pld - verified derivative complaint [date stamped] (00060200)

8/9/2019 PLD - Verified Derivative Complaint [Date Stamped] (00060200)

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IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

VIRGINIA BARNETT,

derivatively as a member

of

and

on behalfofGR8CODE, LLC

Plaintiff,

vs.

PHUONG COTEY,

DEBORAH ALVAREZ NEFF, and

GR8CODE INTERNATIONAL, LLC

Defendants,

vs.

GR8CODE, LLC,

Nominal Defendant.

CIVIL DIVISION

I

Case No:

Division

VERIFIED DERIVATIVE COMPLAINT

Plaintiff, Virginia Barnett ("Barnett"), in a derivative capacity and

on

behalf of all

members

of

Gr8code, LLC ("Gr8code"), sues Defendants, Phuong Cotey ("Cotey"), Deborah

Alvarez Neff

( Neff'),

and Gr8code International, LLC ("Gr8code International")

1

and alleges

as follows:

Parties, Jurisdiction, and Venue

1. This is a members' derivative action under section 605.0802, Florida Statutes, for

injunctive and other equitable relief and damages in excess

of

$15,000, for which Plaintiff is

entitled to recover her reasonable expenses, including attorneys' fees, for maintaining the action.

2.

Gr8code is a member-managed Florida limited liability company that does

1

Pursuant to Florida case law, Gr8code, LLC has been named as a nominal defendant.

{BC00059942:

1}

Filing # 22760907 E-Filed 01/20/2015 06:00:27 PM


2/116

business in Hillsborough County, Florida.

3.

Barnett is a resident of Hillsborough County, Florida. Barnett is currently a

member of Gr8code and was a member of Gr8code when the conduct giving rise to this action

occurred.

4. Gr8code International is a Nevada limited liability company that does business in

Hillsborough County, Florida.

5.

Cotey is a resident

of

Hillsborough County, Florida. Cotey is a member and part

owner of Gr8code. Upon information and belief, Cotey is also a member and part owner of

Gr8code International.

6. Neff is a resident of Hillsborough County, Florida. Neff is a member and part

owner of Gr8code. Upon information and belief, Neff is also a member and part owner

of


7. Venue is proper in Hillsborough County because the causes of action accrued in

Hillsborough County, Florida.

8.

Barnett has retained the undersigned attorneys and is obligated

to

pay them a

reasonable fee for their services.

9. Neff and Cotey were engaged in, and primary beneficiaries of, the malfeasance

alleged below against Gr8code that Barnett seeks to remedy. Accordingly, a demand, pursuant

to section 605.0802, Florida Statutes, was not made prior to filing this lawsuit because such

demand would be futile.

See

605.0802(2), Fla. Stat.

10. All conditions precedent to the bringing and maintenance

of

this action have

occurred, been performed, or have been waived.

General Allegations

{BC00059942:1}

2


3/116

11. Gr8code was originally created by Barnett and Cotey in February, 2014, and its

Articles

of

Organization were filed on February

3,

2014. On July

2,

2014, Neff became a

member of Gr8code.

12. Also on July 2, 2014, Barnett, Cotey, and Neff executed an Operating Agreement

which outlined Gr8code's ownership interest. Under that agreement, Barnett owns thirty-four

percent (34%)

of

the company, Cotey owns thirty-three percent (33%)

of

the company, and

Neff

owns thirty-three percent (33%) of the company. Despite the relatively equal ownership

interests, Barnett contributed $35,000 in capital

to

the company. Cotey contributed only $2,000.

Neff contributed nothing.

13. Gr8code is a "startup" business that offers accelerated computer programming

courses to individuals with little or

no

coding experience. The program is designed to prepare

participants for high wage earning positions following the end of a nine week course. The cost

of

the course is approximately $10,000.00.

14. In the early stages of its existence, Gr8code developed a name and logo that are

unique, distinct, and original. In April 2014, Gr8code began using its name and logo to promote

the business. Gr8code developed a website outlining the various course options and the fees

associated with the courses.

2

Printouts ofGr8code' s website as of January 16, 2015 are attached

as

Exhibit

A.

The website also provides information about the company, its staff, faculty, and

founding members.

15. In addition to the website, Gr8code developed course materials and a course plan.

A genenc overview of the courses is outlined on Gr8code's website. Further, Gr8code

developed multiple relationships with vendors and potential employers for prospective students.

Gr8code also engaged in marketing efforts to procure interest from prospective students.

2

The website can be viewed at www.gr8code.com

{BC00059942:

1}

3


4/116

16. As Gr8code was preparing for the launch of its first course, it sought outside

funding

to

help finance prospective students for the Gr8code courses. Gr8code was introduced

to an investor, Steven Brickner ("Brickner"), who represented that his company would make a

$5.4 million investment into Gr8code which included an immediate $100,000 investment to

continue Gr8code's operations, fund participants, pay salaries, and pay other bills.

17. Despite Brickner's representations,

no

funds were ever transferred to Gr8code.

18. Shortly thereafter, Gr8code's business and assets were misappropriated by a

copycat company Gr8code International - with the assistance

of

Brickner and Gr8code

members, Cotey and Neff.

19. Gr8code International filed its Articles

of

Organization in Nevada on January 9,

2015. Upon information and belief, Gr8code members Neff and Cotey helped form and are part

owners of Gr8code International. Neff is identified

as

a co-founding member of Gr8code

International and is also the COO. Neff held the same position at Gr8code. Cotey is identified

as co-founding member of Gr8code International and is the CCO. Again, this is the same

position she held with Gr8code. Using their positions and access with Gr8code, Cotey and

Neff

wrongfully transferred and utilized Gr8code's assets

to

create this new "copycat" company. No

consideration was provided to Gr8code for the transfer

of

these assets.

20. Gr8code International is virtually identical to Gr8code. In addition to using the

Gr8code name, Gr8code International has adopted an exact replica of the Gr8code logo.

Gr8code International also has a website that is almost identical in design and content to that

of

Gr8code.

3

Printouts

of

Gr8code International's website are attached as Exhibit B. Gr8code

International outlines the exact same courses and programs on its website as the courses and

programs outlined on Gr8code's website. Additionally, the fees for Gr8code International

3

Gr8code International's website can be viewed at www.gr8codeintl.com.

{BC00059942:

1}

4


5/116

courses are identical to that of Gr8code.

21. Further, the other staff and faculty members identified on Gr8code International's

website- Justin Davis, Mitch Neff, and Michael Laplante- are also faculty and staff members

of

Gr8code.

22. Upon information and belief, Gr8code International has also usurped Gr8code's

vendor relationships and business opportunities with prospective students. In addition, upon

information and belief, Gr8code International has also taken cash from Gr8code.

23. Neff and Cotey transferred, or were substantially involved in the wrongful

transfer of, these Gr8code assets to Gr8code International.

24. Gr8code International continues to operate utilizing Gr8code's business and

assets to its benefit while substantially diminishing the value

of

Gr8code.

COUNT I

Breach of Statutory Fiduciary Duties ofLoyalty and Care against Cotey

25. This is a derivative action by Barnett, on behalf

of

Gr8code, for damages against

Cotey.

26. Barnett realleges the allegations in paragraphs 1 through 24.

27. Pursuant to section 605.04091, Florida Statutes, Cotey owes fiduciary duties

of

loyalty and care to Gr8code.

28. Cotey breached her duties of loyalty and care to Gr8code by transferring, without

right or authority, Gr8code's business and assets to Gr8code International. Those assets include,

but are not limited to, Gr8code's name, logo, educational materials, website design and content,

relationships, goodwill, and business opportunities.

29. Cotey' s actions were taken with the intent of transferring some, most, or all

of

the

value of Gr8code

to


{BC00059942:

1} 5


6/116

30. As a direct and proximate result of Cotey's actions, Gr8code has been damaged.

WHEREFORE, Barnett, on behalf of Gr8code, demands damages in favor of Gr8code,

as

well as equitable relief including disgorgement of all property transferred from Gr8code and all

profits derived from such property, and/or a constructive trust over all such property and profits,

interest, and costs against Cotey, and for such further relief

as

the Court deems just and proper.

Cotey.

OUNT II

Conversion against Cotey

31. This is a derivative action

by

Barnett, on behalf of Gr8code, for damages against

32. Plaintiff realleges the allegations in paragraphs 1 through 24.

33. Cotey has transferred, without right or authority, Gr8code's business and assets to

Gr8code International. The converted assets include, but are not limited to, Gr8code's name,

logo, educational materials, website design and content, goodwill, and business opportunities.

34. By knowingly and wrongfully transferring the business and assets of Gr8code,

Cotey has converted the assets of Gr8code.

35. Gr8code has been permanently or indefinitely deprived of the benefits of the use

of

said assets, which have illegally and wrongfully benefited Cotey while diminishing the value

ofGr8code.

36. Cotey was engaged in, and a primary beneficiary of, the malfeasance against

Gr8code that Barnett seeks to remedy, such that demand for the relief sought herein would have

been futile.

37. As a direct and proximate result of

the conversion

of

Gr8code's business and

assets, Gr8code has been damaged.

{BC00059942:1} 6


7/116


as

well as equitable relief including disgorgement of all property converted from Gr8code and all


interest, and costs, against Cotey, and for such further relief

as


COUNT III

Breach of Statutory Fiduciary Duties of Loyalty and Care againstNeff

38. This is a derivative action by Barnett, on behalf of Gr8code, for damages against

Neff.


40. Pursuant to section 605.04091, Florida Statutes, Neff owes fiduciary duties of

loyalty and care to Gr8code.

41. Neff breached her duties of loyalty and care to Gr8code by transferring, without

right or authority, Gr8code's business and assets to Gr8code International. The converted assets

include, but are not limited to, Gr8code's name, logo, educational materials, website design and

content, relationships, goodwill, and business opportunities.

42. Neff's actions were taken with the intent of transferring some, most, or all of the

value of Gr8code to Gr8code International.

43. As a direct and proximate result of Neff's actions, Gr8code has been damaged.

WHEREFORE, Barnett, on behalf

of

Gr8code, demands damages in favor

of

Gr8code, as

well

as

equitable relief including disgorgement

of

all property transferred from Gr8code and all


interest, and costs against Neff, and for such further relief

as


{BC00059942: l}

COUNT IV

Conversion against Neff

7


8/116

44. This is a derivative action by Barnett, on

behalf

of Gr8code, for damages against

Neff.

45. Plaintiffrealleges the allegations in paragraphs 1 through 24.

46. Neff has transferred, without right or authority, Gr8code's business and assets to

Gr8code International. The converted assets include, but are not limited to, Gr8code's name,

logo, educational materials, website design and content, goodwill, and business opportunities.

47. By knowingly and wrongfully transferring the business and assets of Gr8code,

Neff

has converted the assets

of

Gr8code.

48. Gr8code has been permanently

or

indefinitely deprived

of

the benefits

of

the use

of said assets, which have illegally and wrongfully benefited

Neff

while diminishing the value of

Gr8code.

49. Neff was engaged in, and a primary beneficiary of, the malfeasance against

Gr8code that Barnett seeks to remedy, such that demand for the re lief sought herein would have

been futile.

50. As a direct and proximate result of the conversion of Gr8code's business and


WHEREFORE, Barnett, on

behalf of

Gr8code, demands damages in favor of Gr8code, as



interest, and costs, against Neff, and for such further relief as the Court deems

just

and proper.

OUNTV

Accounting against Cotey and

Neff

51. This is a derivative action by Barnett, on behalf of Gr8code, for an accounting

against Cotey and Neff.

{BC00059942:1}

8


9/116

52. Plaintiff realleges the allegations in paragraphs 1 through 24.

53. Pursuant to section 605.04091(2), as members of Gr8code, Cotey and Neff owe a

duty of loyalty to Gr8code and its members, which includes a duty to account for any property,

profit, or benefit derived by the members in the conduct or winding up of the company's

activities and affairs or derived from use by a member

of

the company's property, including the

appropriation

of

a company opportunity.

54. Cotey and Neff have failed to account to Gr8code and its members for all

property, profits, and benefits derived

by

Cotey and Neff from the use of Gr8code' s business and

assets, including the appropriation

of

Gr8code's business opportunities.

WHEREFORE, Barnett, on behalf of Gr8code, demands an accounting from Cotey and

Neff regarding all property, profits, and benefits derived by Cotey and Neff, including entities in

which Cotey and Neff have ownership interests, from their use of Gr8code's business and assets,

including the appropriation of Gr8code's business opportunities, and such further relief as the

Court deems just and proper.

COUNT VI

Aiding and Abetting Breach

of

Statutory Fiduciary Duties

ofLoyalty and Care against Gr8code International

55.

This is a derivative action

by

Barnett, on behalf of Gr8code, for damages against



57. Pursuant to section 605.04091, Florida Statutes, Neff and Cotey owe fiduciary

duties of loyalty and care to Gr8code and Gr8code's members.

58.

Neff and Cotey breached their duties

of

loyalty and care to Gr8code

by

transferring, without right or authority, Gr8code's business and assets

to


{BC00059942:1} 9


10/116

Those assets include, but are not limited to Gr8code's name, logo, educational materials, website

design and content, relationships, goodwill, and business opportunities.

59. Gr8code International was aware of, and gave substantial assistance to,

Neff's

and

Cotey' s breach

of

their fiduciary duties of loyalty and care.

60. As a direct and proximate result

of

Gr8code International's actions, Gr8code has

been damaged.


of

Gr8code, demands damages in favor of Gr8code, as


profits derived from such property; and/or a constructive trust over all such property and profits,

interest, and costs against Gr8code International, and for such further relief as the Court deems

just and proper.

COUNT VII

Conversion against Gr8code International


by

Barnett, on

behalf

of Gr8code, seeking damages

against Gr8code International.


63. Gr8code International has wrongfully taken Gr8code's business and assets.

The

converted assets include, but are not limited to Gr8code' s name, educational materials, website

design and content, relationships, goodwill, and business opportunities.

64. By knowingly and illicitly obtaining the business and assets

of

Gr8code, Gr8code

International has converted the assets

of

Gr8code.

65. Gr8code has been permanently or indefinitely deprived of the benefits

of

the use

of

said assets, which have illegally and wrongfully benefited Gr8code International while

diminishing the value

of

Gr8code.

{BC00059942:1}

10


11/116

66. Gr8code International was engaged in, and a pnmary beneficiary of, the

malfeasance against Gr8code that Barnett seeks to remedy, such that demand for the relief

sought herein would have been futile.


of

the conversion

of

Gr8code's business and


WHEREFORE, Barnett, on behalf of Gr8code, demands damages in favor of Gr8code, as

well as equitable relief including disgorgement

of

all property converted from Gr8code and all

profits derived from such property; and/or a constructive trust over all such property and profits,

interest, and costs against Gr8code International, and for such further relief

as

the Court deems

just and proper.

Count VIII

Common Law Trademark/Service Mark Infringement

against Gr8code International

68. This is a derivative action by Barnett, on behalf

of



69.

Barnett realleges the allegations in paragraphs 1 through 24.

70.

The Gr8code name and logo are unique, distinctive, and protectable

as

unregistered marks.

71. Gr8code has adopted and used the Gr8code name and logo in this judicial district,

and elsewhere, in promoting its company, and has thus established valuable common law rights

in the Gr8code name and logo.

72.

Gr8code International subsequently copied the Gr8code name, and adopted an

exact replica

of

the Gr8code logo. Gr8code International is using the Gr8code name and logo in

{BC00059942: I}

11


12/116

conjunction with promoting and advertising Gr8code International in this judicial district and

elsewhere.

73. Gr8code International's infringement

of

the Gr8code name and logo have caused,

and will likely continue to cause, confusion and mistake

as

to the affiliation, connection, and/or

association of Gr8code International with Gr8code.

74. Gr8code International's use

of

the Gr8code name and logo constitute a false

designation

of

origin that wrongfully and falsely designates Gr8code International's services as

originating from or connecting with Gr8code, and constitutes the use

of

false descriptions or

representations in commerce.

7

5.

As a direct and proximate result

of

Gr8code International's infringement on the

Gr8code name and logo, Gr8code has been damaged.


of

Gr8code, demands damages in favor

of

Gr8code,

special damages, including lost profits, recoupment

of

Gr8code International's profits generated

by

its infringing conduct, costs, interest and such further relief

as

the Court deems just and

proper.

Count IX

Common

Law

Unfair Competition

against Gr8code International


by

Barnett, on behalf

of




78. The Gr8code logo and name are unique, distinctive, and protectable as

unregistered marks.

{BC00059942:1}

12


13/116

79. Gr8code has adopted and used the Gr8code name and logo in this judicial district,

and elsewhere, in promoting its company, and has thus established valuable common law rights

in the Gr8code name and logo.

80. Gr8code International has subsequently copied the Gr8code name, and adopted an

exact replica

of

the Gr8code logo. Gr8code International is using the Gr8code name and logo in

conjunction with promoting and advertising Gr8code International.

81. Gr8code International's use

of

the Gr8code logo and the Gr8code name have

caused and will to continue to cause confusion and mistake, and deceive customers, potential

customers, and the public.

82. Gr8code International's acts

of

unfair competition are willful, and intended to

mislead the public into believing that it

is

Gr8code.


of

Gr8code International's unfair competition,

Gr8code has been damaged.


special damages, including lost profits, recoupment

of

Gr8code International's profits generated

by its unfair competition, costs, interest and such further relief

as

the Court deems just and

proper.

COUNT X

Injunctive Relief against Gr8code International, Cotey, and Neff

84. This is a derivative action by Barnett, on behalf of Gr8code, seeking injunctive

relief against Gr8code International, Cotey, and Neff.

85. Barnett realleges the allegations in paragraphs 1-24, 27-30, 33-37, 40-43, 46-50,

53-54, 57-60, 63-67, 70-75, and 78-83.

{BC00059942:

1} 13


14/116

86. Gr8code International, Cotey, and

Neff

have usurped Gr8code's business and

assets, and are using them to their benefit.

87. Specifically, Gr8code International, Cotey, and Neff are ustng, among other

things, Gr8code' s name, logo, website design and content, educational materials, vendor and

business relationships, and other assets of Gr8code.

88. Gr8code will be irreparably harmed if Gr8code International, Cotey, and

Neff

are

not enjoined from using Gr8code's business and assets.

89. Gr8code does not have an adequate remedy at law for Gr8code International's,

Cotey's,

Neffs

continued use

of

its business and assets.

90. Gr8code is substantially likely to succeed on the merits

of

its claims against

Gr8code International for conversion, aiding and abetting breach of fiduciary duty, common

law

trademark/service mark infringement, and common law unfair competition. Additionally,

Gr8Code is substantially likely to succeed on the merits

of

its claims against Cotey and Neff for

breach of fiduciary duty, conversion, and accounting.

91. Entry of an injunction will serve the public interest.

WHEREFORE, Plaintiff respectfully requests the Court to enter an order prohibiting

Cotey, Neff, Gr8code International, and all those acting in concert with it, or as their officers,

servants, employees, attorneys, affiliates, subsidiaries, agents or representatives from:

a.

Using Gr8code's assets, including, but not limited to, Gr8code's educational

materials, Gr8code's website design and content, goodwill, and business opportunities;

b. Using the Gr8code name;

c. Using the Gr8code logo; and

d. For such other relief as the Court deems just and proper.

{BC00059942:1} 14


15/116

JURY

TRIAL

DEM ND

Plaintiff demands

a

jury

trial on all issues so triable.

VERIFICATION

Under penalties of perjury. I declare that I have read the foregoing and that the facts

stated in

it

are true. to the best of my knowledge and belief.

: 8(00059942: I l

15

V. Stephen Cohen. Esq.

Florida Bar

No.

948756

En1ail:

SC\)hcn

hajocu\ a.com

David A. Hayes. Esq.

Florida Bay No. 096657

En1ail:

dha\

cs

b a j ~ l C U \ a.com

BAJO CUV

A

COHEN &

TURKEL.

P.A.

100

North Tampa Street Suite

1900

Tan1pa. Flor ida 33602

(813) 443-2199 (telephone)

813) 443-2193 facsimile)

Counsel for Plaint(ff


16/116

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gr8codeFront-end Bootcamp Igr8code Page 3

of

6

Courses lnclud

d:

GIT AND GITHUB

HTML5/CSS3

to

TESTING


SASS, SCSS AND

LESS

TEAMWORK

1/16/2015


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gr8codeFront-end Bootcan1p Igr8code

Page

4

of6

E

p

INTERVIEWING AND

Fl DING WORK

i

(There is such a lack of top talent in d

everybody

is scrambling

for

talent. Th

start-ups are lo

SAM

GORD ' ~ ~ : p < < ~ W ~ ~ ~ ~ ~ ~ ~ , ~ ~ ~ f l " ) " ' i , ~ ~ J t ' - f l ' l ' ~ ~ ~ ' j ~ ~ ~ ~ ~ ~ - ' \ ~ ~ o / t ~ r

Every student's experience is different,

and

we can't

guarantee

this is what your experience will be

3


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CL.

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=

::a

>

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50/116

Reach

out

to

your campus director

to receive an

application

link or

apply

through

the

URL

below

https://climbcredit.co/apply/GR803984203460/

Fill

out

our

short

application on

your

laptop,

iPhone,

or

iPad in

just

a few minutes

Usually get

a

response from

us

the

same

day-

we

may have to follow up for some questions

5


51/116

We put

every school

through a rigorous vetting process

to

determine if it really helps students transform their future

earning

potentiaL We

survey

alumni,

speak

with

recruiters

and

continually monitor

the

job prospects for a school's graduates.

The

financing

application typically only takes a few minutes to

complete.

We let most applicants know if they qualify

the

same

day; but it may take up to a week.

We

offer

fixed interest rates

ranging

from

5/o-12/o depending on

your

credit history and future income prospects coming

out

of

your education.

If

you have

good

credit

history,

or

a co-borrower,

you will most likely have a lower rate.

The funds are

available as soon as

you

are approved for a loan.

We will

transfer

your tuition to your approved

school

upon

acceptance

of your

offer.

If

you decide

not to

pursue your education

within the first 10

days of class

your

loan is cancelled. We don't want people to

take

out loans

for educations that

they don't

receive.

6


52/116

Once you are accepted

to a

partner school

just click the

link

they share and

you

will get access to

the

application.

Once you have provided us

with

your

social

security

number

and permission to access

your

information, we will contact a

credit bureau to provide us

with

your credit

history. We will

never

share

your

personal credit information

anywhere

or with

?l :Y


53/116

We ask you to

pay

only

the

interest component

of

your loan for

6

months, giving

you some time

to find a job. Thereafter, we

ask

you

to

start paying

the

full

monthly

amount

If

your

loan amount is $8,500, the monthly interest

only

payment

amount

will range from ~ 3 5 - 8 5

and the

full monthly

payment

will range from -$270-$295,

depending

upon

your

actual interest rate.

Typically our loans have a 3 year term after

the

program ends.

You

can

pay

by

ACH,

credit

card,

or

other payment

methods.

We

offer a discount for borrowers who set up an

automatic payment

from their

bank account. You

can

also save

your payment

information so that future payments

can

be sent automatically.

You

can

pay back

your

loan, in

whole or

in part, at

any

time

without

penalty.

8


54/116

gr8codeAbout gr8code

I

gr8code Page 1

of2

https://gr8code.com/about-gr8code/

1116/2015


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I

gr8code Page 2 of2


1/16/2015


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I

gr8code

Page 1

of2

r

https://gr8code.com about-gr8code/

1/16/2015


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I

gr8code Page 2 of2


1116/2015


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I

gr8code

Page 1 of2

r

https:// gr8code.corn about -gr8code/ 1/16/2015


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gr8codeAbout gr8code Igr8code

Page 2 of2

https :/I gr8code.com/about-gr8code/

1/16/2015


60/116

gr8codeThe Team

I

gr8code Page 1 of 5

\...

844-CODE-411

E2l

[email protected]

f

~ g r 8 c o d e

JUSTIN

DAVIS

VP of Progran1

Development

Justin

is

the

n1astern1ind

behind

our

curriculun1. He is

an industry vet

\XJith two

decades

of experience

designing and

developing digital

products- from

40.000

page

websites

to

cornplex

web

and

Faculty and

Staff

MITCH

NEFF

V.P. of Business

Development

Mitch does a

lot

of

stuff. For reaL

In addition to

finding odd

reasons to

drink

MICHAEL

LAPLANTE

Adjunct

Instructor

Michael

LaPlante

is a user

experience

designer

and

\Vhiskey at work entrepreneur

his skills include: focusing on

Digital

media

bringing the

strategy. brand community

closer

developn1ent/managemegether. Michael

digital

anatytics

and data analysis.

and

product

managen1ent. He

spends his time

organizing Startup

\X/eekends.

Startup \ \leek

https

: I

gr8code.cornithe-team

-

-

Gr8code

Team Mission

OUR

f\1155 0N

IS SIMPLE:

T

EMPOWER

GREAT

DEVELOPER5

T

PRODUCE

GREAT

WORK

FOR

GREAT

COMPANIES

Our

highly

expet-ienced

staff

offers students a

wide array of

technical.

business. and

team building

1/16/2015


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gr8codeThe Tearn Igr8code

Page 2 of5

https://gr8code.com/the-team/ 1116/2015


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gr8codeThe Team

I

gr8code

course

offered

throuQh Uden1y.

Founding

Team

VIRGINI

B RNETT

co founder

I

CEO

Virginia

is

a tech

geek who wanted

to

lear-n

to

code.

Her father and

grandfather

were

entrepreneurs

before her, so the

idea to start a

code

school

exploded

in

her

brain

Uke

fire\vorks on the

Fourth

of

July

Virginia has over

20

years

experience

inbusiness

operations

managementwith

DEBOR H

LV REZ

NEFF

co founder I

coo

Mother hen to

many, organizer

of

chaos, lover

of

community

building.

operational

hustler

of

all

U1ings

entrepreneurial

As

the director of

operations at

Tampa Bay Wave

an

accelerator for

star-tups) Deb

guides

entrepreneurs

every day. She

helps stllall

https

:/I

gr8code.com/the team/

PHUONG

NGUYEN

COTEY

co founder

I

ceo

Phuong loves

words. And she

loves

Word

Press,

which powers

almost

25

percent

of websites on the

internet. She

handles internal

and external

communications

for gr8code and

has persuaded

Justin to offer a

Word

Press

course. She's a

veteran journalist

who garnered

two

Pulitzer Prize

Page 3

of5

Gr8code

Team Vision

GRBCODE

EXISTS

T

SUPPORT

THE

PEOPLE

WHO

1) /ANT TO

CHANGE

THEIR

LIVES

AND

THE

LIVES

OF

OTHERS

Y

LEARNING

T CODE

We believe that

anyone can learn

the necessary

skills

to becotlle

a

qualified

developer.

We

teach not only the

necessary skills to

get

by,

but

the

additional skills

to

thrive. Becoming

1/16/2015


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gr8codeThe Team Igr8code Page 4 of5

https://gr8code.com/the-team/

1/16/2015


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gr8codeThe Team Igr8code

Page 5

of5

https://gr8code.com/the-team/

1116/2015


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gr8codeContact Us

I

gr8code

Page 1

of2

r

https://gr8code.com/contact-us/

1116/2015


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gr8codeContact Us

I

gr8code

Page 2 of2

https://gr8code.corn contact-us/

1/16/2015


67/116

gr8code0ur Programs

I

gr8code

OUR

PROGRAMS

PROGRAM FEES

ABOUT

GR8CODE

FRONT END BOOTCAMP

Become fluent get a job fast.

CONTACT US

Do

you crave a job with high salary potential?

Or

maybe you want to

be a code ninja? Want to build the web programs and apps that you

wished existed?

gr8code is a 9-week, fully intensive course on front-end development.

Just h i n k ~

in

9 weeks, you will be skilled at a full-time, professional

level with HTrvlL, CSS, Javascript, and associated server-side tech.

Practicing professionals will train you to think and work like a

developer. The entire curriculum is designed from a UX, quality-over

codemill perspective.

At the end of

your

coursework, we facilitate

your

first interviews and job

offers

BACKEND

BOOTCAMP

https://gr8code.com/our-programs/[

1116/2015

II :30:38 AM]


68/116

gr8codeFront-end Bootcrunp Igr8code

r

Front nd

o tc mp

b com flu nt, fa

t.

EXCEED

YOUR

LIMITS

https : Igr8code. com/our-programs/front end-bootcamp/

Page 1 of6

REBOOT YOUR

CAREER

1/16/2015


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gr8codeFront-end Bootcamp

I

gr8code

Page 2

of6

0

T T?

What Willi

But

in

What If I Kn

https://gr8code.com/our-programs/front-end-bootcamp/ 1/16/2015


70/116


I

gr8code Page 3 of 6

Courses

lnclud d:

GIT

D

Gl

UB

D

FRAMEWOR

NODE.JS BASI

HTML5/CSS3

RIPT

BASICS

TESTING


SASS, SCSS AND

A PIS

1/16/2015


71/116


I

gr8code

INTERVIEWING

AND

FINDING

WORK

Page 4

of6

TEAMWORK

There is such a lack of

top

talent in

:E

C-:1 Q

ca.et:

Cl.

~ z z

Cl.

Q

Cl.

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98/116

Reach out

to your campus director to receive an

application

link

or

apply

through

the

URL

below

https://climbcredit.co/apply/GR803984203460/

Fill

out

our short

application

on

your laptop,

iPhone,

or

iPad in

just a few minutes

Usually get

a

response

from

us

the

same

day-

we

may have to follow up for some questions

5


99/116

We

put every

school

through

a rigorous

vetting

process to

determine if it really helps students

transform

their future

earning

potential.

We

survey

alumni, speak with

recruiters

and

continually monitor the job prospects for a school's graduates.

The

financing

application typically only takes a few minutes

to

complete.

We let most applicants know if they qualify

the

same

day, but it

may

take up

to

a week

We offer fixed interest

rates ranging from

5/o-12/o depending on

your

credit history and future

income

prospects coming

out

of

your education. If you have

good

credit history, or a co-borrower,

you will most likely have a lower rate.

The

funds

are available as

soon

as

you

are

approved

for a loan.

We will

transfer

your tuition to your approved school upon

acceptance of

your offer.

If

you decide

not

to pursue

your

education within

the first

10

days

of

class

your

loan is cancelled. We don t want people to

take

out loans

for educations that

they don t

receive.

6


100/116

Once you are accepted

to a

partner school

just click

the link

they share and

you

will get access to

the

application.

Once you have provided us with your

social

security

number

and permission to access

your information,

we will contact a

credit bureau to provide us with your credit

history. We wi ll

never share your

personal

credit information anywhere or

with

~ ~ E - l . ? ~ n

e

with u ~ ) ' " g , ~ r ,

~ ~ ~ E E ~ ~ ~ " , E t : ; E m i s s i

on.

You

can be declined if you do not meet our minimum credit

criteria. If that occurs, you

can re-submit your

application with a

Co-Borrower and still receive

financing.

A Co-Borrower is

someone (often

a

parent I guardian or

loved

one) who

promises

,2 p ~ y y o u r l o ~ l ) } f

~ r o u

ca "l' , I 2 ~ Y .

Yes,

you

certainly can with

the

help of

a Co-Borrower.

At

this

time,

only US

Citizens and Permanent Residents are

eligible for

financing.

7


101/116

We ask

you to

pay

only

the interest

component of your

loan for

6 months, giving you some time to find a job.

Thereafter,

we ask

you

to

start paying

the

full

monthly amount.

If

your

loan amount is $8,500, the

monthly interest only

payment

amount will range from -$35-$85 and the full monthly

payment

will

range

from ~ 2 7 0 - 2 9 5 ,

depending upon your

actual interest rate.

Typically our loans have a 3 year term after the

program

ends.

You

can

pay

by

ACH,

credit

card,

or

other payment

methods.

We

offer

a discount for

borrowers who

set up an

automatic payment

from their bank account. You can also save your payment

information

so that

future payments can

be

sent

automatically.

You

can

pay

back your

loan, in

whole or in

part, at

any time

without penalty.

8


102/116

gr8codeAbout gr8code Igr8code Page I of I

https :/Igr8code.con11about -gr8code/

I/16/20I5


103/116

gr8codeAbout gr8code Igr8code Page 1

of2

https : Igr8code com/about -gr8code/

1/16/2015


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gr8codeAbout gr8code Igr8code

Page 2 of2

https:/ gr8code.com/about-gr8code/

1116/2015


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Page 1

of2

https :// gr8code .cmn about-gr8code/

1/16/2015


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I

gr8code Page 2

of2


1/16/2015


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gr8codeContact Us

I

gr8code

Page 1

of2

w

https://gr8code.com/contact-us/

1/16/2015


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gr8codeContact Us Igr8code Page 2 of2

https ://gr8code.com/contact-us/

1/16/2015


109/116

gr8codeFront-end Bootcmnp

I

gr8code

M

Front-

b

om

nd Boot

flu ntl

https://gr8code.con11our-programs/front-end-bootcamp/

mp

t.

Page 1 of6

1/16/2015


110/116

gr8codeFront-end Bootcmnp

I

gr8code Page 2 of6

T?

What Willi

But in

If I

https://gr8code.corn/our-programs/front-end-bootcamp/

1116/2015


111/116


I

gr8code Page 3

of6

Cours

In lud

d:

G

D GITHUB

P ~ ~ - f \ l f t ~ : N

D

FRAMEWORKS

TESTING

https://gr8code.com our-programs/front-end-bootcan1p/

SASS, SCSS

AND

QUERY

A

PIS

1/16/2015


112/116

gr8codeFront end Bootcamp

I

gr8code

I RVIEWING

AND

FIN NG

WORK

Page 4 of6

TEAMWORK

r

There

is

such a lack of top

talent

in d

everybody

is

scrambling for talent. Th

start-ups are lo

SAM

GORD

pld - verified derivative complaint [date stamped] (00060200)

Documents