Background on Herbalife-Related Businesses

• Patricia (“Tish”) Rochin owned and operated A Wealthy U (AWU) (www.awealthyu.com) (domain registration attached as Rochin Exhibit A , a website that provided members with training and recruiting tools that could be used to build their Herbalife businesses.  The domain registration lists Tish Rochin as the owner.  In April 2014, following reports of investigations into Herbalife’s business practices by the Federal Trade Commission (“FTC”) as well as the Federal Bureau of Investigation (“FBI”) and U.S. Attorney’s Office in Manhattan, the AWU website began redirecting to www.ahealthyu.com (see infra), but the AWU website can still be viewed at http://web.archive.org/web/20130518053416/http://awealthyu.com/.

• AWU also hosted the Growth into Greatness (GIG) Herbalife recruiting program operated by Larry Thompson; Pershing Square understands that Thompson is Rochin’s brother.1  The GIG section of the AWU website is no longer active, but can be viewed at  http://web.archive.org/web/20010206185327/http://www.awealthyu.com/gig/gigaipg1.htm.2  Thompson was an early member of Herbalife’s senior management team, serving first as Vice President of Sales from 1980 to 1986, and then as Executive Vice President of Sales from 1986 until 1993.  See Herbalife 1987 10-K, Rochin Exhibit B at 25.  Thompson also served on Herbalife’s Board of Directors from November 1986 (see id. at 8) until February 1993 (see Herbalife 1993 Proxy Statement, Rochin Exhibit C at 3 n.2).  Herbalife fired Thompson in 1993 for “conduct detrimental to Herbalife” and paid him a “substantial settlement” in return for his agreement to no longer be involved with Herbalife.  Rochin Exhibit D at ¶¶ 9-10.  A proxy statement issued by Herbalife in April 1993 noted that Thompson owned 9.2% of the company’s common stock at that time.  Herbalife 1993 Proxy Statement, Rochin Exhibit C at 3.

• Rochin also operates A Healthy U (AHU) (www.ahealthyu.com), a website that promotes Herbalife products and provides links to an Herbalife website where prospective customers can set up a customer account (domain registration attached as Rochin Exhibit E.  The domain registration lists Tish Rochin as the registrant, and uses the address 3000 Custer Rd. Ste. 270-379, Plano, Texas 75075.  Id. at 2.

• Although he is no longer connected to Herbalife, Larry Thompson now operates a multi-level marketing (MLM) consultancy, and refers to himself as “Larry Thompson:  Mentor to the Millionaires.”  (www.lt-online.com; www.larrythompsononline.com; https://www.facebook.com/larrythompsononline.)3

Primary Source Data on Business Practices

Videos4

• Rochin’s 2007 Herbalife Chairman’s Club profile video, available at https://hd.wistia.com/medias/30sdge39im, begins by noting that, before she became involved with Herbalife, Rochin was a truck driver.  The video shows a clip of Herbalife founder Mark Hughes saying the following about Rochin:  “She used to be a truck driver, and she talked like a truck driver when I first met her.  And it was really something.  We had to tone her down, but she has done so well.”  (0:35-0:44.)  Rochin then describes the immediate and substantial growth in her income after starting with Herbalife.  “[W]hen it started growing, and it went from like 1,500 to 4,000 to 7,000 to 15,000 [dollars ] in like a three month period . . . I couldn’t believe it.  What Mark [Hughes] said was gonna happen happened.  And when I got in, they said in six months you’ll be making this much money, and I did. . . .  It just got to be too much money.  You always think they’re going to come and get it, or somebody is [laughter].  Everything that they’ve told us would happen has happened, and more.”  (1:22-1:58.)  Soon after, Rochin describes her large ranch, and how she has hired people to “take care of the grounds and the cows, and I got my horse trainer who comes and helps me with the horses and teaching me to ride.”  (2:24-2:39.)  Acknowledging that speakers at Herbalife events often flaunt “their fancy cars, you know they’ve got their Porsches and stuff,” Rochin continues, “Well I’m not fussy.  [Showing a photo of her collection of farm vehicles.]  I got my Lincoln, I got my pick-up truck, my John Deere, my Honda, my four wheelers—I got four of those things—and my two horses.  And if that won’t get me there, I can go on my boat [applause].”  (2:55-3:20.)  The video concludes with additional descriptions of Rochin’s ranch.  “I can’t even believe that God would allow me to live here . . . it’s unbelievable,” she says.  (4:07-4:14.)

• Larry Thompson hosted a network marketing seminar called “30 Year Millionaire Training,” and produced a “highlight” video from the seminar, which is available at https://hd.wistia.com/medias/fgt9u6hxnw.  The video features a number of clips showing both Thompson and Rochin promoting the Herbalife business opportunity, interspersed with enthusiastic testimonials from attendees.  Speaking about how she attracted recruits to her Herbalife business, Rochin notes that “[w]e were having so much fun, they wanted to be a part of it.  And that’s what you gotta keep in mind too.  Keep it fun, simple, magical.”  (3:46.)  Describing what he considers to be a good sales pitch for potential recruits, Thompson tells his audience that “[a] lot of you [are] talking about $50,000 a month, and twenty zillion dollars a day.  I’m gonna tell you what’ll get you business.  $250 a week to $1,000 a month part-time would get everyone’s attention you could think of.”  (4:03.)  See also 2:45 & 3:13 for other Thompson clips.

• On his website, Thompson also appears in a biographical video.  See https://hd.wistia.com/medias/9fofzraiw5; see also www.lt-online.com/larrys-story/.  The narrator opens the video as follows: “Mr. Larry Thompson—the most experienced active individual in the network marketing industry today.  His experience over 40 years includes developing successful distributor organizations and successful network marketing companies.  His reputation in the industry and experience is unparalleled.”  Discussing Thompson’s role in growing Herbalife’s business in particular, the narrator says, “[Thompson] is well known for being the driving force behind Herbalife International’s unprecedented success.  His sales, teaching and marketing philosophies created a solid foundation which have catapulted Herbalife into the giant they are today.  Larry’s success in building corporations comes from his passion and his ability to develop and equip the ordinary individual [with] the skills necessary to become an extraordinary distributor.”

• In an interview entitled “Conversations with a Legend” and available at https://hd.wistia.com/medias/l6ptqnqxe2 (see also https://www.facebook.com/ConversationsWithALegend for a Facebook website dedicated to this conversation series), Thompson discusses the history of the MLM industry, noting that originally participants were called “pyramiders” until Amway’s consent decree with the FTC in 1979.  Thompson then states that his “hat is always off to those guys” at Amway who “fought for our industry.”  (17:08-17:37.)  Referring to his ability to communicate with others, Thompson says, “I understand my communication gift.  And it’s an anointed gift. . . .  It’s not me.  It’s divine provenance who gave me that.”  (19:35-19:59.)  To encourage struggling distributors to continue investing in the business, Thompson presents an analogy to professional baseball.  Thompson tells the audience that a baseball player does not go directly to the New York Yankees, but rather must make his way up through the “farm team” before he gets to “the show.”  “And then when you do get to be a New York Yankee, there’s only three or four guys on that whole team that are superstars, and everybody else is support . . . .  There’s only a few guys that hit .300, which means seven out of ten they don’t hit the ball at all. . . .  [M]ost of them are not even that good of batters. . . .  And what has happened in our [MLM] industry is we’ve tried to make everybody the superstar New York Yankee, and say you have got to be the leader, you are the one.  And we’ve forgotten about how you get there.”  Thompson then explains that upline mentorship is key.  (26:49-28:09.)  Thompson also refers to “Tish Rochin, the lady truck driver,” and her Herbalife success story, without mentioning that Rochin is his sister.

Recruiting Materials

• Rochin’s A Wealthy U website provided its members with various Herbalife recruiting tools and scripts.  Indeed, upon reaching the site, visitors were greeted with the following message:  “Hi, this is Tish.  Welcome to my site.  Click here so you can hear what’s going on with some of my friends that I’m working with right now.  We’re so excited that the same thing that’s happened for them can happen for you.”  See http://web.archive.org/web/20130518053416/http://awealthyu.com/.
  • In a welcome letter, Rochin congratulated her recruits for taking “the first step to becoming financially independent!”  Rochin further noted that “[i]f I can do this from my dining room table and be successful, so can you!  The Very Best Is Here Now!”  Rochin Exhibit F, available at http://web.archive.org/web/20050117012656/http://www.awealthyu.com/benson/Docs/cust%20Pac%200801/DISTRIBUTOR%20TRAINING%20PACKAGE.doc.
  • In a template on which AWU members could list their “customers,” Rochin described the three types of Herbalife customers:  “A ‘Consumer’ loves the product enough to commit to buying 100vp [volume points] each month for the rest of their life;” “A ‘Retailer’ is a Distributor or Supervisor who produces volume by successfully building a ‘Consumer Group’; and “A ‘Builder’ is a Supervisor who is successfully training members within all 3 groups in their own business.”  Rochin Exhibit G, available at http://web.archive.org/web/20050225095522/http://www.awealthyu.com/benson/Docs/visuals/3CustBlueprint.doc.
  • Rochin then provided her distributors with a “Customer Follow-Up Script” that encouraged those distributors to “advance [a] customer to distributor” by the 21st day after a customer begins on Herbalife products.  Rochin Exhibit H at 2, available at http://web.archive.org/web/20050321021937/http://www.awealthyu.com/benson/Carol’s/Customer%20Follow-Up%20Script.doc.  The script told the distributor to “be looking for” whether a target is “coachable/teachable,” and whether “somewhere along the way of doing [customer] follow-up, you heard an indication they were dissatisfied with their job, lifestyle, income, etc.”  Id.  Then the script implored the distributor to “MAKE 1 OF THESE 3 MAGICAL STATEMENTS: (Or combination of the 3)  1.  ‘My business (or Herbalife) is out of control & I (or they) need help.’  2.  ‘You have such a great personality.’  (or whatever is pertinent)  ‘I/We could use someone like you.’  3.  ‘You could do what I do.  You’ve been sending me referrals & doing so great.’  THEN SIMPLY ASK *IF I CAN SHOW YOU HOW TO MAKE AN EXTRA ___$$$$ AROUND WHAT YOU’RE CURRENTLY DOING, WOULD YOU BE INTERESTED IN KNOWING HOW?‼!”  Id.  See also Rochin Exhibit I, available at http://web.archive.org/web/20041213052915/http://www.awealthyu.com/benson/Docs/Distributor%20%20Follow%20up%20and%20Tracking%20Sheet.doc, for a checklist used to assist Rochin’s distributors in following up with and tracking potential recruits.
  • On an AWU webpage entitled “Recruiting Post Card,” Rochin told her Herbalife distributors that “1 sure way to get your recruiting phone to ring is this postcard method.  The post card is a hand written and addressed 3×5 card sent in the mail that says . . . ‘I’ve been wanting to talk with you about a part time position with my company . . . .”  See Rochin Exhibit J for a screenshot.  The webpage then instructed distributors that they “need to send at least 2000 [postcards] a month and be consistent.”
  • In a flier that seeks to persuade her Herbalife distributors to progress from “Senior Consultant” to “Platinum Success Builder,” Rochin claims that as a Success Builder, the distributor will make more profit ($420 instead of $280 on an order of $1,000) in less time.  Rochin Exhibit K [$420 v $280], available at http://web.archive.org/web/20050225083335/http://www.awealthyu.com/benson/Docs/visuals/You%20Choose%20$280%20vs%20$420.doc.  Of course, the upgrade to Success Builder in most cases also requires the distributor to purchase a large volume of Herbalife products—which is not made clear on the flier.  These kinds of orders by distributors generate revenue for Herbalife and commissions for upline distributors, and create an illusion of retail demand for Herbalife products.
  • Rochin also provided her distributors with sample advertisements to use on both retail and recruiting targets.  In the recruiting advertisement, Rochin claimed that “10-12 hours per week” could net a new Herbalife distributor “$12,000-$60,000/year.”  See Rochin Exhibit L for a screenshot, also available at http://web.archive.org/web/20010331041155/http://www.awealthyu.com/sample_ads.htm.
  • Rochin further offered her distributors an information sheet entitled “Diabetes Product & Testimonial Spotlight,” which suggests—without foundation—that using Herbalife products can benefit those with diabetes.  While the information sheet includes a disclaimer in small font at the end of the document, saying, “Our products are not intended to diagnose, treat, cure or prevent any disease,” it also stated that the “BENEFITS of using Herbalife . . . Reduc[ing the] risk of becoming a diabetic, by as much as 60%.”  Rochin Exhibit M at 2, available at http://web.archive.org/web/20041223093812/http://www.awealthyu.com/benson/Docs/ProductSpotlight/Diabetes%202%20cover%20pages.doc.  Given that the document was hosted by the AWU website, it appears that the information sheet was intended to be used by distributors to convince potential recruits that they could make money selling Herbalife products at retail based on spurious health claims.  See also Rochin Exhibit N, available at http://web.archive.org/web/20050225082051/http://www.awealthyu.com/benson/Docs/Cheat%20Sheet%20for%20Herbalife%20Products.doc, for a list of diseases and ailments, including AIDS, cancer, emphysema, multiple sclerosis, scurvy, and “stage fright,” for which Herbalife products allegedly provide “adjuvant nutrition.”

• In 1992, Thompson, along with Larry Huff, another senior Herbalife distributor, helped create Herbalife’s “Wealth Building program”—an earlier version of Herbalife marketing plan, in which distributors could reach higher levels of the marketing plan by ordering large volumes of Herbalife products (much like the company’s marketing plan today).  See Rochin Exhibit O at 2 (Dana Wechsler Linden & William Stern, Betcherlife Herbalife, Forbes, Mar. 15, 1993, at 46); see also Rochin Exhibit P at 1-2 (Laurie P. Cohen, Herbalife’s Plan Is Ambitious But Criticized, Wall St. J., July 30, 1992, at C1).  Rochin and Thompson adopted the same “wealth building” nomenclature for a series of AWU recruiting and training programs that members could pay to join:
  • Rochin Exhibit G is a distributor welcome letter that refers to AWU’s “Wealth Building Training System.”
  • Rochin Exhibit Q, available at http://web.archive.org/web/20041224221927/http://www.awealthyu.com/benson/Downloads/Cert2.PDF, is a certificate given to distributors for “achieving” the status of “Platinum Wealth Builder” within Rochin’s and Thompson’s “Growth Into Greatness” (GIG) Herbalife recruiting program (see infra for more information regarding GIG).
  • Rochin Exhibit R, available at http://web.archive.org/web/20010206185512/http://www.awealthyu.com/wealthbuilder_personal_achieveme.htm, is a screenshot of an AWU webpage that detailed the “Wealthbuilder Personal Achievement Levels” a distributor could reach, as well as the accompanying benefits of each level.  For instance, “Wealthbuilder Qualification” requires a 1,000 volume point product order and “entitles [the distributor] to the full twelve-week Wealthbuilder Training Course and additional mentors . . . .”  In reality, the “personal achievement levels” promoted inventory loading by encouraging distributors to place large orders for Herbalife products.  Higher levels entitled a distributor to training and mentoring from Thompson personally.  This webpage also referenced the GIG program (“Those who achieve the Cell Instructor Level by April 2, 2001 will be the leadership that will lead us to complete the Growth Into Greatness Goals for Mark Hughes Birthday on January 1, 2002.”).  See infra for more on the GIG objectives.
  • Rochin Exhibit S, available at http://web.archive.org/web/20041213044420/http://www.awealthyu.com/benson/Docs/112202docs/Office%20Setup%20Worksheet%20For%20WB.doc, is a worksheet that offered guidance to new distributors on how to “set up” their home “office.”  The worksheet, which encouraged distributors to “Register with the Wealth Builder Community,” told them, “A good suggestion is to always reinvest the cost of the product into more products.”  As mentioned above, the purchase of products by distributors generates revenue for Herbalife and commissions for upline Supervisors, and generates the appearance of retail demand.
  • Rochin Exhibit T, available at http://web.archive.org/web/20090507085046/http://www.awealthyu.com/benson/2BensonWheel/newsletter/index.htm, is a screenshot of a newsletter written by Thompson and hosted on the AWU website that repeatedly refers to the “Wealth Building System.”  Thompson told new recruits that “[t]here is a vehicle that has the power to change human circumstances—regardless of the current economy.  That vehicle is the Wealth Building System. . . .  With Wealth Building, we have created a new era of opportunity for people to completely revolutionize their lives.  Regardless of their age, their background, their education, their company affiliation or their skills, this program provides people with the answers for adding more to their lives—more rewarding careers, more money, more time, more personal satisfaction, more meaningful friendships, and more reasons to get excited about the future again.”  The bottom of the webpage also referred to the “Growth Into Greatness” program (see infra).

• The Growth Into Greatness program, spearheaded by Thompson, was an additional platform used to recruit new Herbalife distributors.
  • On the former GIG website (www.growthintogreatness.com), Thompson told the story of going from being a construction worker who lived “paycheck to paycheck” to “creat[ing] an incredible fortune,” emphasizing that “[t]oday I am a very wealthy man.”5  The website is no longer active, but can be viewed at http://web.archive.org/web/20041207002647/http://growthintogreatness.com/welcome.htm.  See also Rochin Exhibit U for a screenshot.  Thompson told readers that “[t]o build wealth it only takes three things:  1. Someone who knows the skills: (I DO!);” “2. Someone who is willing to teach the skills, and (I AM!);” “3. Someone who is willing to learn the skills (ARE YOU?).”  Thompson continued, “What has happened to me and to many others I have mentored, can happen for you.  Do you have the desire, teachability, and willingness to try?”  See also http://web.archive.org/web/20010331030444/http://www.awealthyu.com/gig/gigaileadership.htm for the version of this webpage that was hosted on the A Wealthy U website.
  • The GIG website offered new recruits the opportunity to purchase “learning modules” for $49.99-$99.99 each, or $299.99 for “the complete program.”  See Rochin Exhibit V for a screenshot, also available at http://web.archive.org/web/20041207002158/http://growthintogreatness.com/programs.htm.  As with other business methods sold to aspiring Herbalife distributors, the purchase of these learning modules increased the amount of money recruits lost before realizing that they could not make money pursuing the Herbalife business opportunity.
  • Although the GIG program was framed as a general MLM training program, in fact, GIG was focused on recruiting new Herbalife distributors.  A webpage entitled “GIG Objectives,” hosted on Rochin’s A Wealthy U website, noted that the objectives are to “achieve the following by Mark Hughes[’] birthday January 1, 2001[:]  1000 GET Team Members[,] 400 Millionaire Team Members[, and] 100 Presidents [sic] Team Members.”  Rochin Exhibit W, available at http://web.archive.org/web/20010303011849/http://www.awealthyu.com/gig/gigaiobjectives.htm.  The webpage also stated that the “[o]bjectives of Growth Into Greatness Campaign 2001” are to “grow our business by following Tish[] [Rochin’s] simple training plan and techniques, historically proven to be successful.”

• A “lead generation” script hosted on the AWU website noted that “[a] new division named Growth-Into-Greatness was just launched within Herbalife International.  This gives us something quite unique, a 20-year old giant with a ground floor opportunity.” Rochin Exhibit X, available at http://web.archive.org/web/20010124044000/http://www.awealthyu.com/gig/gigaiplan.htm.
• A “Voice Mail” script hosted on the AWU website stated, “while we’re playing phone tag it would really save us both a lot of time if you would just listen to our orientation call of what we are doing with our new Growth Into Greatness division and if you feel like we might have a mutual interest after that, then we’ll take the next step.”  Rochin Exhibit Y, available at http://web.archive.org/web/20010330213546/http://www.awealthyu.com/JenniH.htm.

• Today, Thompson continues to operate a MLM consultancy (www.lt-online.com) that offers consulting services (see http://lt-online.com/consulting-services/), “Mentoring Membership” for $9.97 monthly (see http://lt-online.com/mentoring-membership/), and learning modules for $4.95 each (see http://lt-online.com/products/minimodules/).

Links to Other Senior Distributors

• Pershing Square believes that Rochin’s downline includes Chairman’s Club member Dan Waldron and President’s Team member Mike Patterson.

Links to Herbalife Corporate Leadership

• Upon qualifying for Chairman’s Club, Rochin was profiled in a 1999 edition of Herbalife Today, a magazine published by Herbalife.  The article states that “after a brief period of trial and error [upon joining the company in 1980], [Rochin] soon became one of Herbalife’s top performers, earning a staggering $250,000 in 1982. . . .  She then increased her recruiting efforts and began conducting meetings and making phone calls.”  After citing a period of “semi-retire[ment]” in 1993—the same year Thompson was fired from Herbalife for “conduct detrimental to Herbalife” (see infra at 12)—the article describes Rochin as “pretty unassuming for a woman who makes $100,000 a month.”  The article further notes Rochin’s 200-plus acre ranch and “the serious equipment” she needs to “do . . . chores.”  Excerpt attached as Rochin Exhibit Z, full issue available at https://dev-facts-about-herbalife.pantheonsite.io/content/uploads/2016/01/53.pdf.

• The Herbalife website touts Rochin’s biography in a series of web pages celebrating members of the company’s Founder’s Circle and Chairman’s Club, available at http://media.herbalife.com/myHbl/cc/55753US_MY_HO_CCFLASH_v14b.swf.

• Herbalife awarded Rochin the Mark Hughes Bonus Award—a large, discretionary bonus that Herbalife awards to top distributors—in 2003.

https://dev-facts-about-herbalife.pantheonsite.io/content/uploads/2016/01/97.pdf at 4.

• As mentioned supra at 1, Thompson was Herbalife’s Executive Vice President of Sales from 1986 to 1993 and served as one of the company’s four directors from 1986 to 1993.  See Rochin Exhibit B at 25, 8 and Exhibit C at 3 n.2.  According to Herbalife, “Thompson was effectively the second highest-ranking executive at Herbalife” until his departure in 1993.  Rochin Exhibit D at ¶¶ 8-9 (Complaint, Herbalife International, Inc. v. Thompson, No. BC245401, Dkt. #1 (Cal. Super. Ct. L.A. Cnty. Feb. 20, 2001)).
  • In 2001, Herbalife sued Thompson in California state court.  According to the complaint, “On or about January 15, 1993, Herbalife fired Thompson and shortly thereafter removed him as an Herbalife director because of conduct detrimental to Herbalife.  In connection with Herbalife’s termination of Thompson, Thompson and Herbalife International, Inc. entered in an Agreement . . . whereby Herbalife paid Thompson a substantial settlement in return for, among other things, Thompson’s agreement to no longer be involved with Herbalife.”  Id. at ¶¶ 9-10.  The complaint did not specify what conduct led to Thompson’s dismissal.  Herbalife alleged that, in contravention of the 1993 agreement, “shortly after and as a result of [Herbalife founder Mark] Hughes’ death, Thompson began trying, and has continued to try, to restart his relationship with Herbalife and its distributors.”  Id. at ¶ 12.  Specifically, Thompson unsuccessfully applied to be an Herbalife distributor (id. at ¶ 13), conducted “workshops or seminars, for which he charges a fee, directed at Herbalife distributors” (id. at ¶ 15(i)), conducted “telephone conference calls with Herbalife distributors wherein Thompson promotes his training activities” (id. at ¶ 15(ii)), operated “a web site promoting [Thompson’s] . . . workshops or seminars” (id. at ¶ 15(iii), and sold “audiotapes and other training aids that refer to Herbalife” (id. at ¶ 15(iv).  Herbalife dismissed the suit without prejudice in 2002, see Rochin Exhibit AA at 2, and Thompson continues to offer MLM training services while invoking his Herbalife experience, see, e.g., http://lt-online.com/larrys-story/.

• Oddly, Herbalife issued a press release on January 19, 1993 that was directly at odds with the complaint described above.  Herbalife publicly announced that Thompson had “decided to retire from Herbalife for personal reasons.”  Rochin Exhibit BB.  The press release continued, “In announcing Mr. Thompson’s decision to retire, Mark Hughes, President and Chief Executive Officer of Herbalife, noted that, ‘We at Herbalife will always be grateful for the significant contributions made by Larry Thompson to our success.  I will personally miss Larry’s involvement with the Company and I wish him the very best for the future.’”  Id.
  • The court filings also make reference to a Bankruptcy Petition filed by Thompson in November 1999.  See Rochin Exhibit CC (Notice of Stay, Herbalife International, Inc. v. Thompson, No. BC245401, Dkt. #3 (Cal. Super. Ct. L.A. Cnty. Mar. 8, 2001)).

• Thompson was a close friend with Herbalife founder Mark Hughes from Herbalife’s founding until Thompson’s 1993 dismissal from the company.

Thompson (right) with Hughes (left), available at https://www.facebook.com/194302827283094/photos/pb.194302827283094.-2207520000.1394818296./313196202060422/.

Other Businesses

• Tish Enterprises, Inc. is registered in Texas (Filing Number:  61868300, registration filing attached as Rochin Exhibit DD).  The registration filing uses the address 3000 Custer Road 270-379, Plano, TX 75075—the same address used by A Healthy U (supra at 1)—and lists Patricia A. Rochin as the company’s registered agent.  It is not clear what business is carried on by Tish Enterprises.

[1] See http://dreamteams.homestead.com/MillionaireTrainingLarryT.html (describing Thompson as the brother of Rochin); http://www.locatefamily.com/Street-Lists/USA/TX/75078/index11.html (listing the same street address and telephone number for Thompson and Rochin).

[2] GIG also maintained its own website (www.growthintogreatness.com).  The website is no longer active, but can be viewed at http://web.archive.org/web/20031207031353/http://www.growthintogreatness.com/home.htm.

[3] Moreover, the link to Thompson’s Facebook website——includes the name of his consultancy website.

[4] To the extent that any of the videos in this report requires a password, the password is “rochin”.

[5] But see Thompson’s Bankruptcy Petition referenced in the 2001 court filings described infra at 11.