Securities and Exchange Commission, Plaintiff,
Today's Growth Consultant, Inc.
dba The Income Store and
Kenneth D. Courtright, III
Case No. 1:19-CV-08454
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Receiver's Notice of Amendment to Proposed Noticing and Claims Administration Process

Receiver's Motion to Approve (A) Noticing and Claims Administration Process and (B) Partial Plan of Distribution
- Exhibit A - Legal Notice of Claims Process 
[click here]
- Exhibit B - Proof of Claim Form 
[click here]
- Exhibit C - Proposed Order Approving Claims Process 
[click here]


On December 27th, 2019, the Securities and Exchange Commission (“SEC”) filed a Complaint in the United States District Court for the Northern District of Illinois (the “District Court”) against Todays Growth Consultant Inc. (d/b/a “The Income Store”) and Kenneth Courtright, III (collectively, “Defendants”) and an Emergency Ex Parte Motion for a Temporary Restraining Order Freezing Assets and Imposing Other Ancillary Relief (the “Motion for Restraining/Freeze Order and Receiver”), and for an Order Appointing a Receiver, alleging that, among other things, Todays Growth Consultant (“TGC”) had been engaged in a Ponzi-like scheme that defrauds its investors in violation of several federal statutes. The Complaint alleges that from at least January 2017 through October 2019 the Defendants raised $75 million from more than 500 investors in exchange for “Consulting Performance Agreements” (“Investor Agreements”) through which TGC purported to provide investors with a minimum guaranteed rate of return, in perpetuity, in revenues generated by websites that TGC acquires or builds for each investor and then develops, maintains, and hosts.

In the Complaint, the SEC alleges that TGC’s websites have generated materially less revenue than the amounts guaranteed in the Investor Agreements. Moreover, the SEC alleges that TGC funded the gap between website revenue and guaranteed investor payout through the sale of Investor Agreements to new or repeat investors and loans from distressed lending companies. Further, the SEC alleges that TGC has violated its Investor Agreements by co-mingling its investors’ funds with loan proceeds and using the co-mingled funds to satisfy its guaranteed payments to investors, to repay its loan, and to pay for Mr. Courtright’s personal expenses.

On December 30, 2019, in response to the SEC’s Motion for Restraining/Freeze Order and Receiver, the Court entered a Temporary Restraining Order Freezing Assets and Imposing Other Emergency Relief (the “Restraining / Freeze Order”) to preserve the status quo and protect the SEC‘s ability to collect on any final judgement that may be awarded against TGC and Mr. Courtright. Additionally, the Court issued an Order Appointing Receiver (the “Appointment Order”), which appointed Melanie E. Damian as Receiver for TGC. Pursuant to the Appointment Order, the Receiver has all powers, rights, and privileges previously possessed by the officers of TGC and has assumed control of TGC’s operations in an effort to preserve all of TGC’s assets, claims and other interests. The Receiver will be filing her first report and accounting pursuant to the Appointment Order by January 30, 2020.

The District Court has set a status hearing for January 27, 2020 to further consider the Restraining/Freeze Order and the Appointment Order and whether they should be extended through the entry of a preliminary injunction or other court order, based on the relief sought and arguments presented by the SEC and the Defendants’ responses thereto.

The Receiver encourages investors who conducted transactions with the Defendants to carefully review the Complaint, the Motion for Restraining/Freeze Order and Receiver, and the District Court’s Orders (links to which are set forth at the top of this page) so they understand the nature of the claims alleged against the Defendants in this action and the extent and scope of the Receiver’s duties and authority under those Orders. As the Receiver proceeds with her investigation into the Defendants’ business operations and assets and the Defendants’ dealings with investors, the Receiver will provide additional information regarding her findings and determinations on this website (, and will post additional significant Court filings once they are entered and frequently asked questions and answers under the corresponding tabs along the top of the page.

For further information regarding this action, and how it may affect investors, please visit the SEC’s website:
( You may also contact a representative of the Receiver at 305-542-4410 or

Please understand that neither the Receiver nor any of her attorneys or other representatives may provide you with legal, tax and/or accounting advice in connection with this or any other matter. Should you require such advice, the Receiver asks that you contact your own attorney, accountant or other professional.

The Receiver encourages you to periodically visit the SEC website and this website as they will be updated with additional information throughout the course of the SEC action. Thank you.



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