The Accountability Gap · Exhibit 05Updated Sept. 23, 2026

The SmokingGun


On June 9, 2026, the City of Baltimore sued the Agora network for deceiving its customers. For seven years I was the one paid to break Google's rules so their sales copy would outrank the news. I went to federal prison for what I did there. I also kept the paperwork.

By Chad Arrington. Where my files meet the City's complaint, paragraph by paragraph. The City's claims are allegations in a pending civil case. Blocks marked “in his words” are my account; everything else is sourced.

Part 1

My part first

Chad Arrington, in his words

I pleaded guilty to wire fraud conspiracy. From 2015 to 2018 I ran more than $4.1 million of personal spending through a company American Express card: music promotion, billboards, travel, jewelry. I had billing statements altered and I forged my supervisor's signature to keep it going. I was sentenced to 30 months and ordered to repay $4,142,435.31.⁠[1]

All of that is true. Nothing below is an excuse for it.

I am telling you first because the company's lawyers will. A man with my record does not get to ask for your trust, so I am not asking. Everything on this page comes from a document: their letterhead, their ledger codes, their budget pages, their lawyers' letters, and the City's own complaint. Read those. Not me.

Part 2

The machine, end to end

Six stages. My files document the first three. The City's complaint describes the last four. They overlap at one point: the moment the company captures a name.

Chad Arrington, in his words

My job was the top of the funnel. When someone typed a stock, a scare or an editor's name into Google, I made sure a company page was what they found.

I did that for Money Map Press for seven years. The City's complaint describes what happens to a customer after that click. Put my files and their complaint end to end and you have the whole machine, from the search box to the credit card.

Documented in my filesAlleged in the City's complaintBoth
  1. Build authority

    Private blog networks, purchased links, guest posts, paid shoutouts.
    My files, 2016 to 2017⁠[2]
  2. Rank the pages

    841 tracked search terms across eight company sites, including long-copy promotional pages.
    My files⁠[2]
  3. Capture the name

    The visitor hands over an email address. The company books it as name-gen revenue. The customer enters the database and the emails begin, more than a dozen a day.
    My files⁠[2] and ¶ 53, 58
  4. The pitch

    Advertorials and 45-minute video sales letters that cannot be fast-forwarded.
    ¶ 42 to 51
  5. The checkout

    A cheap front-end subscription, a money-back guarantee, and an auto-renewal in the fine print.
    ¶ 52 to 56
  6. The back end

    Upsells, clubs costing thousands, maintenance fees on lifetime subscriptions, and obstacles to cancelling.
    ¶ 57 to 68, 137 to 180

Money Map Press is not a defendant. It stopped operating in 2024 and MarketWise, which is a defendant, acquired its assets.⁠[3,4] The City alleges that every Agora affiliate runs the same playbook. ¶ 37

Part 3

The rules I was paid to break

Search marketing has a white hat, a gray hat and a black hat. The line between them is Google's published rules. Every method in my budget sat on the wrong side of that line, and the budget was on the company's own server.

Chad Arrington, in his words

Nobody hires a white hat to move a page from nowhere to number one in ninety days. They hire what I did.

White hat is better writing, faster pages, links people give you. Gray hat bends the rules. Black hat buys the result: networks of sites built to look independent, links sold by the thousand, tiers of links pointing at other links. I was not hired to write better pages. I was hired to rank promotional copy above the news, and the only way to do that at the speed they wanted was to buy it.

What Google forbids, and what the budget called it

Google's published ruleThe company's own budget lineDocumented
Buying or selling links for ranking purposes is link spam⁠[5]Purchased monthly dofollow links pointed at company tag pages, and a vendor whose pricing page for 5, 10 or 20 network sites a month was pasted into the reviewAug. 9, 2017 review set⁠[2]
Using automated programs or services to create links⁠[5]A three-tier architecture: Tier 1 private blog networks at about $600 a month, tier 2 long-tail variations through crowdsourcing networks, tier 3 press releases and auto-blogs. Links pointed at links.Aug. 9, 2017 review set⁠[2]
Large-scale guest posting with keyword-rich anchor text⁠[5]Guest posts priced per campaign in the budget and expense plan sent to the managerSept. 8, 2016 email⁠[6]
Advertorials or native advertising carrying links that pass ranking credit⁠[5]Paid influencer placements, and the ranking of long-copy promotional pages as if they were editorialAug. 9, 2017 review set⁠[2]
Third-party content published on a host site to borrow that site's ranking signals⁠[7]Promotional acquisition pages hosted on the company's own news domainsPrintouts in the archive, 2019⁠[8]

Breaking a private company's rules is not a crime, and no one is accused here of committing one by doing it. Google's remedy is its own: it can ignore the links, demote the pages, or remove the site from search. What matters here is who chose the methods, who priced them and who paid for them.

Nobody could say they had not been told

These were not obscure rules. Google's webspam chief had been saying so in public for years before my budget was written. In January 2014 he told the industry to stop using guest blogging for links, that it had become too spammy, and that Google would take a dim view of it.⁠[9] Google's anti-spam updates had been demoting bought links since 2012. More than three and a half years after that post, the company's own review document still read: “We still build Private Blog Networks.”⁠[2]

The clearest proof that everyone knew is in the file itself. In August 2016 I prepared and uploaded a disavow file, a list handed to Google asking it to ignore certain links pointing at the company's sites.⁠[2] You do not file one unless you know the link profile contains links Google would object to.

Chad Arrington, in his words

Why buy the rankings at all? Because they could not buy the ads.

Google Ads will not sell you a get-rich-quick pitch. Its policy bars promises of large financial return for little risk, guaranteed returns, and testimonials of specific results without a disclaimer.⁠[10] In 2018 it restricted speculative financial products outright.⁠[11] The promotions I was ranking were exactly that copy. The paid door was closed. The organic door had no policy desk, only my link budget. Same keyword, same buyer, no ad review and no ad invoice.

That last paragraph is my reading of why the program existed, not something a document states. What the documents do show is the keyword table: fourteen top-tier keywords with backlink cost set against name-generation revenue and sales, ten of them running at a loss. The program kept its funding anyway.⁠[2]

Whose name was on it

The vendor agreement that set up the biggest link relationship carries my name and my title, SEO Director, Money Morning.⁠[12] The vendor accounts ran off a personal email address. The link buys, the network sites and the influencer placements were charged to a corporate card issued to me and coded to marketing accounts.⁠[13] The company's ledger recorded marketing spend. The signatures, the accounts and the card all pointed at one employee.

No document says anyone planned it that way, and this file does not claim one does. What the documents establish is the structure: the company set the budget, approved the methods, funded them every month, and the paperwork for the part that broke Google's rules carried a single name.

The loop closes

One line in my budget was for negative and brand search at $180 a term, with the stated aim of pushing negative results down, and a section for fighting a consumer complaint site.⁠[2] The complaints I was paid to bury were customers saying they had been charged without permission, refused refunds and sold lifetimes that ended early. Exhibit 07 collects 98 of those accounts from the public web today. They are the same complaints. The promotions are the same promotions. The City is now in court about them.⁠[14]

Part 4

Where my files meet their complaint

Eight points. On the left, what the City alleges, with the paragraph. On the right, what a document in my files shows, with the date. The City's claims are allegations in a pending civil case. My documents are what they are.

1

One back office

The City alleges

Hiring, payroll, human resources, legal, IT and accounting for every affiliate run through a single defendant, 14 West. The City says no Agora company can function without it, and that it reviews ads and handles escalated customer complaints. ¶ 15, 212 to 216

My files show

I worked for Money Map Press. My termination letter of Aug. 3, 2018 is on 14 West letterhead, signed by its HR director, the same person the complaint lists as the network's chief human resources officer.⁠[15] ¶ 217 Across 2016 and 2017, every card statement checked was paid in full by a corporate online payment, $67,000 to $89,000 a month. The statements do not say which entity paid.⁠[16]

Where they meetThe City has to show the affiliates are one enterprise. The firing of a Money Map Press employee was handled by the hub.

2

When money was at stake, the parent stepped in

The City alleges

Monument & Cathedral Holdings is the holding company, formerly Agora, Inc. With the Bonner family it sits on top of the structure, and it is MarketWise's largest shareholder. ¶ 16, 222 to 223

My files show

When the company came after me in September 2018, the letter to my lawyer did not come from Money Map Press. It was written on behalf of Monument & Cathedral Holdings.⁠[17]

Where they meetThe holding company acted as owner of a subsidiary's claim.

3

People and promotion crossed the lines

The City alleges

Staff are shared across business units without regard to which company houses them. Brands promote one another without telling customers they are related. ¶ 60, 104, 218

My files show

My supervisor's public profile shows the path: he directed all SEO, SEM and pay-per-click work at Agora Publishing from 2007 to 2013, then ran Money Map Press as executive director until 2018.⁠[18] In 2017 the paid-link cart for moneymorning.com included its page on Jim Rickards, who edits newsletters for a different Agora company and is a named defendant.⁠[2] ¶ 31

Where they meetOne career, two Agora companies. One company's site, another company's editor.

4

The complaints the company was paying to push down

The City alleges

Regulators have tried for years to stop the network's practices, and it keeps going. Among the earlier actions the City lists: the Pennsylvania and Oregon attorneys general reached a settlement with Money Map Press over promotions they alleged misrepresented money available through the 1998 tobacco settlement. ¶ 198, 200, 208 Baltimore's complaint dates this settlement to 2016; the Oregon DOJ release is dated June 18, 2020.⁠[19]

My files show

Same company. My budget sheet, reviewed with my manager in August 2017, carried a Negative Search and Brand section for each editor and product at $180 a term. Its stated objective: first-page spots for company properties, and “Push down negative.” The company's Confluence page put that work at about $11,000 a month. The rank tracker followed searches pairing editors' and products' names with the word scam.⁠[2] The state settlement came later: Oregon announced it on June 18, 2020.⁠[19]

Where they meetThe company knew what customers were saying about it and paid every month to move it down the page.

5

The complaints were already there

The City alleges

For years the most common customer complaints have been the same: recurring card charges, cancellation requests refused, phone lines that never pick up, refund guarantees not honored. ¶ 139, 154 to 165

My files show

My files hold 191 pages of customer reviews of Money Map Press from a consumer complaint site, printed July 30, 2019.⁠[8] They are in the locked file for the City's lawyers. The same complaints are still online today: Exhibit 07 gathers 98 of them from the public record.

Where they meetWhatever those pages say, they existed, the company's search budget was aimed at pages like them, and they are dated.

6

Lose on the front, earn on the back

The City alleges

A former marketing staffer says the network loses money acquiring each customer and profits on back-end programs. The first small purchase exists to get the customer into the database. ¶ 53, 65

My files show

My August 2017 keyword table, built in my manager's format, set $337,000 in link cost against $93,535 in what the company called name-gen revenue and $239,638 in sales. Ten of fourteen keywords ran at a loss. The program kept its funding at about $67,000 a month.⁠[2]

Where they meetPaying more for a name than the name first returns is consistent with the model the City describes: the money is made later.

7

Borrowed authority

The City alleges

Ads and advertorials are built to look like independent editorial content, and the experts who front them do not write them. ¶ 40, 44, 71, 75

My files show

Google's own rules name both halves of that: advertorials carrying links that pass ranking credit are link spam,⁠[5] and publishing promotional third-party content on a host site to borrow its ranking signals is site reputation abuse.⁠[7] Promotional acquisition pages sat on the company's news domains, and my budget bought the links that ranked them.⁠[2]

Where they meetWhat the City calls disguised advertising, Google classifies as two separate spam violations.

8

Sales pages dressed as search results

The City alleges

A reader who clicks a targeted ad is sent to an “advertorial” that imitates the format, style and tone of an objective editorial article, such as an exclusive interview with an “expert,” and teases a secret without disclosing it. Its links lead to a video sales letter, about 45 minutes long, that typically cannot be fast-forwarded. ¶ 42 to 47

My files show

Part of my job was ranking long-copy promotional pages, 6,000 to 10,000 words of sales copy, so they surfaced as ordinary search results. To do it we built private blog networks, bought links, placed guest posts and paid for influencer shoutouts. All of it is named in my review with prices attached, and the company's budget page told the newsroom: “Editorial must be accountable for everything we spend for MM.com.”⁠[2]

Where they meetManufactured authority upstream, sales copy presented as information downstream. Same design principle.

Part 5

Sanctioned, then renamed

Five enforcement actions in 23 years. Follow each sanctioned entity forward and see what is left of the name.

“The Agora enterprise is a hydra.”City of Baltimore, complaint, paragraph 224⁠[14]
Who actedWho was namedWhere that name is now
SEC, 2003 to 2007Pirate Investor LLC and its editorThe editor's firm, Stansberry Research, is today a brand inside MarketWise, a public company and a defendant. ¶ 19
Oregon and Pennsylvania AGs, 2020Money Map PressAssets acquired by MarketWise effective Jan. 1, 2024. Stopped operating May 1, 2024. ⁠[3,4]
ASIC, Australia, 2019Port Phillip PublishingDefunct and renamed, the City says. ¶ 205
FTC, 2019 to 2021Agora Financial, LLCAbsorbed into Paradigm Press in 2023. Paradigm Press is a defendant. ¶ 20
The parent itselfAgora, Inc.Renamed Monument & Cathedral Holdings. The administrative arm has also carried two earlier names. ¶ 15, 16, 215
Department of Justice, 2019 to 2021Chad ArringtonSame name. A federal record for life. Named in three government press releases in which his employer is only “Company 1.”⁠[1]

Every one of those matters ended in a settlement or a judgment against a subsidiary. The FTC settlement was entered without admission of liability; the Oregon and Pennsylvania settlement resolved allegations.⁠[20,19] In Australia, the publisher and its former director admitted the statements were misleading.⁠[21] In the one case that went to trial, the court found the subsidiary and its editor liable and the parent not liable.⁠[22]

Chad Arrington, in his words

A company can be renamed, merged or folded into another one. A person cannot.

The publisher I worked for settled with two states and no longer exists. The company the FTC sued was folded into another. The firm the SEC beat in court is a brand inside a public company. I am still Chad Arrington, and my case follows my name for life. I earned my record. My point is that nobody on the other side has one.

Part 6

The arithmetic

The City says the penalties so far are small next to the revenue, small enough that breaking the law stays profitable. ¶ 10, 208

Ordered from one employee, 2021
$4,142,435.31

Restitution in a criminal case, plus 30 months in federal prison.⁠[1]

Obtained from the whole network, 2003 to 2026
about $4.19M

$4,185,737 in all: FTC refunds $2,052,868. SEC judgment $1,552,620, including penalties on the subsidiary and its editor. ASIC A$650,000, A$600,000 against the company plus A$50,000 against its former director, about US$438,750 at about US$0.675 per A$ (Aug. 29, 2019 rate). Oregon $141,499. Pennsylvania's share is excluded because its amount is not confirmed. About the same amount as the one employee's restitution.⁠[23,24,21,19] MarketWise alone reported $328.1 million in net revenue for 2025.⁠[25]

These are different kinds of cases under different laws, and a restitution order is not a civil settlement. The comparison is of outcomes, not of guilt. The full ledger is in The Agora Files.

Part 7

What I am putting on the table

Chad Arrington, in his words

1,068 files. Every one opened and checked against its label, including the ones that hurt me.

My files end in August 2018. They cannot prove what the network does today, and the publisher I worked for is not a defendant. What they can show is how the traffic machine was built and paid for, that the back office was shared, that the holding company sat above the subsidiary when it counted, and that the company tracked its own complaints and budgeted to push them down the page. The City's lawyers can have all of it.

  • The enterprise. A termination letter on 14 West letterhead. A demand letter on behalf of Monument & Cathedral Holdings. The company's own agreement form.⁠[15,17]
  • The rule-breaking, priced and approved. The three-tier link architecture with per-keyword costs, the network vendor pricing pages, the purchased-link carts, the influencer buys, and the August 2016 disavow file.⁠[2]
  • The acquisition machine. Monthly budgets on the company's Confluence server, a keyword profit-and-loss table, the PosiRank partnership agreement, and monthly vendor promotion plans from April 2016 through July 2017.⁠[2,12]
  • What the company knew. Rank-tracking exports with the scam queries, the budget line to push negative results down, and 191 pages of customer reviews.⁠[2,8]
  • The money and the controls. Corporate card statements paid in full every month, coded by ledger account and publication, and years of email with my manager and supervisor about the program.⁠[16,13,6,26]
What Agora says. Agora says it rejects the claim that its marketing is predatory, that the complaint raises constitutional problems including under the First Amendment, and that it will defend the case vigorously. It has asked the court to dismiss, arguing in part that the City's ordinance does not reach a global business.⁠[27,28]
Chad Arrington, in his words

I know what I did. I have said it under oath and I have said it here. The question this page leaves is what they built.

Sources

The document spine

  1. 1Court record DOJ, sentencing release, May 5, 202130 months, 12 months home confinement within three years of supervised release, restitution $4,142,435.31. Re-read Sept. 18, 2026.
  2. 2Company document Aug. 9, 2017 review set (touchpoint, manager's agenda, card export, Confluence budget)Nine files produced or assembled for a mid-year review with my manager on Aug. 9, 2017. Discussed in The Agora Files, File 4.
  3. 3Securities filing MarketWise Form 10-Q, filed Aug. 14, 2024On Jan. 1, 2024 MarketWise acquired certain assets and liabilities of Money Map Press, LLC, a related party.
  4. 4Reporting moneymappress.com noticeMoney Map Press states it is no longer in operation as of May 1, 2024, its services merged into other publishers.
  5. 5Company document Google, Spam policies for Google Web SearchGoogle's published rules. Link spam includes buying or selling links for ranking purposes, automated link creation, and advertorials or native advertising carrying links that pass ranking credit.
  6. 6Chad's records Email, Sept. 8, 2016, SEO budget and expense plan to the managerEmail.
  7. 7Company document Google, Updating our site reputation abuse policy, Nov. 19, 2024Publishing third-party content on a host site to borrow that site's ranking signals. Google does not take a site's account of how the content was made at face value.
  8. 8Chad's records Consumer review printouts, Money Map Press, captured July 30, 2019 (191 pages)Printouts of a third-party review site, described here and not reproduced.
  9. 9Reporting Matt Cutts, The decay and fall of guest blogging for SEO, Jan. 20, 2014The head of Google's webspam team: stop using guest blogging for links, it has become too spammy. He said Google would take a dim view of it going forward.
  10. 10Company document Google Ads, Misrepresentation policy, unreliable claimsGoogle Ads bars get-rich-quick schemes, guaranteed returns, and unrealistic promises of large financial return for little risk or effort. Testimonials claiming specific results must carry a visible disclaimer.
  11. 11Reporting Google restricts speculative financial product ads, March 2018Google restricted advertising for cryptocurrency, binary options, rolling spot forex and contracts for difference, citing their unregulated and speculative nature.
  12. 12Company document PosiRank Full-Service Trading Partnership, effective March 25, 2016Vendor-drafted agreement. The copy on file is unsigned.
  13. 13Company document Corporate card export, June 28 to July 28, 2017 (94 lines, $67,056.47)One month of coded corporate card spend, part of the Aug. 9, 2017 review set.
  14. 14Court record Complaint, Mayor and City Council of Baltimore v. The Agora Companies, LLCCircuit Court for Baltimore City, case C-24-CV-26-004112, e-filed June 9, 2026. 63 pages, two counts, jury demanded. Nine company defendants and ten individuals. Allegations only. Pending.
  15. 15Company document Termination letter, Aug. 3, 2018, with the Nov. 14, 2017 agreement attachedLetter of Aug. 3, 2018 with the company's Nov. 14, 2017 agreement form attached.
  16. 16Company document Corporate card statements, 2016 to 2017, and reconciliation workbook (7 months shown; the May 2017 statement headers could not be fully read)American Express corporate card statements as issued, with a reconciliation workbook.
  17. 17Company document EX-010, company counsel's letter, Sept. 4, 2018Available in the locked copy as EX-010.
  18. 18Chad's records LinkedIn printout, captured Feb. 10, 2020Printout of a public profile.
  19. 19Regulator Oregon Department of Justice release, June 18, 2020$141,499 settlement with Money Map Press, the conclusion of a joint investigation with the Pennsylvania Attorney General. The conduct is described as alleged.
  20. 20Regulator FTC release, Feb. 2021 settlementSettlement with Agora Financial and affiliates. Entered without admission of liability.
  21. 21Regulator ASIC media release 18-393MR, Dec. 20, 2018; penalties announced in 19-235MR, Aug. 30, 2019Port Phillip Publishing, Agora's Australian publisher: A$600,000 penalty and A$50,000 against its former director, proposed jointly by the parties and ordered Aug. 29, 2019; both admitted the promotion's statements were misleading. ASIC v Port Phillip Publishing [2019] FCA 1483.
  22. 22Court record SEC v. Pirate Investor LLC, 580 F.3d 233 (4th Cir. 2009)Affirms disgorgement, civil penalties and injunction against the subsidiary and its editor. Pirate was wholly owned by Agora, Inc.
  23. 23Regulator FTC release, Nov. 2021 refunds34,893 checks and PayPal refunds totaling $2,052,868.
  24. 24Court record SEC v. Agora, Inc., Pirate Investor LLC and Frank Porter Stansberry, D. Md. MJG-03-1042: Judgment Order (Doc. 117, Aug. 1, 2007) and Amended Judgment (Doc. 126, Oct. 2, 2007)Judgment against Pirate Investor LLC and Stansberry: disgorgement $1,002,000 plus prejudgment interest $310,620, jointly and severally, plus civil penalties of $120,000 each, $1,552,620 in total. Judgment for Agora, Inc.
  25. 25Securities filing MarketWise FY 2025 results, March 6, 2026Net revenue $328.1 million for 2025; 374 thousand paid subscribers at Dec. 31, 2025.
  26. 26Chad's records Email, March 17, 2017, OEI update to the managerEmail.
  27. 27Reporting CBS Baltimore, June 10, 2026Agora's response: constitutional objections, including the First Amendment; it says it will defend the case vigorously.
  28. 28Reporting The Banner, Aug. 19, 2026Agora has asked the court to dismiss and rejects the predatory characterization. City says its investigation followed the 2025 Forbes report.
  29. 29Reporting Forbes, Emily Baker-White, July 7, 2025Reporting on the network's enforcement record; the Baltimore investigation followed this report.

How to read this exhibit

Paragraph numbers refer to the complaint in Mayor and City Council of Baltimore v. The Agora Companies, LLC, et al., Circuit Court for Baltimore City, case C-24-CV-26-004112, filed June 9, 2026. It is a civil case and it is pending. Its claims are allegations, the defendants dispute them, and no court has ruled on them. People named as defendants are described here only as defendants.

The FTC settlement described here was entered without admission of liability; the Oregon and Pennsylvania settlement resolved allegations; the SEC matter ended in a court judgment against the subsidiary and its editor, with the parent found not liable; in Australia, the publisher and its former director admitted the statements were misleading. Money Map Press is not a defendant in the City's case. Chad Arrington is not a party to it and has no role in it.

File names in Chad Arrington's archive are his descriptions, not facts. Every document was opened and checked against its label, and material that cuts against him is logged the same way as material that helps him. The documents themselves open with the password in the locked copy of The Agora Files.