The Agora
Files

Charge and plea

A federal grand jury indicted Chad Arrington on May 29, 2019 on one count of conspiracy, two counts of wire fraud and four counts of aggravated identity theft. On Feb. 3, 2020 he pleaded guilty to one count of wire fraud conspiracy before U.S. District Judge Richard D. Bennett.⁠^[1,2]

What he admitted

More than $4.1 million in unauthorized purchases on a company American Express card, from at least January 2015 through August 2018, with four co-conspirators: music promotion, purchased streams and followers, billboards, travel, merchandise and a bike-sharing venture.⁠^[3]

Money routed back

More than $1.5 million of the card spending went to entities and accounts controlled by two co-conspirators, who returned hundreds of thousands of dollars to him.⁠^[2]

How it was hidden

According to the plea agreement, he had false entries made on the card's billing statements to conceal who was being paid, and he forged his supervisor's signature on statements so that approvals appeared to exist. Other employees relied on those documents to pay the card.⁠^[3]

Sentence

May 5, 2021: 30 months in federal prison, then 12 months of home confinement within three years of supervised release. Restitution of $4,142,435.31, the full amount of the loss.⁠^[3]

He pleaded guilty. He was sentenced. He owes the restitution. Nothing in this file contests any of that, and nothing in it should be read as a claim that the charges were authorized. The co-conspirators are not named or characterized here.

The file asks a different question. What does the record show on the other side of that judgment?

For scale: MarketWise, the publicly traded affiliate that acquired Money Map Press's assets on Jan. 1, 2024, reported $328.1 million in net revenue for 2025.⁠^[18,19] Truth in Advertising calculated the FTC settlement at 0.4 percent of the network's annual revenue.⁠^[20] Baltimore's complaint says the network claims more than 3 million paid subscribers and revenue above half a billion dollars a year, and it describes the fines and settlements to date as “a minor tax” on that revenue.⁠^[8]

These matters rest on different laws, different theories of liability and different burdens of proof. A criminal restitution order and a civil settlement are not the same instrument. The comparison is of outcomes, not of guilt.

The name that is not in the record

Court records did not name the company that issued the card. Readers learned it was Money Map Press, a subsidiary of The Agora Companies, because reporters found it on a LinkedIn page, which was later deleted.⁠^[21,22] The individual's name, age, hometown and billboards are in the government's own releases. The institution's name is not.

Money Map Press itself no longer operates. MarketWise acquired its assets and liabilities as a related-party transaction effective Jan. 1, 2024, and the Money Map Press site says operations ended May 1, 2024, with its services merged into other publishers.⁠^[18,23]

1. June 2018The FTC sues MOBE, an online business-coaching company, in federal court in Florida, charging three individuals and nine businesses. A temporary restraining order entered June 5, 2018 halts the operation and appoints a receiver. The FTC alleges consumers paid more than $125 million for a 21-step system with a $49 entry fee, marketed to service members, veterans and older adults.⁠^[24,25]
2. Feb. 2020Founder Matthew Lloyd McPhee agrees to a stipulated judgment of $318,512,336, suspended after he surrendered more than $16 million and his foreign real estate interests: his Fiji and Costa Rica resort interests and two Kuala Lumpur apartments. The parties stipulated the figure represents the consumer injury alleged. He is permanently banned from selling business coaching programs and investment opportunities, and his order states he neither admits nor denies the allegations. MOBE settlements total more than $17 million.⁠^[26]
3. March 2020On March 5, 2020 the FTC settles with five affiliate marketers, each named individually, for more than $4 million and permanent bans: Gar Leong Chow, $3,350,000 paid in full; Michael Giannulis and Michael Williams, $31.6 million suspended upon payment of $760,000 and surrender of personal items; Steven Bransfield, $4.7 million suspended for inability to pay; Scott Zuckman, $1.8 million, of which he pays $406,150, the remainder suspended. “Affiliates should take note that the FTC will hold you personally and financially accountable for false or unsubstantiated marketing claims,” said Andrew Smith, Director of the FTC's Bureau of Consumer Protection.⁠^[27]

The MOBE settlements were stipulated orders; the founder's order states he neither admits nor denies the allegations. The Agora Financial settlement was entered without admission of liability. The difference is who the enforcement reached. In MOBE the FTC shut the company down and pursued the people who drove its traffic, by name. In Agora Financial the company kept operating, and the two individuals named were a physician-editor and a newsletter editor.⁠^[10,20] No one who ran marketing was named.

Exhibit 03, The Missing Link, lays the three cases side by side.

One marketer, both worlds

Chad Arrington's own records place him in both. His Money Map Press-era mailbox holds MOBE commission statements and a 2017 1099-MISC notice, and photographs show him at MOBE events with the founder and with one of the affiliates the FTC later pursued.⁠^[28] He was never a party to the MOBE case.

On Aug. 9, 2017, nobody was preparing for a dispute. Chad Arrington had a scheduled mid-year review with his direct manager. Nine files were produced or assembled that day for that meeting.⁠^[29] They establish five things.

1. The budget was published.

   A monthly SEO cost rundown lived on the company's Confluence server with line items, purposes, general-ledger codes and a running total of about $67,000 a month for January through June 2017. It linked to earlier review documents going back to January 2016.

2. The spend was reported on demand.

   The manager's written agenda called for year-to-date spend, this month's spend, next month's spend, and a total-spend report. The review answered in writing: more than $470,000 year to date.

3. The money moved through company channels.

   A corporate card, coded line by line to ledger accounts 40150 and 60250 and to publication codes 304MMP, 304EAD and 304GNA, with attendees and a business purpose on every travel and meal line. The July 2017 cycle came to $67,056.47, against a published run rate of about $67,000.⁠^[30]

4. The methods were disclosed.

   Private blog networks, purchased links, tiered link campaigns, paid influencer shoutouts and the suppression of “scam” search results were named in the review with vendor pricing attached. The budget page told the newsroom that “Editorial must be accountable for everything we spend for MM.com.”

5. The results were measured against revenue.

   A keyword profit-and-loss table, in the manager's requested format, set $337,000 in backlink cost against $93,535 in lead revenue and $239,638 in sales. Most keywords ran at a loss. The program kept its funding.

A failure of control, or a feature of the business? The documents do not answer that. They do establish that the scale, the methods and the monthly totals of the search program were on the company's own server, in its own ledger codes, and in its own manager's agenda.

The limit of this argument

The plea record says billing statements were altered to hide who was being paid, and that approval signatures were forged.⁠^[3] A process cannot approve what it was not shown, and this file does not argue otherwise. About a third of the July 2017 statement went to individual PayPal and Venmo accounts. No document here ties those payees to company work, and this file does not claim they were company work. The narrower point stands on the company's documents alone: a card running about $67,000 a month matched a budget on the company's server, carried payments to individual accounts, and was coded to marketing and paid.

What the job was called, and by whom

The same evaluation form carries, in its typed sections, the PosiRank relationship, private blog network creation and more than $30,000 in tool memberships. Those sections are in Chad's first person, so they are his self-evaluation on the company's form; handwritten notes on it appear to be a reviewer's. Either way, the vendors, the networks and the tool spend were in his personnel file in January 2016.⁠^[31]

The manager's inbox

The August 2017 review was not a one-off. Email threads from 2016 and 2017 show the same program moving through the manager's inbox: a two-week SEO push she proposed, copied to the executive director;⁠^[34] a budget and expense plan listing private blog networks, social signals and guest posts with per-campaign prices;⁠^[35] her own reply to PosiRank's co-founder with per-keyword backlink cost ranges;⁠^[36] a March 2017 update on guest posting, blog networks and negative brand terms;⁠^[37] a March 21, 2017 thread in which he tells her the HTTPS switch set back seven years of SEO work, asks whether to continue what he calls “Negative SEO campaigns,” and lists resetting the blog networks, and she clears 90 minutes for it the next day;⁠^[38] and a note that Wednesdays were for setting up blog networks from a home connection.⁠^[39]

Three things follow, and none of them is a defense of the 2018 charges.

• Six months of statements in hand, the company's own counsel could not classify roughly $900,000 of charges as business or personal without the employee's help. That is a statement about the company's records, in the company's words. The plea record later established that more than $1.5 million of card spending went to entities controlled by two co-conspirators,⁠^[2] and this file does not suggest those payees were arm's-length vendors.
• The letter was written on behalf of Monument and Cathedral Holdings, the Agora holding company formerly known as Agora, Inc. That company is now a named defendant in Baltimore's pending civil suit.⁠^[8]
• The itemized claim covers 2018. The search program documented in File 4 is 2016 and 2017. They are different periods and different subjects, and neither should be used to explain away the other.
• The letter itemizes $926,410.35 and flags more than $1,000,000 beyond it. The restitution order is $4,142,435.31 for January 2015 through August 2018.⁠^[3] No public document itemizes the full figure by year or by payee.

The termination letter

The Aug. 3, 2018 letter, on the letterhead of the Agora services affiliate and signed by its HR director, terminates employment for an “on-going and escalating pattern of unauthorized purchases,” lists concert tickets, travel, clothing, jewelry and billboard ads, says the related expense reports were falsified, and notes possible criminal implications. It says managers had tried several times to reach him about the charges.⁠^[33]

14 West, the affiliate on that letterhead, is also a named defendant in Baltimore's suit. The City alleges it is the network's administrative hub, running accounting, payroll, human resources and compliance for every affiliate. Those are allegations in a pending case.⁠^[8]

In every sampled month the prior balance was paid in full by a corporate online payment. The card ran between about $67,000 and $89,000 a month across 2016 and 2017.⁠^[41] For the 2017 months checked, the totals submitted to accounting match what American Express billed: July 2017 and August 2017 to the dollar, January 2017 within $100.⁠^[41]

Matching totals do not settle what the payee lines said. The public record on that subject is the plea summary in File 1.

What the documents show

• He came from search. A public LinkedIn profile, printed in 2020, lists Bret Holmes as the Agora Publishing ecommerce director who directed and developed all SEO, SEM and pay-per-click work from 2007 to 2013, then as executive director of Money Map Press from 2013 to 2018.⁠^[42]
• 2011 and 2012. In chats, he supplies a detail needed to complete a PayPal purchase for campaign tools; is told the PayPal charges are landing on the American Express account and that October's PayPal payments have been filed for him, and says he will sort it out; and is told the SEO receipts are on their way to him.⁠^[43,44,45]
• 2013 to 2015. PayPal's own records show 444 payments labeled “Subscription Payment: Bret Holmes” into Chad's Nuke My Rank account, $70,148 in all. For 2014, every one of 301 payments, $44,247, came from his Money Morning email address, and the total matches the 1099-K PayPal filed.⁠^[46]
• 2015, the same records. The pattern changes. Of $176,888.50 received that year, $88,576 came from an account tied to a link payee the archive describes as Chad-connected, $77,846.50 came from Chad's own email address, and $10,466 came from Bret Holmes. The adverse reading is that accounts on Chad's own side were paying Chad's own entity, which is the shape the government's case later described. The 2014 and 2015 records are the same kind of document and are reported together.⁠^[46]
• February 2016. Asked to come support an SEO meeting Chad was leading, he replies that it is the one he is coming to.⁠^[47]
• April 11, 2016. On Chad's five-year anniversary he writes: “You've been a trail blazer in the industry.”⁠^[48]
• Aug. 4, 2016. Copying the manager, he warns that the card paperwork must be in by the 10th or the account will be closed, says he has reminded Chad several times in six months, and adds: “I am trusting you to take care of it.”⁠^[49]
• February to April 2018. Chad reports active campaigns; he replies to the team about bringing in an outside SEO consultant and calls it a possible pairing for Chad.⁠^[50]

What the documents do not show

• No document in the archive states an open-ended authorization to use the card, a spending deal, or a sign-off on any specific statement. The files that were labeled that way were read, and the labels did not hold: a chat described as showing “a deal” is a single check-in message; a payment confirmation described as approved shows only a payment.
• The 2018 consultant thread was labeled as a betrayal behind Chad's back. The thread shows the opposite: the plan was disclosed to him directly.
• Of 57 conversation files checked against their labels, 31 were verified, 24 were weaker than labeled, and 2 did not support the label at all. The full log is kept with the file.

So the record holds two things at once. A supervisor who ran search himself, paid the employee's side business from his company email for years, praised the work and chased the card paperwork. And a plea agreement that says the approvals on the statements were forged. How far the supervisor's knowledge reached is the open question in this file, and the documents do not close it.

Regulators have described the network's marketing in similar terms for two decades: a falsely claimed insider tip in the SEC case, a sham diabetes cure and a fictional government check program in the FTC case, and, in Baltimore's pending civil suit, a uniform “scare and sell” playbook aimed at older adults.⁠^[6,11,14] Baltimore says its lawyers reviewed more than 1,000 consumer complaints.⁠^[13] Money Map Press was also the defendant in a 2019 federal class action under the Telephone Consumer Protection Act; its outcome is not recorded in this file.⁠^[51] One of those cases was Money Map Press's own: Oregon and Pennsylvania concluded a joint investigation of its promotions in 2020.⁠^[7] As the city solicitor put it: “No business, no matter its size, is above the law.”⁠^[13]

The 2017 review in File 4 lists the suppression of “scam” search results among the search program's methods. Managing what customers found when they searched the company's names was part of the job.⁠^[29]

Inside the budget

The August 2017 review set shows where that pressure landed. Rank tracking covered queries pairing each editor's name or product with the word scam. The budget sheet carried a section for negative and brand search at $180 per term, with the stated objective of taking first-page spots for company properties to push negative results down, and the Confluence rundown put brand and negative-search work at about $11,000 a month.⁠^[29] A 191-page printout of consumer reviews of Money Map Press, captured in July 2019, shows what those results were competing with.⁠^[52]

1. What did the approval process consist of?

   The plea record says signatures were forged on statements. It does not describe what review the company performed on a card that ran about $67,000 a month and matched a budget on its own server. Baltimore's complaint alleges that accounting for every affiliate is centralized at 14 West. What would answer it: 14 West's expense-approval and payment records for February 2015 through August 2018, by approver.

2. What is inside $4,142,435.31?

   In September 2018 the company's counsel called $926,410.35 non-business, listed more than $900,000 it said might be business-related, and flagged more than $1,000,000 in dispute. The court ordered the full loss in May 2021. No public document shows how the second category was treated. What would answer it: the loss schedule behind the restitution order, by year and payee.

3. Why is the employer “Company 1”?

   Three federal press releases name the defendant, his age, his hometown and his billboards. None names the company. What would answer it: nothing in the public record; it is a practice, and readers can weigh it.

4. Who ran the marketing?

   In MOBE, the FTC pursued the marketers by name. In Agora Financial, it named two editors. What would answer it: the FTC's investigative record, or discovery in the pending Baltimore case.

5. What happened to the search program after August 2018?

   The networks, the purchased links and the brand-search work were company programs on company budget lines. What would answer it: the Confluence page histories and the vendor accounts after that date.