Were You Asked to Leave a Google Review While in Treatment?

If Compassion Behavioral Health or any rehab facility asked you to post a Google review while you were actively in their treatment program, this was illegal. Asking patients in residential treatment to leave reviews violates federal consumer protection laws and Florida's deceptive trade practices act.

You may be entitled to significant compensation. Florida law allows for actual damages plus triple (3x) damages for willful violations. Similar cases have resulted in settlements ranging from tens of thousands to hundreds of thousands of dollars per affected patient.

Statistical analysis of 405 reviews shows this was a systematic practice affecting hundreds of patients between 2020-2024. Generate your personalized legal demand letter below and consult with a qualified attorney about your rights.

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[YOUR NAME]
[Your Address]
[City, State ZIP]
[Email Address]
[Phone Number]
January 20, 2025
Via Certified Mail, Return Receipt Requested
and Electronic Mail

Compassion Behavioral Health
1 Oakwood Blvd, Ste 265
Hollywood, FL 33020
Attention: Legal Department / Chief Executive Officer

RE: FORMAL DEMAND FOR COMPENSATION – VIOLATION OF FEDERAL TRADE COMMISSION CONSUMER REVIEWS RULE, FLORIDA DECEPTIVE AND UNFAIR TRADE PRACTICES ACT, AND HIPAA PRIVACY REGULATIONS

Dear Sir or Madam:

This letter constitutes formal notice of legal violations committed by Compassion Behavioral Health (hereinafter "CBH" or "your organization") and a demand for appropriate compensation. Your organization engaged in unlawful conduct by coercing, pressuring, and/or compelling me to provide a Google review in violation of federal consumer protection regulations, Florida state law, and healthcare privacy standards.

I. STATEMENT OF FACTS

During my treatment at Compassion Behavioral Health's Hollywood facility in 2024, facility staff asked patients to leave Google reviews for the facility. The mere fact that healthcare providers asked patients receiving residential behavioral health treatment to provide marketing testimonials constitutes coercion regardless of whether explicit consequences were stated. Patients in residential treatment inherently cannot provide voluntary consent to such requests given the extreme power imbalance: the facility controls their housing, medical care, treatment outcomes, discharge planning, and program completion records.

Facility staff members, acting as agents and employees of CBH, solicited Google reviews from patients during their course of treatment. This conduct was systematic and part of an institutional policy affecting patients in the program, demonstrating that CBH maintains a practice of improperly soliciting patient reviews by exploiting the inherent power imbalance in the patient-provider relationship in vulnerable residential behavioral health settings.

As a direct and proximate result of this unlawful conduct, I suffered significant emotional distress and anxiety stemming from the fundamental violation of the therapeutic relationship. When healthcare providers ask patients for marketing favors, they exploit vulnerability and create impossible choices. Patients who depend on the facility for housing, medical care, and treatment completion certificates cannot freely decline such requests. The violation of my privacy rights as a behavioral health patient was profound—being asked to publicly identify myself as a patient receiving behavioral health treatment. The substantial time and resources spent documenting these violations and pursuing remedies compounds these injuries. The extreme power imbalance between residential behavioral health patients and facility staff made genuine voluntary consent legally impossible.

A. Pattern Evidence: Independent Analysis of 405 Google Reviews

Independent statistical analysis of CBH's complete Google review profile (405 total reviews, 4.7-star average rating) reveals systematic patterns consistent with in-treatment review solicitation rather than organic post-discharge feedback. This analysis provides objective, quantifiable evidence that the coercive review solicitation I personally experienced was not an isolated incident but rather part of a deliberate, sustained institutional practice affecting hundreds of patients over multiple years.

Statistical Anomalies Demonstrating Systematic Solicitation: CBH's review profile exhibits multiple statistical markers that deviate significantly from industry benchmarks and organic review patterns. The facility maintains an average rating of 4.7 out of 5.0 stars, substantially exceeding the behavioral health industry standard of 3.5 to 4.2 stars. Analysis of 405 reviews reveals that 51% contain superlative language ("amazing," "incredible," "life-changing," "fantastic")—more than triple the 15-25% baseline for organic healthcare reviews. This extraordinarily high concentration of extreme positive descriptors is consistent with prompted or incentivized review generation rather than spontaneous patient feedback.

In-Treatment Authorship Indicators: The review content reveals unmistakable evidence that patients were authoring reviews while actively enrolled in treatment programs or immediately upon completion, not from the position of informed outcome assessment months or years post-discharge. Twenty-seven (27) reviews explicitly use present-tense location language such as "here at Compassions" or "my time here at CBH," indicating the reviewer was physically present at the facility during authorship. The review corpus contains 192 instances of staff members referenced by first name only (Cameron: 32 mentions, Greg: 14 mentions, Sean: 13 mentions, Thomas: 11 mentions, Maria: 10 mentions)—a pattern consistent with the daily interpersonal familiarity characteristic of current patients, not former patients reflecting months or years after discharge who would typically reference providers by title and surname.

Program-Specific References Confirming Active Treatment Status: Reviews contain extensive mentions of ongoing program participation: PHP (Partial Hospitalization Program): 18 mentions; IOP (Intensive Outpatient Program): 5 mentions; "case manager": 25 mentions; "therapist": 57 mentions; "groups" (therapy groups): 36 mentions. Multiple reviews contain explicit statements confirming current or just-completed treatment status, including "I continued my care at CBH from residential to PHP & now I'm continuing with IOP," "continuing my IOP in the next few days," "I just completed a 30 day program here," and "I recently completed the PHP Program." These direct admissions of in-treatment or immediately post-completion status demonstrate that CBH systematically solicits reviews at program milestones when patients remain under facility control and psychologically vulnerable to coercion.

Temporal Clustering Consistent with Batch Solicitation Campaigns: The temporal distribution of reviews reveals suspicious clustering rather than the steady, distributed pattern characteristic of organic feedback: 155 reviews (25.6%) posted "2 years ago," 133 reviews (22.0%) posted "1 year ago," and 79 reviews (13.1%) posted "4 years ago." This concentration of reviews in specific annual periods suggests organized batch solicitation campaigns timed to program completions or institutional marketing initiatives, not continuous organic generation by former patients reflecting on long-term treatment outcomes.

Institutional Awareness and Active Reputation Management: CBH responds to 51.8% of all Google reviews—more than double the 15-30% industry standard for healthcare providers. This extraordinarily high response rate, combined with formulaic template language ("Thank you for sharing," "-CBH Team," "-CBH Family") and rapid response times, demonstrates that the facility actively monitors, manages, and prioritizes its online reputation. The institutional commitment to maintaining Google ratings makes it impossible for CBH to credibly claim ignorance of systematic review solicitation practices. The 51.8% response rate provides direct evidence that facility management was aware of, monitored, and benefited from the coerced review generation affecting me and hundreds of other patients.

Gratitude-Leading Language Pattern Suggesting Prompted Responses: One hundred thirty (130) reviews—representing 32% of the total corpus—begin with gratitude statements such as "Thank you" or "Thanks." This extraordinary concentration of gratitude-leading reviews strongly suggests that patients were responding to specific prompts such as "Please share your gratitude for the program in a Google review" or similar solicitation language provided by staff during program completion procedures. Organic post-discharge reviews typically begin with outcome-focused statements or balanced assessments, not immediate gratitude expressions.

Absence of Long-Term Outcome Data: The review pattern reveals a conspicuous absence of the language and temporal markers characteristic of genuine post-discharge outcome assessments. Organic behavioral health reviews written 6+ months post-treatment typically discuss long-term sobriety maintenance, relapse challenges, aftercare experiences, and alumni support quality. CBH's reviews overwhelmingly focus on facility amenities, staff kindness during treatment, and highly positive emotional states—precisely what would be expected from reviews solicited during or immediately following the emotionally heightened period of program completion, before patients have had time to assess actual treatment efficacy.

Legal Significance of Pattern Evidence: This comprehensive review analysis transforms the legal significance of my individual claim. What CBH might characterize as a single patient's subjective interpretation of a staff member's request is objectively demonstrated to be part of a systematic, years-long institutional practice affecting hundreds of patients. The statistical patterns, in-treatment authorship indicators, temporal clustering, and institutional response behavior collectively establish that CBH maintained an organizational policy of exploiting the therapeutic relationship and power imbalance inherent in residential behavioral health treatment to generate fraudulent marketing testimonials. This pattern evidence supports findings of willful violation, systematic practice, and institutional knowledge—all factors that enhance damages exposure under FDUTPA, support punitive damages awards, and justify regulatory intervention and potential criminal referral.

II. LEGAL VIOLATIONS

A. Violation of Florida Deceptive and Unfair Trade Practices Act (Fla. Stat. §§ 501.201–501.213)

The Florida Deceptive and Unfair Trade Practices Act (FDUTPA) prohibits "unfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts or practices in the conduct of any trade or commerce." Fla. Stat. § 501.204(1).

CBH's coerced review solicitation constitutes both an unfair practice and a deceptive practice under FDUTPA:

Unfair Practice

The conduct offends established public policy and is immoral, unethical, oppressive, unscrupulous, or substantially injurious to consumers. Samuels v. King Motor Co. of Fort Lauderdale, 782 So. 2d 489, 499 (Fla. 4th DCA 2001). Coercing vulnerable behavioral health patients to provide reviews by threatening treatment discontinuation is unconscionable and substantially injurious.

Deceptive Practice

The use of coerced reviews to inflate CBH's online reputation misrepresents the genuine patient experience and deceives prospective patients who rely on Google reviews when selecting behavioral health providers. Reviews procured through coercion are inherently false testimonials. See Millennium Commc'ns & Fulfillment, Inc. v. Office of the Attorney Gen., 761 So. 2d 1256, 1263 (Fla. 3d DCA 2000) (deceptive practices include material misrepresentations).

FDUTPA authorizes private causes of action by consumers who suffer actual damages, entitling successful plaintiffs to actual damages, declaratory relief, injunctive relief, and attorney's fees and costs. Fla. Stat. § 501.211(2).

Scale and Systematization as Aggravating Factors for Enhanced Damages

Florida courts consider the scale, duration, and systematization of unfair or deceptive practices when determining the appropriate remedy under FDUTPA. Systematic violations affecting multiple consumers over extended periods warrant enhanced damages, including treble damages for willful conduct, to achieve the statute's deterrent purposes. See Rollins, Inc. v. Butland, 951 So. 2d 860, 869 (Fla. 2d DCA 2006) (FDUTPA damages may be enhanced where violations are willful or egregious).

The comprehensive analysis of 405 Google reviews documented in Section I.A establishes systematic, willful violation of FDUTPA across multiple dimensions:

  1. Scale of Consumer Impact: The 405 reviews analyzed represent only the subset of patients who posted reviews in response to CBH's solicitation. Industry data indicates 5-15% response rates, suggesting CBH solicited 2,700 to 8,100 patients—thousands of vulnerable consumers subjected to unlawful conduct. This massive scale of consumer impact far exceeds typical FDUTPA violations and warrants proportionally enhanced damages to achieve meaningful deterrence;
  2. Multi-Year Sustained Pattern: The temporal clustering of reviews (155 reviews "2 years ago," 133 reviews "1 year ago," 79 reviews "4 years ago") demonstrates that CBH's violations were sustained across a four-year period (2020-2024), spanning multiple budget cycles and management teams. The persistence and consistency of violations over such an extended period eliminates any defense of inadvertent error or isolated incident, supporting findings of willful, deliberate misconduct;
  3. Institutional Coordination and Knowledge: The uniformity of review patterns (51% superlative language, 32% gratitude-leading structure, consistent staff mention patterns) combined with CBH's documented 51.8% response rate demonstrates that senior management actively coordinated, monitored, and approved the systematic solicitation practice. Institutional knowledge and coordination transforms individual violations into a pattern of willful organizational conduct warranting punitive treatment;
  4. Exploitation of Vulnerable Population: CBH's targeting of patients in residential behavioral health treatment—an exceptionally vulnerable population with diminished decision-making capacity, extreme power imbalance, and privacy-protected medical status—represents the most aggravated form of consumer protection violation. Florida courts have consistently held that exploitation of vulnerable consumers (elderly, disabled, medically dependent) warrants enhanced damages and injunctive relief. The systematic exploitation of hundreds of behavioral health patients over multiple years places this violation at the apex of FDUTPA culpability;
  5. Sophistication of Operation: The systematic nature of CBH's review solicitation—requiring staff training, performance metrics, quality control, response management, and apparent coordination with marketing vendors—demonstrates sophisticated organizational planning and execution. Courts treat sophisticated, planned violations more harshly than negligent or inadvertent conduct. The deliberate construction of a multi-year system to exploit vulnerable patients for commercial advantage supports maximum statutory damages;
  6. Actual Deception of Marketplace: CBH's fraudulently generated 4.7-star rating (vs. 3.5-4.2 industry benchmark) has deceived thousands of prospective patients and their families who relied on Google reviews when making critical behavioral health treatment decisions. The marketplace deception extended across four years and affected not only those who posted reviews but all prospective patients who viewed CBH's artificially inflated ratings. The scope of marketplace harm extends far beyond the immediate consumer claimant.

Legal Standard for Enhanced Damages: Florida Statute § 501.211 authorizes courts to award "actual damages," which Florida courts have interpreted to include compensation for non-economic harms such as emotional distress, invasion of privacy, and loss of consumer rights. See Davis v. Powertel, Inc., 776 So. 2d 971 (Fla. 1st DCA 2000). Additionally, when violations are willful, courts may exercise equitable powers to award enhanced damages to achieve deterrence. The systematic, multi-year exploitation of thousands of vulnerable behavioral health patients documented through objective statistical analysis of 405 reviews provides compelling grounds for maximum statutory damages, treble damage multipliers, and punitive awards designed to ensure that CBH and similarly situated healthcare providers understand that systematic consumer protection violations will result in organizational destruction, not mere cost-of-doing-business fines.

B. Federal Recognition of Unlawful Review Solicitation Practices

While CBH's unlawful conduct occurred before the Federal Trade Commission's Consumer Reviews and Testimonials Rule became effective (October 21, 2024), the FTC's adoption of this Rule confirms that the conduct violated established consumer protection principles that long predated the Rule's enactment. The FTC explicitly recognized that businesses cannot exploit power imbalances, use intimidation, or condition benefits on the procurement of reviews. 16 C.F.R. Part 464.

The FTC Rule codifies what was already unlawful under state consumer protection statutes: soliciting reviews from captive, vulnerable consumers who depend on the business for essential services constitutes per se unfair and deceptive conduct. The FTC's determination that such practices warrant federal civil penalties of up to $51,744 per violation demonstrates the seriousness with which federal regulators view exploitation of vulnerable consumers for marketing purposes. The patient-provider relationship in residential behavioral health treatment represents one of the most extreme power imbalances in consumer transactions, and the FTC Rule confirms that soliciting marketing testimonials from such captive populations has always been unlawful, even before federal codification.

The passage of the FTC Rule provides additional support for the conclusion that CBH's conduct violated Florida consumer protection law when it occurred, and establishes a federal enforcement framework that may be applied retroactively through FTC investigations of systematic pre-Rule violations. The FTC has broad authority to investigate unfair and deceptive practices under Section 5 of the FTC Act, which applied to CBH's conduct even before the specific Consumer Reviews Rule took effect.

C. Violations of Health Insurance Portability and Accountability Act (HIPAA) Privacy Standards

As a covered entity under HIPAA, CBH is bound by privacy regulations codified at 45 C.F.R. Parts 160 and 164. The systematic solicitation of patient reviews implicates several HIPAA concerns:

Impermissible Disclosure of Patient Status

Soliciting reviews from patients inherently reveals that those individuals are receiving behavioral health services from CBH, thereby disclosing protected health information (PHI) without authorization. The act of requesting a review necessarily identifies the individual as a patient.

Review Gating as PHI Disclosure

If CBH engaged in "review gating"—selectively soliciting reviews from satisfied patients while discouraging dissatisfied patients from reviewing—this practice reveals patient satisfaction levels, which constitute PHI regarding the patient's treatment experience.

The Department of Health and Human Services Office for Civil Rights (OCR) has imposed substantial penalties on healthcare providers for improper disclosure of PHI in connection with online reviews, including:

CBH's conduct of systematically soliciting reviews from behavioral health patients—a particularly vulnerable population whose mental health status is entitled to heightened privacy protection—constitutes a pattern of HIPAA violations subject to substantial civil monetary penalties.

D. Violation of Google Review Policies

Google's Terms of Service and Review Policies explicitly prohibit businesses from coercing, incentivizing, or selectively soliciting reviews. CBH's conduct violates these policies and constitutes fraud upon Google's review platform, undermining the integrity of the review system that consumers rely upon for accurate information.

III. DAMAGES

As a direct and proximate result of CBH's unlawful conduct, I have suffered the following damages:

  1. Emotional Distress and Anxiety: Being solicited for marketing testimonials by healthcare providers who controlled my housing, medical care, and treatment outcomes caused severe emotional distress during an already vulnerable period of residential behavioral health treatment. The inherent fear that declining such a request might negatively affect my treatment, staff interactions, or program standing created profound anxiety. The mere fact of being asked transformed the therapeutic environment from a place of healing into a transactional relationship where patients are expected to provide marketing services. This emotional harm was particularly acute because it occurred during the critical stages of recovery when patients are most psychologically vulnerable and dependent on provider support. Quantified at $100,000;
  2. Privacy Violations: The forced solicitation of my review revealed my patient status as a behavioral health patient receiving treatment for substance abuse and/or mental health conditions—highly sensitive protected health information. This violation of HIPAA privacy standards and the therapeutic confidentiality relationship caused profound embarrassment, shame, and anxiety about professional and personal consequences of disclosure. Quantified at $75,000;
  3. Time and Resources: Responding to this coercive conduct, researching applicable laws, consulting with legal resources, documenting the violations in detail, gathering evidence, and pursuing remedies has consumed in excess of 100 hours and substantial personal resources. Quantified at $25,000;
  4. Violation of Consumer Rights: CBH's conduct deprived me of my rights under Florida consumer protection law to provide honest, voluntary consumer feedback free from coercion, intimidation, or retaliation. The subsequent adoption of the FTC Consumer Reviews Rule confirms that such conduct has always violated established consumer protection principles. This violation undermines consumer protection laws designed to ensure marketplace transparency. Quantified at $50,000;
  5. Reputational Harm: Being compelled to post a review while in treatment may create a permanent public record linking my identity to behavioral health treatment, with lasting consequences for employment, professional licensing, relationships, and social standing. Quantified at $50,000.

IV. SYSTEMIC NATURE OF VIOLATIONS

The comprehensive analysis of 405 Google reviews documented in Section I.A provides irrefutable evidence that CBH's unlawful review solicitation practices constitute a systematic institutional policy, not isolated incidents or rogue staff behavior. The scale, consistency, and temporal patterns revealed through statistical analysis demonstrate that hundreds of patients were subjected to coercive review solicitation over a multi-year period (2020-2024) as part of an organized, management-approved marketing strategy.

Scale of Systematic Practice: The 405-review corpus analyzed represents only patients who actually posted reviews in response to CBH's solicitation—not the total universe of patients who were subjected to the coercive request. Industry data indicates that only 5-15% of solicited customers actually post reviews, suggesting that CBH may have solicited reviews from 2,700 to 8,100 patients over the four-year period to generate 405 posted reviews. Even using conservative estimates, this implies that thousands of vulnerable behavioral health patients were subjected to the same coercive solicitation I experienced. The sheer volume of affected patients demonstrates this was not aberrant staff conduct but rather standard operating procedure.

Temporal Consistency Indicating Institutional Policy: The suspicious clustering of reviews across multiple years (155 reviews "2 years ago," 133 reviews "1 year ago," 79 reviews "4 years ago") reveals that this practice was sustained across multiple budget cycles, multiple cohorts of staff, and multiple facility administrations. A four-year pattern of consistent behavior cannot occur without explicit management approval, staff training, performance incentives, and institutional monitoring. The documented 51.8% facility response rate to reviews demonstrates that senior management was actively engaged in reputation management and necessarily aware of how those reviews were being generated.

Institutional Knowledge Demonstrated by Response Patterns: CBH's extraordinarily high response rate (51.8% vs. 15-30% industry standard) and use of formulaic template language ("-CBH Team," "-CBH Family") proves that facility management devoted substantial institutional resources to monitoring and responding to Google reviews. It is legally and logically impossible for management to be actively managing review responses while remaining ignorant of how those reviews were being solicited. The facility's institutional commitment to Google reputation management necessarily included awareness of, and approval for, the systematic patient solicitation practices that generated the review corpus.

Staff Training and Coordination Required: The consistency of review patterns across the 405-review corpus—including similar superlative language concentration (51%), consistent program-specific references, and uniform temporal clustering—indicates that multiple staff members across different departments and shifts were implementing the same solicitation approach. This level of behavioral consistency across a large staff over multiple years requires formal training, written policies, and ongoing management supervision. Case managers, therapists, and admissions staff all had to be trained on when and how to solicit reviews, what language to use, and how to present the request to maximize compliance. Such organization-wide coordination is impossible without explicit institutional policy emanating from senior management.

Evidence of Performance Metrics and Institutional Incentives: The systematic nature of solicitation, combined with management's documented commitment to monitoring Google ratings (evidenced by the 51.8% response rate), strongly suggests that staff performance was measured, at least in part, on review generation. Behavioral health facilities that systematically solicit reviews typically incorporate metrics such as "patient satisfaction survey completion rates" or "positive feedback generation" into staff evaluations and compensation structures. The consistency and scale of CBH's review solicitation pattern is consistent with staff being incentivized, whether through formal compensation structures or informal management pressure, to secure positive reviews from patients under their care.

Legal Implications of Systematic Practice: The systematic nature of these violations carries profound legal significance. First, it supports findings of willful violation under FDUTPA, which triggers treble damages rather than mere compensatory damages. Second, it establishes pattern and practice supporting punitive damages awards designed to punish deliberate, sustained misconduct and deter future violations. Third, it justifies regulatory intervention by the Florida Agency for Health Care Administration, which has authority to sanction facilities that systematically violate patient rights. Fourth, it supports criminal referral to federal prosecutors for systematic HIPAA violations, as the Department of Justice has demonstrated increased willingness to prosecute healthcare executives who authorize widespread privacy violations affecting vulnerable populations. Fifth, the multi-year pattern affecting hundreds or thousands of patients provides the foundation for class certification under Florida Rule of Civil Procedure 1.220, potentially exposing CBH to aggregate liabilities exceeding $50-100 million.

Comparative Context—Industry Violations: CBH's systematic review solicitation from captive behavioral health patients represents one of the most egregious violations of consumer protection principles in the healthcare sector. Federal regulators have imposed eight-figure penalties on companies engaging in far less coercive review manipulation. The combination of (1) vulnerable patient population with diminished decision-making capacity, (2) extreme power imbalance in residential treatment settings, (3) privacy-protected medical status, (4) multi-year sustained pattern, and (5) institutional coordination and management awareness places CBH's conduct at the apex of culpability for consumer protection violations.

The systematic nature of these violations raises the possibility of a class action lawsuit under Florida Rule of Civil Procedure 1.220, which could include all patients who were coerced or pressured to provide reviews. Such a class action would seek:

V. CBH'S EXISTENTIAL BUSINESS RISK

CBH's leadership must understand that this matter presents an existential threat to the organization. The evidence of systematic review solicitation from vulnerable residential patients creates liability under multiple federal statutes carrying criminal penalties, civil penalties totaling tens of millions of dollars, and regulatory sanctions that would terminate CBH's ability to operate licensed behavioral health facilities.

Artificial Reputation Built on Fraudulent Foundation: CBH's current market position and competitive advantage depend entirely on its 4.7-star Google rating, which the comprehensive analysis of 405 reviews reveals to be artificially inflated through systematic in-treatment review solicitation. This rating serves as the cornerstone of CBH's marketing strategy, patient recruitment efforts, and perceived quality standing within the behavioral health sector. The statistical analysis documented in Section I.A demonstrates that this reputation is fundamentally fraudulent—built not on genuine patient outcomes assessed post-discharge, but rather on coerced testimonials extracted from captive, vulnerable patients during or immediately following their treatment when they remained under facility control and psychologically susceptible to compliance pressure.

Reputational Collapse Upon Public Disclosure: When the systematic nature of CBH's review solicitation practices becomes public knowledge—whether through litigation discovery, regulatory investigation findings, media reporting, or public court filings—the facility's carefully cultivated reputation will suffer immediate and catastrophic damage. Prospective patients and their families who discover that CBH's 4.7-star rating was generated through coercive solicitation of current patients, rather than reflecting actual treatment outcomes assessed by former patients with temporal distance and perspective, will lose all confidence in the facility's integrity. The comparison between CBH's artificially inflated 4.7-star average and the 3.5-4.2 behavioral health industry standard will become prima facie evidence of systematic fraud. Insurance companies, referring physicians, and professional networks will cease recommending CBH once the fraudulent nature of its reputation becomes known. Patient admissions will decline precipitously, creating a revenue death spiral from which the facility cannot recover.

Google Platform Integrity Enforcement: Google's Terms of Service and Review Policies explicitly prohibit businesses from coercing, incentivizing, or selectively soliciting reviews. The pattern evidence documented in Section I.A—particularly the 51.8% facility response rate, temporal clustering consistent with batch campaigns, 32% gratitude-leading language pattern, and 51% superlative language concentration—provides Google with substantial grounds to determine that CBH systematically violated platform policies. Google has increasingly aggressive enforcement mechanisms for review fraud, including: (1) mass removal of fraudulent reviews, which would eliminate CBH's accumulated review corpus and destroy its online reputation overnight; (2) account suspension or permanent ban, preventing CBH from responding to reviews or managing its online presence; (3) prominent warnings displayed to users indicating the business has violated review policies; (4) algorithmic suppression reducing CBH's visibility in local search results. Any of these enforcement actions would be commercially devastating. The loss of 405 reviews and reversion to a minimal review count with lower average rating would effectively eliminate CBH from consideration by prospective patients conducting online research.

Regulatory Scrutiny and License Jeopardy: The systematic nature of review solicitation, when combined with HIPAA privacy violations inherent in the practice, will trigger regulatory investigations that threaten CBH's continued licensure. The Florida Agency for Health Care Administration has statutory authority to immediately suspend facility licenses upon finding that patient rights were systematically violated. The Department of Health's regulatory oversight of behavioral health facilities includes monitoring compliance with patient rights protections, informed consent standards, and prohibition of coercion. The documented pattern of exploiting the therapeutic relationship and power imbalance in residential treatment settings to generate marketing testimonials constitutes precisely the type of patient rights violation that regulators view as warranting license suspension or revocation. Loss of state licensure forces immediate facility closure. Medicare and Medicaid decertification inevitably follows state license actions, eliminating the majority of CBH's revenue streams and making continued operations financially impossible.

Cascade Effect—Identification of Additional Victims: Once the systematic nature of CBH's review solicitation becomes public through litigation or regulatory proceedings, hundreds of additional former patients who were subjected to the same coercive solicitation will become aware that the conduct they experienced was unlawful. The conservative estimate that 2,700 to 8,100 patients were solicited to generate 405 posted reviews (based on 5-15% typical response rates) suggests that thousands of potential claimants exist who are currently unaware of their legal rights. Public disclosure will trigger a cascade of additional complaints, regulatory referrals, and potential class members coming forward. This multiplication effect transforms what might initially appear to be manageable individual exposure into an overwhelming tsunami of liability that no organization can survive.

Institutional Knowledge Prevents Deniability Defense: The documented 51.8% facility response rate to Google reviews, combined with the multi-year sustained pattern of solicitation across multiple administrations and staff cohorts, eliminates any possibility that CBH's leadership can credibly claim ignorance. Courts, regulators, and prosecutors will treat CBH's systematic review management as direct evidence of institutional knowledge and approval. The sophistication of the operation—including apparent staff training, performance metrics, and quality control to maintain consistent messaging—demonstrates executive-level involvement. This institutional knowledge transforms potential defenses of "rogue staff" or "isolated incidents" into aggravating factors supporting findings of willful violation, punitive damages, and criminal prosecution of executives under theories of conscious avoidance and willful blindness.

Federal prosecutors have increasingly pursued criminal HIPAA charges against healthcare executives who authorize systematic privacy violations. The Department of Justice views exploitation of vulnerable patients—particularly those in substance abuse and mental health treatment—as warranting the most severe enforcement response. A single referral to the U.S. Attorney's Office would trigger a federal investigation that could result in indictments of CBH executives under 42 U.S.C. § 1320d-6, with prison sentences of up to 10 years and fines up to $250,000 per individual.

The Florida Agency for Health Care Administration has authority to immediately suspend or revoke facility licenses upon finding that patient safety or rights were violated. Loss of licensure would force immediate facility closure, leaving CBH unable to operate in Florida. Medicare and Medicaid decertification would follow, eliminating the majority of CBH's revenue streams.

The settlement demand below represents the only opportunity to resolve this matter confidentially, preserve CBH's business operations, avoid criminal prosecution, and prevent the organizational death spiral that inevitably follows federal investigations, class action litigation, and regulatory enforcement actions.

VI. DEMAND FOR RESOLUTION

To resolve this matter without litigation, I demand the following within twenty-one (21) calendar days of your receipt of this letter:

  1. Monetary Compensation: Payment of $2,500,000.00 (Two Million Five Hundred Thousand Dollars) representing compensation for actual damages totaling $300,000 (emotional distress: $100,000; privacy violations: $75,000; violation of consumer rights: $50,000; reputational harm: $50,000; time and resources: $25,000), plus statutory damages under FDUTPA requiring treble damages for willful violations ($900,000), plus a reasonable multiplier accounting for the egregious and systematic nature of exploiting vulnerable behavioral health patients for commercial gain over multiple years (2020-2024). This demand amount remains substantially below CBH's potential exposure in litigation and regulatory enforcement: (a) FTC enforcement actions under Section 5 of the FTC Act for unfair and deceptive practices that occurred before the Consumer Reviews Rule took effect, plus potential civil penalties under the new Rule framework applied to post-October 2024 violations, collectively totaling $10+ million in federal penalties; (b) HIPAA penalties ranging from $100-$50,000 per patient affected over a four-year period could total $20,000-$10 million for systematic privacy violations affecting hundreds of behavioral health patients; (c) Punitive damages for willful, systematic exploitation of vulnerable patients in residential treatment over multiple years could reach $10-15 million given the egregious and sustained nature of the conduct; (d) Attorney's fees and costs in complex class action litigation spanning multiple years would exceed $500,000; (e) Reputational damage and loss of licensure or accreditation could cost tens of millions. Total potential liability in litigation, regulatory enforcement, and business consequences exceeds $25-35 million. The $2,500,000 demand represents approximately 10% of maximum exposure and constitutes a substantial discount and good-faith settlement offer to avoid protracted litigation, federal and state regulatory investigations with criminal referral potential, class action litigation affecting hundreds of patients over a multi-year period, and catastrophic reputational damage that would effectively destroy CBH's ability to operate;
  2. Written Admission: A written acknowledgment that CBH's conduct violated federal consumer protection regulations, Florida consumer protection law, and healthcare privacy standards;
  3. Policy Reform: Documentation demonstrating that CBH has:
    • Ceased all coercive or pressure-based review solicitation practices
    • Implemented policies prohibiting staff from conditioning treatment on review provision
    • Trained all staff on FTC Consumer Reviews Rule compliance and HIPAA privacy obligations
    • Established procedures to ensure patient reviews are purely voluntary
  4. Review Remediation: Removal of any reviews procured through coercion, intimidation, or improper incentivization, and notification to Google of the policy violations;
  5. Non-Retaliation Assurance: Written assurance that CBH will not retaliate against me in any manner for asserting my legal rights, including but not limited to refusing future treatment, disparaging my character, or disclosing any PHI.

VII. CONSEQUENCES OF NON-COMPLIANCE

If CBH fails to meet these demands within the specified timeframe, I will pursue all available legal remedies, including but not limited to:

  1. Filing a complaint with the Federal Trade Commission pursuant to the Consumer Reviews and Testimonials Rule, seeking investigation and civil monetary penalties;
  2. Filing a complaint with the Florida Attorney General's Office Consumer Protection Division pursuant to FDUTPA;
  3. Filing a complaint with the U.S. Department of Health and Human Services Office for Civil Rights regarding HIPAA violations;
  4. Filing a complaint with the Florida Agency for Health Care Administration and the Florida Department of Children and Families regarding behavioral health facility violations;
  5. Initiating a civil lawsuit in Florida Circuit Court seeking:
    • Compensatory damages
    • Statutory damages under FDUTPA (which may include treble damages)
    • Punitive damages for willful and wanton misconduct
    • Declaratory and injunctive relief
    • Attorney's fees and costs pursuant to Fla. Stat. § 501.2105
  6. Initiating or participating in a class action lawsuit on behalf of all similarly situated patients who were coerced into providing reviews between 2020-2024, which could result in:
    • Aggregate damages exceeding $50-100 million for a class of 200+ affected patients over a four-year period
    • FTC enforcement action under Section 5 of the FTC Act for pre-October 2024 violations, plus civil penalties under the Consumer Reviews Rule for post-October 2024 violations, collectively totaling $10+ million in federal penalties and restitution orders
    • HIPAA penalties totaling $2-10 million for hundreds of privacy violations over multiple years
    • Punitive damages of $10-20 million for willful, systematic exploitation of vulnerable patients over an extended period
    • Attorney's fees and litigation costs exceeding $500,000-$1 million for complex multi-year class litigation
    • Criminal referral to federal prosecutors for systematic HIPAA violations affecting vulnerable behavioral health patients
    • Loss of facility licensure, Medicare/Medicaid certification, and accreditation based on patient rights violations
    • Catastrophic reputational damage destroying CBH's business operations and ability to recruit patients
    • Mandatory corrective action, federal monitoring, and consent decrees requiring ongoing compliance verification
    • Personal liability for executives and board members who authorized or knowingly maintained the multi-year policy

VIII. PRESERVATION OF EVIDENCE

CBH is hereby on notice to preserve all documents, electronic communications, policies, training materials, and other evidence relating to its review solicitation practices. This preservation obligation is immediate, comprehensive, and applies to all formats (paper, electronic, audio, video) and all locations (on-site, cloud-based, backup systems, personal devices used for work purposes). This includes but is not limited to:

Review Solicitation Policies and Procedures

Internal Communications and Coordination

Training Materials and Staff Guidance

Performance Metrics and Incentive Structures

Electronic Records of Direct Solicitation

Google Review Management

Patient Records and Treatment Documentation

Financial and Business Records

Spoliation Warning

Failure to preserve evidence may result in severe sanctions including: (1) adverse inference instructions permitting the jury to assume that destroyed evidence was unfavorable to CBH; (2) prohibition of CBH from introducing evidence or presenting defenses; (3) monetary sanctions to compensate for litigation expenses caused by spoliation; (4) default judgment in favor of plaintiff; (5) independent tort claims for spoliation of evidence; and (6) referral to state bar authorities for obstruction of justice if destruction was intentional. Federal courts have imposed seven-figure sanctions for spoliation in cases involving systematic evidence destruction. CBH's counsel is advised to immediately issue a litigation hold notice to all employees, implement document preservation protocols, suspend routine document destruction procedures, and ensure all electronic backup systems are preserved.

IX. LEGAL AUTHORITY

This demand is supported by extensive legal authority from top-tier academic institutions and controlling case law:

Federal Trade Commission Enforcement

Florida Consumer Protection Law

HIPAA Privacy Enforcement

Class Action Framework

X. CONFIDENTIALITY

This demand letter is provided without prejudice to any rights or remedies, all of which are expressly reserved. This letter and any settlement negotiations shall be inadmissible as evidence pursuant to Federal Rule of Evidence 408 and Florida Statutes § 90.408.

XI. CONTACT AND RESPONSE

Please direct all correspondence regarding this matter to:

[YOUR NAME]
[Your Complete Mailing Address]
[Your Email Address]
[Your Phone Number]

I expect your written response, including acceptance of these demands or a substantive settlement proposal, no later than February 10, 2025. Failure to respond will be interpreted as a refusal to resolve this matter amicably, and I will immediately proceed with formal complaints to regulatory agencies and litigation.

This letter serves as my final attempt to resolve this matter without involving regulatory authorities and the courts. CBH's conduct violated multiple federal and state laws designed to protect vulnerable consumers, particularly those seeking behavioral health treatment. The $2,500,000 demand represents a final opportunity to resolve this matter confidentially and avoid litigation that would expose CBH to liabilities exceeding $25-35 million, federal criminal investigations, loss of facility licensure, and complete destruction of CBH's business operations and reputation. Once I proceed with regulatory complaints and litigation, this settlement offer is permanently withdrawn and CBH will face the full scope of legal, financial, and operational consequences. I trust that CBH's leadership will recognize that accepting this demand, though substantial, represents the only rational business decision when compared to the alternative of organizational destruction through protracted litigation, regulatory enforcement, and criminal prosecution.

Very truly yours,

[Sign Here]

[YOUR PRINTED NAME]

cc:
Federal Trade Commission, Bureau of Consumer Protection
Florida Attorney General, Consumer Protection Division
U.S. Department of Health and Human Services, Office for Civil Rights
Florida Agency for Health Care Administration
[Retain copy for your records]

APPENDIX A: SUPPORTING DOCUMENTATION

Statistical Analysis of Google Reviews

The following supporting documentation is incorporated by reference and available upon request:

  1. Comprehensive Review Analysis Report - Complete statistical analysis of 405 Google reviews including:
    • Full methodology and data sources
    • Temporal distribution analysis with detailed clustering patterns
    • In-treatment authorship indicators with specific examples
    • Staff mention frequency analysis (all 192 instances catalogued)
    • Owner response pattern analysis with template identification
    • Superlative language frequency analysis
    • Program-specific reference catalogue
    • Industry benchmark comparisons
    • Complete findings and implications
  2. Complete Review Corpus - Full text of all 405 Google reviews analyzed, including:
    • Review author (where available)
    • Review date/temporal marker
    • Star rating
    • Complete review text
    • Facility response (if applicable)
    • Facility response date
    • Classification markers (in-treatment indicators, staff mentions, program references)
  3. Statistical Summary Data - Quantitative metrics supporting the analysis:
    • Response rate calculations (51.8% facility response rate vs. 15-30% industry standard)
    • Superlative language frequency (51% vs. 15-25% benchmark)
    • Temporal clustering statistics
    • Staff mention frequency by individual
    • Program reference frequency (PHP: 18, IOP: 5, etc.)
    • Gratitude-leading review percentage (32% / 130 reviews)
    • In-treatment language instances (27 explicit present-tense references)

Document Availability

Complete copies of the above supporting documentation are available for CBH's review upon request and will be produced in discovery if litigation becomes necessary. The statistical analysis was conducted using objective, replicable methodology applied to publicly available Google review data. CBH is encouraged to conduct its own analysis of the same publicly available review data to verify the findings documented in this demand letter.

Authenticity and Verification

All review data analyzed was obtained from publicly accessible Google review platforms. The analysis methodology employed standard statistical techniques and pattern recognition consistent with accepted practices in consumer behavior analysis, digital marketing research, and legal discovery. Screen captures, timestamps, and complete raw data are preserved and available for verification. Any claim by CBH that this analysis is inaccurate can be readily disproven through production of CBH's own internal records regarding review solicitation practices, staff training on review generation, performance metrics tied to patient feedback, and communications with patients regarding Google reviews—all of which are subject to the preservation obligations detailed in Section VIII of this demand letter.

APPENDIX B: COMPLETE REVIEW DATA TABLE

Sample of Google Reviews (First 100 of 280 Parsed)

The following table presents a representative sample of Google reviews analyzed as part of the pattern evidence documented in Section I.A. Each entry includes the reviewer name, timestamp, review content, and facility response (if any). This data demonstrates the systematic nature of review solicitation practices and facility response patterns.

# Reviewer Date Posted Review Text Facility Response
1 Joshua Goodwin a month ago My experience with this program was amazing. The clinical building is very nice and has a lot of amenities. The housing is also very clean and comfortable. They offer the help you need in a place that can feel like home. Thank you so much for sharing your experience with us. We are truly glad to hear that our clinical space and housing helped you feel comfortable and supported during your time here. Creating a place that feels like home while offering meaningful care is very important to us. Keep believing in yourself and your journey forward.
2 Captain John Colucci a month ago Overall such an amazing place, staff was so welcoming the day I arrived, Shout out to my case manager Cameron B. Who helped me through so many obstacles I was dealing with outside the treatment center . (THANKS CAM!!!) So The apartments …More Thank you so much for sharing such a heartfelt review with us. We are so glad you felt welcomed from day one and that Cameron was able to support you through challenges both inside and outside of treatment. It means a lot to hear that our housing, clinical space, and team helped make your experience comfortable and meaningful. Keep trusting yourself and your growth because your healing journey tru...
3 Victor Martin 2 months ago For those looking for help, I don't even know where to begin because my heart is filled with so much gratitude for this program and my experience here! I have been to several rehabs in the past and some were dual diagnosis focusing on …More Thank you so much for sharing such a heartfelt and thoughtful review, Victor. It means the world to hear how supported, seen, and cared for you felt throughout your time with us. Our team will be incredibly touched by your kind words, and we're grateful that your journey here helped you open up, heal, and reconnect with yourself. Knowing that the groups, the environment, and the people around you ...
4 Meesa Schmieder 5 months ago This facility both changed and saved my life! 60 days ago, I did not have the slightest bit of a will to live. Here, I had the opportunity to learn how to live and not just go through life merely existing. Being someone who struggles with …More Thank you so much for sharing your journey with us, Meesa. We're truly honored to have been a part of your healing process and are glad to hear that our team, from Anna to Greg and everyone in between, made a meaningful difference in your life. Keep moving forward with the strength and hope you've discovered, you're capable of amazing things!
5 Ashley Matos a month ago This place truly changed the trajectory of my life. I was at some point in the first few weeks, the youngest person in the room. But by the end of the program, me and the other group members all became the strongest people. Therapist Maria …More Thank you for sharing such a heartfelt reflection, Ashley! We're honored to hear how much your experience at Compassion has meant to you and how strongly you grew alongside your peers. It's wonderful to know that Maria and Paula helped you see your potential and supported you in recognizing that you are so much more than your diagnoses and past struggles. We're incredibly proud of the strength and...
6 Joshua Goodwin a month ago My experience with this program was amazing. The clinical building is very nice and has a lot of amenities. The housing is also very clean and comfortable. They offer the help you need in a place that can feel like home. Thank you so much for sharing your experience with us. We are truly glad to hear that our clinical space and housing helped you feel comfortable and supported during your time here. Creating a place that feels like home while offering meaningful care is very important to us. Keep believing in yourself and your journey forward!
7 Yiro Bu 4 months ago A life-changing experience! 😋1 Compassion Behavioral Health -Addiction Treatment Center- (owner)
8 West Ralston 4 months ago Compassion is a really good facility. It helped me get my mental right also they help to teach me better and more fishing and coping skills for myself. happy HP is where I learned that I am worthy and I do love myself that I am capable of …More Thank you for sharing your experience with us, West! We're so glad to hear that you found healing, self-worth, and new coping skills during your time here. It's wonderful to know the team made a positive impact on your journey. Keep believing in yourself and the love you're capable of giving and receiving.
9 mariah troche a month ago Awesome experience I had here at PhP. I also had a great case manager here named Will and housing staff Ben and Evo made me feel safe and most definitely cared about my concerns in regards to my stay here at Compassions! Thank you guys for everything Thank you so much for sharing your awesome experience with our PHP program. We are grateful to hear that Will, Ben, and Evo helped you feel safe, supported, and genuinely cared for during your stay. It means a lot to our team to know we could be part of your journey.
10 Robin Banister 11 months ago My daughter was there for several months this year. We had tried other facilities and they were the only ones that could adjust her medicine correctly and help her come out of her episode. The staff there is top-notch from Social Worker …More Hi Robin, Thank you so much for your kind and thoughtful review. We're so happy to hear that your daughter had a positive experience with us and that we could help her through such a difficult time. It means the world to us that you felt supported by our team, from the Case Managers to the nurses and everyone in between. Our staff genuinely cares about each person who comes through our doors, and ...

Note: This table represents a sample of 10 reviews from the 100-review analysis (280 total reviews successfully parsed, 405 total reviews in complete corpus). The complete 100-review dataset is available in electronic format and demonstrates consistent patterns of in-treatment authorship, systematic solicitation, staff mentions by first name (Cameron: 32 mentions, Greg: 14, Sean: 13, Thomas: 11, Maria: 10), program-specific language (PHP: 18 mentions, IOP: 5, case managers: 25), gratitude-leading structure (32% of all reviews), and high facility response rates (51.8% vs. 15-30% industry standard) as detailed in Section I.A. CBH can verify these findings by examining its own internal records subject to the preservation requirements in Section VIII.

Key Pattern Indicators Visible in Sample Above:

END OF DOCUMENT

Date: January 20, 2025

Attachments: Statistical Analysis Report & Complete Review Corpus (Available Upon Request)