WASHINGTON, D.C. — Florida-based substance use disorder treatment clinic operators Evoke Wellness, LLC, Evoke Health Care Management, LLC, and their officers, Jonathan Moseley and James Hull, have agreed to pay $1.9 million to settle allegations of deceptive advertising practices, announced the Federal Trade Commission (FTC).
The settlement follows an FTC complaint filed in January 2025, accusing the operators of using Google ads and telemarketing to impersonate other treatment providers. The complaint alleged that Evoke Wellness used the names of competing clinics as keywords in Google search ads, which linked to Evoke’s call center under the guise of a centralized admissions hotline. Telemarketers allegedly misrepresented themselves as being affiliated with the substance use disorder clinics consumers were attempting to contact.
The FTC also alleged that these practices violated the FTC Act and the Opioid Addiction Recovery Fraud Prevention Act of 2018. “Opioids have ravaged American communities, killing well over one hundred Americans per day and ruining the lives of countless others,” said FTC Chairman Andrew N. Ferguson. “Today’s settlement helps consumers affected by opioid addiction navigate their path to recovery by preventing fraudsters from leading them astray. The Commission will continue to take every action it can against those who prey on our nation’s vulnerable in their time of need.”
The proposed federal court order, which requires approval from a judge, imposes several measures on the defendants, including:
- A ban on using competitors’ names in search engine ads.
- Prohibitions against misrepresentations related to substance use disorder treatment services.
- A ban on impersonating other businesses.
- A requirement to implement a compliance program to monitor their call centers.
- Required corrective action against agents who violate the terms.
Additionally, the defendants face a $7 million civil penalty, partially suspended to $1.9 million due to their inability to pay in full. Should their financial condition be misrepresented, the remaining penalty will become immediately due.
The FTC voted 3-0 to approve the stipulated order, which was filed in the U.S. District Court for the Southern District of Florida.
The case was managed by attorneys Victor DeFrancis and Cassandra Rasmussen of the FTC’s Bureau of Consumer Protection.
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