiveness of the market; it limits open competition by deceiving, misleading and defrauding consumers. The core of collusion is that it is a weakness before a greater force called “the market.” The market is brutal and it has a long memory, especially in real estate.
 
When consumers begin to realize that Vishal Garg has cheated them out of tens of thousands in competitive tax-free buyer rebates, they will retaliate in more ways than one. Eventually, collusion yields terrible UX.
 
To build upon price-fixing with nearly a billion USD in funding is like building a luxury skyscraper on a foundation made of sand — it will fall, and it will fall fast and hard.
 
As always, it takes an outsider to break the status quo.

Related: Better Real Estate, antitrust, price fixing, wire fraud, kickbacks, RESPA, Sherman Act, FTC Act, market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, price-fixing practices, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, C.F.R. § 1024.14

Whenever I see a Realtor set their listing commissions at 0.95% vs 1%, or buyer rebates at 51% vs 50% this is not gaming the system, this is competition at work. Competition among Realtors results in lower costs of buying and selling homes, as well as better customer UX.
 
Sure, one might say that a Realtor does this as a “trick” to be shown ahead of competing Realtors with nearly identical pricing, but I see it as an opportunity to deliver a message to consumers that pricing does matter.
 
There is, of course, another side to setting prices where a third party does it for the Realtor.
 
In a hub-and-spoke type price-fixing conspiracy, all prices for Realtors are typically set exactly the same. Moreover, instead of competing for consumers with lower pricing, the Realtors in the hub are really competing for placement based on how much in kickbacks the hub is expecting to receive.
 
“In early 2016, we changed the pricing and structure of the Redfin Partner Program. Instead of paying 15% of the commissions’ partner agents earned through the program to us, partner agents began paying us 30%. At the same time, we began directly issuing a $500 check to certain partner program customers, partially offsetting the increase in referral fees paid by partner agents.”
 
Redfin’s most recent statement on the company’s website reads: “Since Partner Agents aren’t employed by Redfin, we can’t guarantee our 1%–1.5% listing fee or offer a Redfin Refund for customers who work with a Partner Agent.”
 
There are several of problems with fixing rates for competitors and allocating consumers to those same competitors, primarily, a lack of genuine competition. That 0.05% listing savings or 1% extra in buyer rebates may seem irrelevant, but, it is, in fact, the fragile force of competition at work.
 
With absolute certainty, Glenn Kelman has committed wire fraud by transmitting collusion with competitors on the Internet.
 
Redfin Partner Program is unlawful, but it has not been exposed by the industry because the entire industry is complicit. The scheme relies on an illicit referral network of over 11,600 Redfin Partner agents.
 
Redfin Partner Agents are independent Realtors firmly affiliated with various brokerages such as Berkshire Hathaway HomeServices, eXp Realty, Windermere Real Estate, Keller Williams Realty, Inc., RE/MAX, Coldwell Banker, NextHome, Inc., HomeSmart, Compass, John L. Scott Real Estate, CENTURY 21®, Realty ONE Group, Vylla, ERA Real Estate, Weichert, Realtors, Better Homes and Gardens Real Estate, Fathom Realty, Intero Real Estate Services, John R. Wood Properties, Worth Clark Realty, Sotheby’s International Realty, etc. What do any of them have anything to do with Redfin?
 
As always, it takes an outsider to break the status quo.

Related to: Redfin Partners, antitrust, price fixing, wire fraud, kickbacks, RESPA, Sherman Act, FTC Act, market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, price-fixing practices, 18 U.S.C. § 1346, 18 U.S.C. § 1343, 15 U.S.C. § 1, 15 U.S.C. § 45, 12 U.S.C. § 2607, C.F.R. § 1024.14

A copy of the author’s official request that asks the United States Federal Trade Commission, the United States Department of Justice, and the United States Consumer Financial Protection Bureau to investigate Zillow, Inc. subsidiary “shell” real estate brokerages for Zillow Flex and Zillow 360, among other programs; Zillow Group Marketplace, Inc.; and Zillow Home Loans, LLC operating in open collusion with “Zillow Flex Partner Agents” and “Zillow 360 Partner Agents” on the grounds of an alleged violation of the Federal Trade Commission Act of 1914 (15 U.S.C. Section 45) an alleged violation of the Sherman Antitrust Act of 1890 (15 U.S.C. Section 1) an alleged violation of RESPA Section 8 (12 U.S.C. 2607) as well as any other possible violations of antitrust and consumer protection laws currently ratified and enforced in connection with alleged broker-to-broker market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices.

Attn: Citizen Complaint Center, Antitrust Division
Department of Justice
950 Pennsylvania Ave., NW Room 3322
Washington, DC 20530

Attn: Office of Policy and Coordination
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Ave. NW Room CC-5422
Washington, DC 20580

Attn: CFPB Regulatory Implementation
Consumer Financial Protection Bureau
1700 G St., NW
Washington, DC 20552

Please find the information below with regards to possible antitrust laws and RESPA violations.

What companies or organizations are engaging in conduct you believe violates the antitrust laws?

Zillow Flex (via “shell” brokerages operated by Zillow, Inc.)
Zillow 360 (via “shell” brokerages operated by Zillow, Inc.)
1301 2nd Avenue, Floor 31
Seattle, WA 98101
Phone: (206) 470–7000
Licensed broker in Alabama 000128023–0
Licensed broker in Alaska 157723
Licensed broker in Arizona CO580407000
Licensed broker in Arkansas PB00085034
Licensed broker in California 1522444
Licensed broker in Colorado EC.100080923
Licensed broker in Connecticut (Zillow CT, LLC) REB.0793077
Licensed broker in Delaware RB-0020865
Licensed broker in District of Columbia REO98365391
Licensed broker in Florida CQ1058944
Licensed broker in Georgia 76885
Licensed broker in Hawaii RB-23130
Licensed broker in Idaho CO50816
Licensed broker in Illinois 478.012434
Licensed broker in Indiana RC51900252
Licensed broker in Iowa F06155000
Licensed broker in Kansas CO00003080
Licensed broker in Kentucky 237601
Licensed broker in Louisiana BROK.77092-CORP
Licensed broker in Maine AC90603333
Licensed broker in Maryland 5001260
Licensed broker in Massachusetts 7508
Licensed broker in Michigan 6505427377
Licensed broker in Minnesota 40638657
Licensed broker in Mississippi 23127
Licensed broker in Missouri 2020010153
Licensed broker in Montana RRE-BRO-LIC-79688
Licensed broker in Nebraska 202000935
Licensed broker in Nevada B.1002277.CORP
Licensed broker in New Hampshire 75732
Licensed broker in New Jersey 2076842
Licensed broker in New Mexico 9769
Licensed broker in New York 10991231981
Licensed broker in North Carolina C30388
Licensed broker in North Dakota 2826
Licensed broker in Ohio REC.2020001732
Licensed broker in Oklahoma 183652
Licensed broker in Oregon 201235057
Licensed broker in Pennsylvania RBR003965
Licensed broker in Rhode Island REC.0015982
Licensed broker in South Carolina 23960
Licensed broker in South Dakota 15196
Licensed broker in Tennessee 264500
Licensed broker in Texas 549646
Licensed broker in Utah 11735955-CN00
Licensed broker in Vermont 083.0650389-MAIN
Licensed broker in Virginia 226031797
Licensed broker in Washington 21212
Licensed broker in West Virginia 005388
Licensed broker in Wisconsin 835987–91
Licensed broker in Wyoming 235500

Zillow Group Marketplace, Inc.
1301 Second Ave., 30th floor, Suite 3000-A
Seattle, WA 98101
Phone: (206) 470–7000
NMLS 1303160

Zillow Home Loans, LLC
10975 El Monte
Overland Park, KS 66211
Phone: (206) 470–7000
NMLS 10287

Further, a partner network of an unknown number of real estate brokers who choose to execute blanket broker-to-broker referral agreements in an alleged collusion scheme via Zillow Flex and Zillow 360 paper brokerage schemes.

Acting as the “spokes” within the “hub-and-spoke” broker-to-broker collusion scheme, “Zillow Flex Partner Agents” and “Zillow 360 Partner Agents” are independent Realtors firmly affiliated with various brokerages such as Berkshire Hathaway HomeServices, eXp Realty, Windermere Real Estate, Keller Williams Realty, Inc., RE/MAX, Coldwell Banker, NextHome, Inc., HomeSmart, Compass, John L. Scott Real Estate, CENTURY 21, Realty ONE Group, Vylla, ERA Real Estate, Weichert Realtors, Better Homes and Gardens Real Estate, Fathom Realty, Intero Real Estate Services, John R. Wood Properties, Worth Clark Realty, Sotheby’s International Realty, etc.

Why do you believe this conduct may have harmed competition in violation of the antitrust laws?

Zillow Group Annual Report for the Fiscal Year Ended December 31, 2020 reads:

“We participate in large addressable markets of buying, selling, renting and financing residential real estate in the U.S. As we continue to move towards a transactional model focused on helping customers move, we estimate our TAM has expanded from $19 billion in U.S. residential real estate related advertising in 2019 (according to a Borrell Association report) to nearly $300 billion. Our TAM includes Zillow’s estimate of over $100 billion in referral fees derived from participating in real estate transactions with our partners (based on the 2021 National Association of REALTORS®U.S. Economic Outlook published in November 2021). In addition, we provide important adjacent services, including mortgages through Zillow Home Loans and title and escrow closing services through Zillow Closing Services. U.S. mortgage origination revenue represents a $155 billion annual opportunity (according to a 2021 Mortgage Bankers Association Report), while title and escrow represents a combined $26 billion annual opportunity (according to an American Land and Title press release dated April 7, 2021 and a report by Doma Holdings, Inc. published in May 2021).”

“In October 2018, we began testing a new Flex pricing model for Premier Agent and Premier Broker advertising services in limited markets. We now offer this pricing model to select partners, and provide it alongside our legacy market-based pricing model. With the Flex model, Premier Agents and Premier Brokers are provided with validated leads at no upfront cost and pay a performance advertising fee only when a real estate transaction is closed with one of the leads” where Zillow receives a kickback “for validated leads when we receive payment for a real estate transaction closed with a Flex lead.”

This is a problem for several reasons. First of all real estate agent commissions are protected from being “taxed” with kickbacks by RESPA Section 8 and Regulation X federal regulations. 12 C.F.R. § 1024.14(g)(1)(v) (Regulation X) and RESPA Section 8 12 U.S.C. § 2607(c)(3) narrowly allow payments pursuant to cooperative brokerage and referral arrangements between real estate agents and real estate brokers. This limited exemption on kickbacks only applies to fee divisions within real estate brokerage arrangements when all parties are acting in a real estate brokerage capacity. Zillow, as a licensed real estate shell entity, does not act in a brokerage capacity. This entity willfully chooses to disengage from offering real estate representation services to consumers. There is a big difference between a business arrangement where a party acts as a sham under the Real Estate Settlement Procedures Act (RESPA) or a bona fide provider of settlement services.

Zillow Flex shell real estate brokerage acts as a “bridge” for kickbacks to collect a “Thing of value” from random Realtors, disguised as “a performance advertising fee only when a real estate transaction is closed with one of the leads.” There is no such thing as “a performance advertising fee” between licensed brokers. Licensed brokers cannot legally advertise the services of competitors, to begin with.

Zillow Flex and Zillow 360 schemes violate 12 U.S.C. § 2607 and C.F.R. § 1024.14 because Zillow Group entity does not provide any legitimate real estate services as a licensed real estate agent — it operates as a shell entity to collect kickbacks from other agents under the perceived notion that such arrangement is sufficient to meet RESPA 12 U.S.C. § 2607(c)(3) allowance of payments pursuant to cooperative brokerage and referral arrangements between real estate agents and real estate brokers.

However, RESPA violation is not the “Elephant in the Room” problem here. The real problem here is the fact that Zillow Flex and Zillow 360 organize Realtors as a hub-and-spoke conspiracy that violates Sherman Antitrust Act, and subsequently, FTC Act: 15 U.S.C. § 1 and 15 U.S.C. § 45. Zillow Flex and Zillow 360 are broker-to-broker collusion schemes, where “Partner Agents” unlawfully agree to pay massive kickbacks to receive consumers’ information and engage in market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, and price-fixing practices. It takes two parties to agree to collude, and in this case, there are: (1) Zillow Group shell brokerage and (2) thousands of colluding Realtors tied into the hub with identical terms.

It is a per se violation of the Sherman Act for real estate brokers to agree on a “standard” referral fee that will be paid for producing a client. Real estate professionals are not allowed to enter into “standard” referral agreements because such agreements always restrict free trade. To comply in good faith with RESPA (12 U.S.C. 2607) Section 8 exception for cooperative brokerage and referral arrangements, legitimate real estate agents are only able to render referral agreements in a particular instance for a particular transaction.

Whatever economic justification particular price-fixing agreements may be thought to have, the law does not permit an inquiry into their reasonableness. They are all banned. Zillow 360 offers consumers a rebate that is price-fixed for services offered by a third-party broker, meaning one broker Zillow, now sets rebates amounts for other brokers outside of their firm. By law, all Realtors must compete for consumers and set prices individually. This means that each Realtor must define their rebates by competing for consumers with other Realtors.

If we go back to the beginning of this report, where Zillow Group claims that their “TAM has expanded from $19 billion in U.S. residential real estate related advertising to nearly $300 billion” the reason to maintain these hub-and-spoke schemes becomes self-evident: greed. The United States is undergoing a housing affordability crisis, and Zillow Group now aims to collect kickbacks from tens of thousands of Realtors to further increase the costs of buying and selling homes. Both Zillow 360 and Zillow Flex are products of collusion where prices and levels of services are set by the hub to rake commissions earned by the spokes — independent Realtors.

Thousands of uncompetitive Realtors would rather fork over 40% of their future commissions to Zillow than offer that same money to their clients. For example, on a purchase of a $4 million home, with collusion with Zillow Flex, a buyer agent commission easily amounts to $100K where a colluding Realtor keeps $60K and Zillow Flex takes $40K as a kickback. On the open market, that same Realtor can offer this $40K kickback to their client as a genuine rebate, making the entire home purchase more affordable. This is the difference between kickbacks and rebates — the same money, ending up in two very different bank accounts.

We, as consumers, are not the only victims of Zillow Flex and Zillow 360 schemes. Whenever Realtors begin to organize their operations into networks, whenever Realtors refuse to provide a tangible service, whenever Realtors allocate consumers for kickbacks, whenever Realtors set prices for one another — the open competition in the entire sector suffers.

Competitive Realtors who refuse to participate in wire fraud arrangements with Zillow receive less business. Genuine competitive online marketplaces where Realtors compete for consumers, such as HomeOpenly, receive less attention from Realtors and consumers, leading to lesser network effects. Genuine Realtors who offer genuine listing savings and buyer rebates promoted online receive fewer benefits for doing so — their savings no longer have the required “bang for the buck” incentive to attract a large number of customers.

Zillow Flex and Zillow 360 are not merely products of broker-to-broker collusion, these are products of wire fraud as defined by 18 U.S.C. § 1346 and 18 U.S.C. § 1343 because the network effects of the Internet and Zillow’s dominant position in the market work together to further the scheme across all 50 US states and Washington DC.

What is your role in the situation? For instance, are you a user, customer, competitor or supplier?

I currently maintain HomeOpenly marketplace. HomeOpenly is an Open Real Estate Marketplace™ designed and built to improve the homeownership experience in the United States.

HomeOpenly is a technology company that designs, builds, and maintains a series of online marketplace solutions with a focus on a home search, automated valuation modeling (AVM), home buyer’s and seller’s representation services, mortgage origination, refinance, home insurance, renovation, design, staging, home inspections, home security, moving, home maintenance, title, escrow, cash offer stand-in programs, home warranty, and other real estate products and services.

HomeOpenly operates subject to a 0% rake as our primary competitive advantage to establish a competitive fee schedule for service providers in the real estate industry with the use of network effects. HomeOpenly is not a paper broker and all service providers on our network compete for consumers individually. Our efforts are actively hampered by the anticompetitive practices of Zillow Flex and Zillow 360.

Successful implementation of an Open Marketplace™ platform in the real estate industry requires full enforcement of existing antitrust laws that are enacted to protect US consumers.

As long as paper brokers can allocate consumers as leads between independent service providers in exchange for blanket referral fees, Open Marketplace™ continues to operate at a competitive disadvantage. Consumer welfare is always improved by open markets, the same way it is always diminished with collusion.

If you have a question or comment about an antitrust issue, you may submit it to the Bureau of Competition at the United States Federal Trade Commission and/or to the Antitrust Division of the United States Department of Justice

If you have a question or comment about federal consumer protection financial laws, including RESPA, you may submit it to the Office of Enforcement of the United States Consumer Financial Protection Bureau

A copy of the author’s request that officially asks the United States Federal Trade Commission (US-FTC), the United States Department of Justice (US-DOJ), and the United States Consumer Financial Protection Bureau (US-CFPB) to investigate Uber (NYSE: UBER) Lyft (NASDAQ: LYFT) Amazon Home Services (NASDAQ: AMZN) Handy HQ (HomeAdvisor, NASDAQ: IAC) Porch Group (NASDAQ: PRCH) DoorDash (NYSE: DASH) Gopuff (GoBrands, Inc.) Grubhub (NASDAQ: GRUB) Amazon Marketplace (NASDAQ: AMZN) Walmart Marketplace (NYSE: WMT) Realtor.com ReadyConnect Opcity (NASDAQ: NWSA) Zillow Flex (NASDAQ: ZG) Zillow 360 (NASDAQ: ZG) Opendoor Brokerage (NASDAQ: OPEN) Redfin Partner Program (NASDAQ: RDFN) Xome Concierge (NASDAQ: COOP) Rocket Homes (NYSE: RKT) mellohome (NYSE: LDI) HomeLight (HomeLight, Inc.) OJO Labs (OJO Labs, Inc.) Better Real Estate (Better Holdco, Inc.) Blend Realty (NYSE: BLND) Offerpad (NYSE: OPAD) Opendoor (NASDAQ: OPEN) Coinbase (NASDAQ: COIN) FTX (West Realm Shires Services, Inc.) Gemini (Gemini Trust Company, LLC) Crypto.com Exchange (Foris DAX, Inc.) Binance (BAM Trading Services Inc.) Kraken Digital Asset Exchange (Payward, Inc.) Cash App (Cash App Investing LLC) Amazon Flex (NASDAQ: AMZN) Apple Pay (NASDAQ: AAPL) Google Pay (NASDAQ: GOOGL) Google Adsense (NASDAQ: GOOGL) for possible violations of antitrust and consumer protection laws currently ratified and enforced in connection with alleged market allocation, consumer allocation, false advertising, unlawful kickbacks, wire fraud, issuing and passing digital pirate currencies intended for use as current money, and price-fixing practices.

Attn: Antitrust Division Office of Operations
Department of Justice
950 Pennsylvania Ave., NW Room 3322
Washington, DC 20530

Attn: Office of Policy and Coordination
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Ave., NW Room CC-5422
Washington, DC 20580

Attn: CFPB Regulatory Implementation
Consumer Financial Protection Bureau
1700 G St., NW
Washington, DC 20552

The year 2022 is very likely the final year of a long-standing battle in e-commerce that will redefine the United States e-commerce as either: (1) highly raked, collusive, price-fixed, pay-to-play, allocated, low-quality, false ads channel, or (2) a pattern of novel open e-commerce channels. There is really nothing in between.

Violations of 15 U.S.C. § 1 Sherman Antitrust Act, violations of 15 U.S.C. § 45 FTC Act, violations of 12 U.S.C. § 2607 and C.F.R. § 1024.14 RESPA are presently and successfully aided by electronic interstate communications, otherwise known as wire fraud.

Further, violations of Article I, Section 8, Clause 5 of the United States Constitution in the United States that prohibits exchange, maintenance, coinage, issuing, and passing alternative digital currencies intended for use as current money, is not merely wire fraud but further, a conspiracy against the United States.

The severity of the damages and scale of these schemes must become the new normal for the DOJ, FTC, and CFPB when it approaches the sector dominated by (5EA) companies at the top of Nasdaq 100 that control over 60% of the entire Nasdaq 100 by market capitalization value.

Collusion agreements and pirate currency systems, supported by network effects of the Internet, have proven to be highly effective. Today, price-fixing and market allocation agreements are openly offered “as a service” to consumers in a “hub-and-spoke” fashion in massive trillion-dollar markets: online travel stay booking, residential online real estate, online home services, online ride-hailing, online food delivery, and other sectors of the United States economy.

Further, alternative digital currencies have now grown into a cult (see Web3) of VC-backed consumer-facing schemes and exchanges that operate in a number of sectors, where wire transfer and wire exchange fees alone are valued in tens of billions USD. The pirate digital currencies are a form of wire fraud that creates a supply of seemingly legitimate counterfeit money, in direct competition with the legal tender of the United States.

These schemes are not harmless.

(1) They are harmful to United States consumers.

(2) They are harmful to open e-commerce in the United States.

(3) They are harmful to legitimate online platforms that develop and maintain compliant digital services in the United States.

(4) They are harmful to individual compliant businesses that operate outside of named “hub-and-spoke” conspiracies.

(5) They are, eventually, harmful (yet seemingly beneficial in the short term) to the millions of “spokes” that collude with a handful of “hubs” in the United States.

(6) They are harmful to the United States government consumer protection agencies that must spend taxpayer resources to investigate and prosecute them.

(7) They are harmful to the United States court systems that must spend taxpayer resources to listen to their appeals.

(8) They are harmful to all United States citizens, friends, and visitors, even if they do not directly engage with these schemes, by the mere presence of wire fraud on the Internet.

(9) They are harmful to compliant innovation in any sector where they exist.

Subjected to these schemes, people, eventually, do not receive a full benefit of trust on the Internet, leading to lower aggregate sales volume via the Internet and the subsequent damages to the entire information sector around the world.

The United States consumer protection agencies must take these facts at full value because the schemes and companies listed in this report are real, and they are not new.

The aggregate damages that scaled wire fraud produces by means of false advertising, market allocation, consumer allocation, price-fixing collusion, exchange and distribution of illicit currencies, and hub-and-spoke conspiracies are as clear as day. Go look at them, and see what they do, count how many millions of third-party sellers signed allocation and price fixing (price parity) agreements with Amazon. These numbers don’t lie. There is no secret here.

There is, however, a pattern of wire fraud. From the millions of price-fixing agreements between Uber and local Uber drivers to hundreds of thousands price-fixing agreements between Realtor.com-Opcity and local Realtors – they are all exactly the same, a hallmark of a hub-and-spoke conspiracy schemes where spokes no longer act in any meaningful competition with one another, and act as hub’s integral vassals.

The United States is not the land governed by feudal tenure. The United States is the land of the free speech. The United States is the land of the free competition. The United States is the land of the law. The United States is the land of open and fair commerce.

These collusion schemes operate in plain sight because the Internet is not a plain sight environment. Wire fraud can be (and is currently being) aided by a “lipstick on a pig” flashy websites, and/or Super Bowl ads, Google Ads, and Facebook Ads, and other mainstream consumer exposure channels.

Open e-commerce is a pattern of communicating the availability of products and services to consumers because that relies on the fragile yet very powerful forces of an open competition between third parties, aka network effects produced by the Internet. Open e-commerce is a pattern of complaint platforms that encourage competition between third parties, rather than force third parties into agreements that restrain free trade.

The open competition relies on a single most powerful law for support: Section 1 of the Sherman Antitrust Act. Without the proper enforcement of Sherman Act, open e-commerce is powerless against raked e-commerce. This law must be enforced if the Internet is to produce a service of competitive and transparent wiring. The wiring of the Internet is not accidental, it is deliberate.

Some of the largest digital platforms in the United States, such as Amazon Marketplace and Uber, are a product of deliberate hub-and-spoke consumer allocation and price-fixing between millions of small competitors tied into these hubs by the Internet. The Internet becomes integral to these schemes because it allows a much greater form of communication freedom than any other communication methods before it.

For example, Amazon third-party sellers remain small competitors to Amazon, bound as independent entities into a network secured by approximately two million identical and uncompetitive consumer allocation agreements with the hub. Each one of these illicit agreements places third-party sellers into collusion with Amazon, rather than competition to build a better Amazon elsewhere — why build a better Amazon if one can settle for collusion with it? There is no reason, in fact, some Amazon sellers are now massive VC-backed companies.

The United States attorney is obligated to advocate, on behalf of consumers, for the maximum fines available for these violations. The false notion that “big is bad” will not deliver these fines. This is why, thus far, the government has delivered no significant fines, and it has delivered no significant progress in e-commerce. The money derived by means of wire fraud is there. The law is there. You have the information and resources that you need. Where is your progress?

The United States attorneys have not delivered on the antitrust front because you had refused to accept the full weight of the fact that e-commerce is highly raked, and it consists of trademarked and nationally-known massive schemes that all utilize the Internet to promote activities outlawed under the federal law by means of wire communications between state borders.

Wire fraud is a federal crime, not a misdemeanor, and the United States government cannot allow individuals and corporations to earn a profit on such a massive scale by means reducing the integrity of the entire Internet, by means of reducing competition, by means of illicit agreements that restrain free trade, coupled by false advertising.

The following list of individual Internet schemes must become the aggregate core target for the United States government in 2022. These schemes are at the center of some of the biggest, the most damaged, and the most problematic B2C markets in the United States:

(1) B2C sales of Realtor services

(2) B2C sales of professional home services

(3) B2C sales of hotel stays

(4) B2C sales of consumer goods

(5) B2C sales of local transportation

(6) B2C sales of food delivery

(7) B2C sales of Cryptocurrencies (whatever that is)

(8) B2C sales of mobile phone applications and digital services

The following entities currently engage in price-fixing outside their “firm” with third party independent contractors via mobile online applications and websites across state borders:

Uber Technologies price fixes rates with a network of millions third party drivers and food delivery drivers (NYSE: UBER)

Lyft Platform price fixes rates with a network of millions third party drivers (NASDAQ: LYFT)

Amazon Home Services price fixes rates with a network of thousands third party home services pros (NASDAQ: AMZN)

Handy HQ price fixes rates with a network of thousands third party home services pros (HomeAdvisor, NASDAQ: IAC)

Porch Group price fixes pay rates with a network of thousands third party home services pros (NASDAQ: PRCH)

DoorDash price fixes pay rates with a network of millions third party delivery drivers (NYSE: DASH)

Gopuff price fixes pay rates with a network of millions third party delivery drivers (GoBrands, Inc.)

Grubhub price fixes pay rates with a network of millions third party delivery drivers (NASDAQ: GRUB)

The following entities currently engage in consumer allocation outside their “firm” with third party independent sellers via mobile online applications and websites across state borders:

Amazon Marketplace allocates consumers and price fixes terms with a network of millions third party sellers (NASDAQ: AMZN)

Walmart Marketplace allocates consumers and price fixes terms with a network of millions third party sellers (NYSE: WMT)

The following “shell” real estate entities currently engage in consumer allocation and price fixing outside their “firm” with third party independent Realtors via mobile online applications and websites across state borders:

Realtor ReadyConnect Opcity allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: NWSA)

Zillow Flex allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: ZG)

Zillow 360 allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: ZG)

Opendoor Brokerage allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: OPEN)

Redfin Partner Program allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: RDFN)

Xome Concierge allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NASDAQ: COOP)

Rocket Homes allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NYSE: RKT)

mellohome allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NYSE: LDI)

HomeLight allocates and price fixes commission rates with third party Realtors networked into tens of thousands (HomeLight, Inc.)

OJO Labs allocates and price fixes commission rates with third party Realtors networked into tens of thousands (OJO Labs, Inc.)

Better Real Estate allocates and price fixes commission rates with third party Realtors networked into tens of thousands(Better Holdco, Inc.)

Blend Realty allocates and price fixes commission rates with third party Realtors networked into tens of thousands (NYSE: BLND)

The following direct cash home buying (iBuying) real estate entities currently engage in false advertising and make illicit “consumer steering” offers to third-party Realtors outside their “firm” via mobile online applications and websites across state borders:

Offerpad offers illicit steering incentives to Realtors (NYSE: OPAD)

Opendoor offers illicit steering incentives to Realtors (NASDAQ: OPEN)

The following entities currently engage in exchange, maintenance, coinage, issuing, and passing alternative digital currencies intended for use as current money via mobile online applications and websites across state borders:

Coinbase sells pirate digital currencies intended for use as current money (NASDAQ: COIN)

FTX.US sells pirate digital currencies intended for use as current money (West Realm Shires Services, Inc.)

Gemini sells pirate digital currencies intended for use as current money (Gemini Trust Company, LLC)

Crypto.com Exchange sells pirate digital currencies intended for use as current money (Foris DAX, Inc.)

Binance.US sells pirate digital currencies intended for use as current money (BAM Trading Services Inc.)

Kraken sells pirate digital currencies intended for use as current money (Payward, Inc.)

Cash App sells pirate digital currencies intended for use as current money (Cash App Investing LLC)

The following entities currently engage in employee misclassification via mobile online applications and websites across state borders:

Amazon Flex misclassifies delivery drivers as independent contractors  (NASDAQ: AMZN)

The following entities currently engage in tying of digital services and market allocation via mobile online applications and websites across state borders:

Apple Pay unlawfully ties into Apple App Store (NASDAQ: AAPL)

Google Pay unlawfully ties into Google Play Store (NASDAQ: GOOGL)

Google Adsense allocates digital advertising space with a network of competing third party media publishers (NASDAQ: GOOGL)

Successful implementation of open e-commerce in United States requires full enforcement of existing antitrust laws that are enacted to protect consumers.

If you have a question or comment about an antitrust issue, you may submit it to the Bureau of Competition at the United States Federal Trade Commission and/or to the Antitrust Division of the United States Department of Justice.

If you have a question or comment about federal consumer protection financial laws, including RESPA, you may submit it to the Office of Enforcement of the United States Consumer Financial Protection Bureau