Editors’ Note This story is momentous for Snopes’ newsroom in several ways. It represents the longest-running investigation we’ve ever tackled — some two years since our General Manager Vinny Green first tipped us to it — and that Senior Writer Alex Kasprak has ever produced. It also was among the most challenging to pursue because of the labyrinthine corporate structure of the anonymous business entities involved, making precise determinations impossible at times. As such, we welcome any new documentation or leads you have to offer. Finally, a word of warning: This investigation is not safe for work consumption. While we obscured, toned down, and/or avoided certain language and pornographic pictures, the material cited remains graphic, vulgar, and profoundly misogynistic — characteristics impossible to avoid in presenting the evidence. Thank you in advance for your understanding. — Doreen Marchionni, managing editor Snopes.com.

In April 2018, a seemingly simple question first presented itself to us: Why would the official Cheech and Chong Facebook page be sharing memes that not-so-subtly advertised bogus hook-up sites such as plentyofhoes.com? Our search for that answer took us on a months-long digital odyssey — first to a small operation run by two men in the English countryside, and ultimately to a much bigger operation spread between Ukraine and Silicon Valley. The convoluted international trail we followed, several financial-crime experts and investigators told us, appears to be designed to obscure the ownership details of companies that profit from deceptive dating websites by using fake profiles and expensive, hard-to-cancel subscription packages.

In this two-year investigation, Snopes follows the money from these deceptive dating companies to the Menlo Park office of a man whose private space company was awarded a bidding opportunity by NASA to build landers for future missions to the Moon.

Savage Memes

Since at least early 2018, high-profile, celebrity Facebook accounts have intermittently promoted non-existent hook-up sites with misogynistic names such as Zip Code Hoes, Hungry Hoes, Plenty of Cheats, and the like. Our primary goal at first was to figure out who was behind the celebrity memes and specifically how they profited from the placement of memes for hookup sites that do not exist.

The most recent instance we observed occurred in April and May 2019 and infected, in part, the Facebook timelines of Snoop Dogg, Ludacris, Cheech and Chong (both individually and as a duo), Charlie Sheen, Gucci Mane, Sean Kingston, The Game, Bow Wow, Shammi, Lil Twist, J. Holiday, Brad Holmes, and, The Situation. Snopes collected hundreds of examples published — and now mostly deleted — during this time. An extremely NSFW collection of the nearly 600 iterations of hook-up dating memes we encountered can be found here.

(We reached out to representatives or social media contacts we could find for Snoop Dogg, Cheech and Chong, Sean Kingson, Bow Wow, Shammi, and Lil Twist, but either we received no response, or the representatives, in their responses, were unable or unwilling to explain a meme’s appearance on their clients’ pages.)

The people who created these “memevertisements,” as we call them, are two self–described British “entrepreneurs” named Ryan Hodge and Adam Spencer. Both have occasionally referred to themselves as the “Savage Squad” (or “Savage Fam”) on social media. The websites their memes promote are fake sign-up pages programmed to dump a curious Facebook user onto a different, ostensibly legitimate dating website. Thanks to that fake page, the Savage Squad gets credit for bringing the user to that final site. If that user gives up a credit card number, the Squad receives a cut of the profits.

We found Spencer first. He had publicly listed himself as manager of several Facebook meme pages, and some of those pages contained hook-up memes reshared by celebrities. We found Ryan Hodge’s name because he and Spencer registered a business associated with a gift shop featured on one of those meme pages. We then found that many websites had been registered to a “Ryan Hodge” with words like “hoe” and “hub” in their URLs. In a process described in full detail here, we were able to link these Hodge-registered pages to some of the specific fake landing-page URLs we encountered on celebrity pages, including the website plentyofhoes.com found currently on Cheech Marin’s timeline. Neither Spencer nor Hodge responded to our requests for comment, and their online presences temporarily disappeared after we contacted them in August 2019.

Solving the mystery of who created these memes was the beginning of a much larger story, however. Each of the dating websites to which the Savage Squad was sending people was part of an affiliate marketing platform named TopOffers. This company provides financial incentives for individuals with significant social media reach to share links to a catalog of over 200 different dating websites.

The Savage Squad is hardly alone in gaming this platform through deceptive tactics. Two other examples come from Instagram and Tinder. On Instagram, “sex bots” — fake profiles programmed to flirt with users on Instagram — have reportedly been used to point unsuspecting users in the direction of TopOffers websites. Similarly, Snopes has obtained screenshots of several “profiles” on the dating app Tinder that, like the Savage Squad’s memes and landing pages, end up rerouting curious swipers to a TopOffers dating website. These are likely different actors profiting from the same affiliate marketing platform as the Savage Squad.

At best, TopOffers appears to be in denial about the apparently widespread abuse of its platform. When we first reached out to the company via email, then-“user acquisition lead” Nick Martsenitsen told us that “a preliminary check of our records indicates that all traffic generated by use of our platform is in compliance with our Terms of Use.” When we provided Martsenitsen an example of Cheech Marin’s sharing a Pornhub Hoes meme that ultimately redirected traffic to TopOffers, he conceded that this example represented “a serious violation of our TOS [terms of service].” The fake Tinder profiles — which Snopes had observed as recently as February 2020 — would be violations as well, he told us.

The existence of an entire affiliate marketing company dedicated to the promotion of these sites, and the fact that TopOffers is well-rated by its affiliates, suggests real money is to be made in this dubious economy.

Subscription Traps and Contested Snaps

At the root of this investigation is a product known as a “niche dating website.” These sites comprise the destinations to which the Savage Squad drove traffic through its fake landing pages. As opposed to more mainstream dating websites or apps such as Match.com or Tinder, these websites allegedly tailor their content toward people looking for specific kinds of partners, whether that’s people in uniform or those with specific ethnicities or physical attributes. We focused specifically on the 200-plus niche dating websites listed by the affiliate marketing company TopOffers — roughly 90% of which are largely identical in appearance:

It’s a pretty simple business model: To do anything on any of these sites besides make a profile, a user needs a paid membership. To encourage membership, the site bombards users who open an initially free account with a self-evidently ridiculous number of messages from attractive women who are alleged to live practically next door. As a final nudge, these sites generally offer a cheap, three-day trial package. Not prominently advertised with such offers is the fact that, according to the sites’ terms of service, “when you subscribe to … the trial period … you will become liable for automatic renewal billing.” The default liability is a monthly recurring charge that is subject to change. Cancelling an account on many of these sites, according to numerous online complaints, is challenging, if not impossible.

For investigative purposes, Snopes created free accounts on several TopOffers sites. A brief timeline of the level of activity we received on the website Spicy Desires in the first hour of joining — without our ever providing a profile picture or any personal details — is illustrative of the aggressive tactics used by these sites to convince people to sign up. We “browsed” the website as if we were searching for a partner and have highlighted below the pop-up notifications on the site that occurred:

One hour on Spicy Desires (Jan. 23, 2020)

5:36 PM

We provided email and location to create an account on “SpicyDesires.com.”

5:36 PM

We declined to add a profile picture or add other personal details.

5:40 PM

magicwp32 sent us a message.

Notification – Upgrade to Read

5:43 PM

Dominika sent us a message.

Notification – Viewable

5:43 PM

We attempt to reply to Dominka’s message.

Notification – Upgrade to Reply

5:45 PM

forcefullHall51 sent us a message.

Notification – Viewable

5:46 PM

Jenae6 sent you a message.

Notification – Upgrade to Read

5:49 PM

Lauren445 sent us a message.

Notification – Upgrade to Read

5:49 PM

We viewed katonya’s profile

5:50 PM

We viewed Rebecca’s profile

5:52 PM

katonya sent us a message.

Notification – Upgrade to Read

5:53 PM

We viewed Dana453’s profile

5:55 PM

Andrea3601 winked at us.

Notification – Viewable

5:58 PM

Julissa winked at us.

Notification – Viewable

5:59 PM

Rebecca sent you a message.

Notification – Upgrade to Read

5:59 PM

Dana 453 sent you a message.

Notification – Upgrade to Read

5:59 PM

Savannah sent you a message.

Notification – Upgrade to Read

6:22 PM

We were sent a reminder that we left a signup page without joining.

Notification – Email

During our time on the site, we also received a message from “anatasia_mikov.” Snopes identified the photograph associated with that profile as that of a professional model named Magda Panasiuk. Tara Le Roux, director of the London-based Linden Staub modeling agency that represents Panasiuk, told us via email that the image had been used without her consent. “Magda does not want to be involved in this story, nor has given her permission for her image to be used anywhere else online except her social media profiles and her modelling agency profiles,” Le Roux said. When “anatasia_mikov” messaged us (in Finnish, because Snopes was testing the site’s appearance in other countries at the time), she asked if we would like to chat with her. To take “anatasia” up on that offer, however, a credit card number was required.

These tactics are familiar to Steven Baker, a former director of the Federal Trade Commission’s (FTC) Midwest Region Office and an international investigations specialist for the Better Business Bureau. In 2014, he was part of the FTC’s first enforcement action against an online dating service: a company named JDI Dating. The FTC alleged that the company “used fake profiles to make people think they were hearing from real love interests and to trick them into upgrading to paid memberships,” and that “users were charged automatically to renew their subscriptions – often without their consent.” Like Snopes, the FTC set up blank profiles as part of that investigation, and the results mirrored those we found on TopOffers websites.

Baker told us that this sort of tactic, termed a “subscription trap,” is a potential violation of a U.S. law named the Restore Online Shoppers’ Confidence Act (ROSCA). In part that is because such tactics fail to clearly inform customers of their subscription terms or provide a simple way to stop recurring charges. “People have to understand upfront what they’re signing up for, and it has to be clear and conspicuous. What does clear and conspicuous means? It means people really … need to understand it,” he told us. “You can’t just bury that sort of stuff in terms and conditions.” ROSCA is a civil, as opposed to criminal, statute; the FTC fined JDI dating $616,165.

It’s not only models who have found images of themselves allegedly used without their permission. In one notable example that had been under litigation in late 2019, a married Miami, Florida, police officer with children, David Guzman, alleged his social media photos were used in advertisements for the website Uniform Dating without his consent. He sued the holding company that operated the website, NSI (Holdings) Ltd. Company Director Laura Edison alleged that Guzman had actually signed up for Uniform Dating himself in what may have been a “momentary dalliance.” Uniform Dating’s terms state that when you sign up for a membership “you automatically grant … to us … a non-exclusive, royalty free, worldwide licence to use, copy, publish, display, reformat, translate and distribute, and broadcast, such information or content.”

The evidence Edison first presented to support this notion was possibly flawed. She initially introduced a screenshot of a profile on Uniform Dating “with [Guzman’s] image, birth date, and personal email address, all of which has since been confirmed to be accurate.” The ZIP code listed, however, was for Miami, Arizona. The IP address shown as the one Guzman used to create the account was “0.0.0.0” In a second declaration, citing “additional information that NSI Holdings has discovered,” Edison argued that the ZIP code issue was the result of an auto-populated field that Guzman failed to correct, and that the 0.0.0.0 IP address was “a result of a user profile being created via a mobile device browser rather than through a website on a PC.” Further investigation, she said, identified the correct, Miami, Florida, IP address in the company’s database.

Guzman via his lawyer declined to comment for this story. The case was dismissed on jurisdictional grounds in January 2020. We also attempted to contact individuals who filed online complaints against these websites through the email addresses posted with their complaints, but we received no responses.

Pending litigation aside, our own investigation supports the allegations of fake profiles, photos used without consent, and buried subscription terms to encourage subscription charges on TopOffers sites. We then tried to figure out where all this subscription money ultimately flowed.

Following the Money

Snopes collected the legal contact information from each of the TopOffers sites’ terms of service pages. Based on this data, Snopes discovered that 194 sites out of the 218 listed on TopOffers.com are owned or operated by at least one off-shore company with a documented historical or present-day connection to venture capitalist and Firefly Aerospace Co-Founder Max Polyakov. A detailed accounting of that conclusion can be found in this document. Polyakov has had a long and public association with online dating: He was co-founder of the publicly traded, U.K.-based online dating company Cupid plc — once a darling of the British tech sector.

In 2013, however, a report by the BBC alleged Cupid used “fake profiles” of women to entice men to sign up for their paid service — behavior similar to what we observed at current TopOffers sites. Though the company vehemently denied the allegations and asserted that an independent review exonerated the firm of wrongdoing, Cupid plc ceased existing as a dating company by the end of 2014. In a series of transactions completed in 2013 and 2014, Cupid plc sold its myriad dating websites to several offshore entities in the British Virgin Islands (BVI) and Malta.

Around this time, Polyakov moved to Silicon Valley and branded himself a player in the intersecting worlds of venture capital and aerospace tech. Though the fact that he purchased some Cupid plc websites was publicly disclosed, post-2016 Polyakov biographies often imply no current involvement in online dating or neglect to mention his history with Cupid in the first place. He is a managing partner at venture capital firm Noosphere Ventures and has previously identified himself as that firm’s chief executive officer (CEO). Noosphere Ventures’ website simply states that “we invest in space technology companies.”

Polyakov also supports a global “Association Noosphere” network of non-profit organizations, supports universities in his native Ukraine, and is involved in other charitable causes. He can be found in the company of high-ranking U.S. officials, including former U.S. Ambassador to Ukraine Bill Taylor:

Polyakov (center) with former U.S. Ambassador to Ukraine Bill Taylor to his right.

From what can be gleaned through the public record, however, Polyakov apparently never gave up a financial stake in the online dating industry. To the contrary, it appears as though he merely incorporated his dating businesses, masked by a convoluted network of holding companies in different jurisdictions, into the portfolio of his Menlo Park venture capital firm, Noosphere Ventures. The latter does not publicly disclose all of its sources of its funding, and it is the same entity that purchased and funds the company Firefly Aerospace.

However, the nature of these offshore jurisdictions allows a person to obscure ownership, shareholder information, and assets, and enables the formation of what are termed anonymous companies — making it impossible to conclusively prove that Polyakov is the current owner or beneficiary of each of the companies associated with TopOffers websites. Mark Hays, an anti-money laundering expert at Global Witness, an NGO that seeks in part to end “corruption in the global political and economic system,” told us by phone that, “It’s very difficult to know exactly where all the sources of funds are coming from or going to because the fundamental corporate structure is built or has been built on shell companies that are created in so-called secret jurisdictions: Malta, Cyprus, [and] BVI.”

What we can demonstrate — using court records, business filings, press reports, and internet forensics — is that each shell company that owns and operates these largely identical TopOffers websites has a documented historical connection to Polyakov, remains currently active, and shows no evidence of having been sold by Polyakov to any new or unrelated owners. Two instances in which Polyakov or his companies were sued provide evidence of both the convoluted structure of the businesses associated with TopOffers websites and Polyakov, and Noosphere Ventures’ connection to them.

The first example comes from a March 2014 lawsuit against a Cyprus-registered company named Alcuda Ltd that was alleged to have spammed a children’s email provider with over 20,000 emails advertising dating websites with names like “iwantumilf.com” and “shagaholic.com.” In those filings, Polyakov was described as “founder and director” of both the defendant Alcuda Ltd and another company, the BVI-registered Bulova Invest Limited. This same Bulova Invest Limited also appears as the holding company for at least 41 dating websites in the TopOffers catalog.

A second example comes from court documents filed in 2016 regarding a dispute between Polyakov and two former business partners. Among other things, this case identified a BVI-registered company named Phoenix Holdings Limited as a legal entity that maintained a collection of dating websites grouped under the moniker Together Networks. Together Networks represents at least 49 of the dating sites listed on TopOffers.

The Phoenix Holdings Link

The Phoenix Holdings court case also provides evidence linking the broader network of dating businesses directly to Polyakov’s Noosphere Ventures and to Firefly Aerospace. Based on findings from the two court cases described here, Phoenix Holdings appears to be near the top of the holding company pyramid (shown below) associated with the TopOffers website holding companies, as it is the entity that owns Alcuda Ltd, Bulova Invest, Together Networks, and other intermediate companies that ultimately own portions of other TopOffers-related companies:

Arrows from each company point toward the business entities that either control, own, or partially own that company.

Several reasons explain why people sometimes register their companies in so-called offshore jurisdictions, Matthew Stephenson, a professor at Harvard Law School who teaches anti-corruption law, told us in a phone interview. But, he said, “When you have multiple anonymous companies all owning each other in various convoluted complex schemes, I would say there’s no legitimate reason […] other than to conceal the actual owner of the company.”

The Phoenix lawsuit, however, did actually reveal three people who have had, at one time or another, a personal financial interest in Phoenix Holdings Ltd.: Max Polyakov, his father, and someone identified as “Mr. James Watt.” Based on the corporate link between Phoenix and Together Networks stated in case files, as well as Mark Watt’s middle name, we infer that these documents are referring to Mark James Watt — the same Mark Watt who is a partner at Noosphere Ventures and a co-founder, board member, and the acting chief financial officer (CFO) of Firefly Aerospace. Neither Watt nor Polyakov responded to a detailed list of questions we sent them.

Evidence and Obfuscation

That both partners of Noosphere Ventures appear to have, at least, a past financial interest in an offshore holding company responsible for an international network of deceptive dating websites is evidence of a link between the dating business, Noosphere Ventures, and Firefly Aerospace — but it is far from the only evidence. For one thing, Noosphere Ventures’ corporate address is the same as a company named “Together Networks USA, Inc.,” a California-registered company with the same name as the entities that maintain numerous TopOffers dating websites. Lakshmi Kumar, policy director at the U.S -based think tank Global Financial Integrity, said in a phone interview that, “It’s deeply suspicious they [Together Networks and Noosphere Ventures] would share an address because they’re such different entities.”

When Together Networks USA was first registered, it took the name of an existing Delaware-registered company named “Woodrock USA.” Four months later, the company amended its name to Together Networks USA.

In addition, the person who first registered Together Networks USA was Noosphere partner and Firefly Aerospace acting CFO Mark Watt. He registered both USA and a company named Noosphere Ventures USA Inc. on the same day — Aug. 29, 2013 — a month or so after Cupid plc announced the sale of what it called its “casual assets” to a Polyakov-linked shell company. In 2013, Together Networks and Noosphere Ventures shared the same corporate address. When Noosphere Ventures moved in 2016, Together Networks USA moved to the same address, this time with another man listed in business filings: a former Noosphere Ventures employee named Vladimir Levykin.

In addition to currently owning his own U.K. space company named Skyrora Ventures, Levykin is listed as holding at least 75% ownership in an apparent U.K. subsidiary of Firefly Aerospace. That company changed its name from “Firefly Aerospace UK” to “Arosky Services Limited” on April 8, 2019.

It is self-evident that Noosphere Ventures maintains a present-day relationship to Together Networks, and by extension with the remains of Polyakov’s Cupid plc dating empire. A 2017 press release from Noosphere stated in passing that “Together Networks” is “in its portfolio.” The most recent person to list herself as director of Together Networks USA in 2019 filings is Zoya Grishashvili, who describes herself on LinkedIn as head of human resources for Noosphere Ventures and personal assistant to the company’s “CEO” and “founding partner” — which could only be referring to Polyakov and/or Watt. Noosphere Ventures’ funding of Firefly Aerospace is a matter of public record.

Implausible as it may sound, Polyakov, Levykin, and Watt are not the only current or former Noosphere employees who have or have had leadership roles in online dating businesses and space startups. Laura Edison — the NSI Holdings director presently arguing in federal court that Uniform Dating’s use of police officer Guzman’s image was the result of his “momentary dalliance” — was, until we contacted her, listed as “contracted general counsel” for Noosphere Ventures on LinkedIn and is currently listed as the director of the apparent U.K subsidiary of Firefly Aerospace, according to U.K business records. She is also a director of, and legal counsel for, Levykin’s Skyrora Ventures, which, she told us by email, denies any connection to Noosphere Ventures.

Before we reached out to Edison with questions about links between Noosphere and dating websites on Jan. 6, 2020, her LinkedIn profile listed one of her jobs as “contracted general counsel” for Noospheres Ventures and executive director of Skyrora. After we sent our questions via email, someone removed Noosphere Ventures from Edison’s LinkedIn profile and changed her title at Skyrora to “non-executive director.” When we asked Edison about her apparent links between Noosphere Ventures, Skyrora, and dating websites, she told us that “as an experienced practitioner in the tech sector I act as a board member of many U.K. companies.”

Lunar Dreams

On Nov. 29, 2018, NASA selected Firefly Aerospace as one of nine companies to be given the opportunity to place bids on contracts to build landers for future missions to the moon. Though this was not a commitment by NASA to purchase Firefly’s services, the underlying projects on which Firefly is now eligible to bid — essentially delivery services to the moon’s surface — are lucrative, representing up to $2.6 billion in NASA spending over 10 years. Firefly Aerospace is publicly funded by Noosphere Ventures, which shares office space and staff with a global network of deceptive dating websites that operate in potential violation of FTC regulations.

This should be a concern for NASA and the U.S. government, according to Global Financial Integrity’s Kumar: “Should key U.S. national interests be in bed with an individual who owns companies that have a really shady past?” Neil Gordon, an investigator at the non-partisan Project on Government Oversight, echoed this point. “It certainly should be a matter of concern for NASA,” he told us by phone. “It goes to the reputation of the vendor they’re doing business with, whether they’re a responsible vendor. And if they have these shady businesses on the side, it might point to a larger problem with their ethics and their honesty.”

In response to a summary of our findings, a NASA spokesperson told us that it “is not aware of any illegal activity by Firefly Aerospace.” Gordon, who has researched the ways in which contractors have used offshore companies to deceive the federal government, explained by phone that U.S. law requires a determination that potential vendors are “affirmatively responsible.” This means, in part, that they “have a satisfactory record of integrity and business ethics.” NASA, in its response, told us that “The agency follows all federal procurement practices to ensure its business partnerships are within current laws and regulations.”

Here is what we know about the company NASA entered into a business relationship with: It is owned by, and funded through, a venture capital fund that shares office space and staff with Together Networks, a company that is home to websites like nastymams.com and that uses deceptive tactics to sign people up for recurring credit card charges. Firefly’s acting CFO and Co-Founder Mark Watt and Firefly’s Co-Founder Max Polyakov have had, at the very least, a historical financial interest in a labyrinthine network of holding companies that own or maintain these websites. The affiliate marketing platform that drives income from these sites is riddled with abuse that has resulted in the recurring pollution of high-profile Facebook feeds and the widespread use of “sex bots” to trick people on Tinder or Instagram.

Can such a company credibly be deemed “satisfactory” from a business ethics or integrity standpoint? NASA’s position, at the moment, appears to be “yes.”

This story originated with a tip from Snopes General Manager Vinny Green, who also contributed to the reporting. Staff writer Bethania Palma also contributed research to this story.

Disclosure: Alex Kasprak was employed by NASA’s Jet Propulsion Laboratory from 2013 to 2015.