Note

Appendix 2: 90% of TopOffers is Polyakov-Linked

Source of Data

The following data are sourced from the “CPA (Cost Per Acquisition) Offers” page found at TopOffers.com as it appeared on Sep. 25, 2019:

https://topoffers.com/cpa-offers/ (archive)

As of that date, TopOffers listed affiliate deals with 218 dating websites. We present all 218 of those websites in this spreadsheet: 

Dating Websites Listed on TopOffers.com (Raw, Unsorted)

The Tortola Companies (72% of Top Offers)

158 of 218 (72%) websites have the same British Virgin Islands (BVI) P.O. Box as their legal contact found on each dating website’s terms of service page:

P.O. Box 146, Trident Chambers, VG1110, Road Town, Tortola, British Virgin Islands 

Those websites can be found in this spreadsheet:

TopOffers.com Dating Websites Registered to the Tortola Address

The BVI address is also associated with the BVI Trident Trust branch, a financial services firm that, in part, provides legal services to shell companies. Forty dating websites with that address are not held by any named shell company. Each of the others is owned or operated by one of six shell companies also registered to that same address: 

  • Bulova Invest Ltd
  • Together Networks Holdings Limited
  • Nelfor Services Limited
  • Timespace Holdings Limited
  • Kingsrock Holdings Ltd
  • Northlock Holdings Ltd

By design, shell companies obscure ownership and other financial or legal details, making it challenging to determine, conclusively, who benefits from each company, or to discern how many shareholders are invested. That being said, court documents provide some clues.

In a March 16, 2016, court filing, Max Polyakov is named as “founder and director” of Bulova Invest Ltd:

Zoobuh, Inc. v. Alcuda, Ltd. (Case No. 2:14cv228 DN BCW)

Several of the remaining companies are associated with the breakup of a former online dating empire co-run by Polyakov and a Scottish businessman named Bill Dobbie. In 2013-2014, their joint partnership ended when the dating websites were sold to a company — Grendall Investments Limited — which is or was once owned by Polyakov, according to December 2014 reporting in The Scotsman (archive):

Together Networks already operates dating websites including Be Naughty, Cheeky Lovers and Flirt, which were sold last year to Polyakov’s Grendall investment firm in a deal worth £45.1m. However, Cupid said yesterday that a deferred £20m payment from this sale has been reduced to £12.5m. This will be paid by the middle of December next year, rather than November 2016 as originally planned.

March 2017 court documents filed with the The Eastern Caribbean Supreme Court provide details about Grendell Investments and its relationship to other companies that control or own Together Networks.

Gilfanov v Polakov (Interlocutory Appeal Under ECSC CPR 62.10)

According to these documents, Grendall Investments “owns substantial interests in the Together Networks business.” The filings also imply multiple corporate entities behind Together Networks, and that these are ultimately owned by a BVI-registered company named Phoenix Holdings Ltd.  At least in 2013-2014, Polyakov, his father Valeriy Polyakov, and “Mr. James Watt” held for-profit shares in Phoenix Holdings: 

In or about July 2013, [Max] Polyakov became involved in other businesses involving  casual  dating which he grouped under the name “Together Networks”. The Together Networks business was owned by the 3rd respondent, Phoenix Holdings  Ltd., a British Virgin Islands company … The  capital  of  Phoenix  was  owned by  the 2nd respondent,  Valeriy Polyakov, the father of Dr. Polyakov. […]

In September 2014, the appellants received a certificate of incumbency from the Company showing that apart from the 1,000,000 common shares there were also 481,000 issued profit interest shares divided between Dr. Polyakov and a Mr. James Watt.

Based on these facts and the shared Tortola P.O box, we have concluded that Max Polyakov likely holds a substantial financial interest in Together Networks Holdings Limited.

Meanwhile, Nelfor Services Limited, in addition to being the registered agent for several dating sites, is a company listed as the developer for several of these dating website’s mobile applications. It developed FlirtyDesires (part of Together Networks) and GetAnAffair (a Bulova Invest Ltd. site), both of which we have tied to Max Polyakov via the above records.

Timespace Holdings Limited, although it currently serves as the legal agent for several active dating websites, was actually the corporate entity that held EasyDate — the first dating website Polyakov and Dobbie created.

Kingsrock Holdings Ltd, based on data contained in the International Consortium of Investigative Journalists Offshore Leaks Database, shares the same Tortola, BVI, P.O. box with several dating-related companies mentioned above. According to this same database, Kingsrock Holdings Ltd is a shareholder in a company named Kingsrock Malta Limited, which shares the address with other Malta-based dating companies including Timespace Services Limited, whose website is one of only two hosted on the same server as Timespace Holdings Limited mentioned above.

Northlock Holdings Ltd is the registered company listed at several TopOffer domains, but some of those websites share the same IP address as dating-website companies previously tied to Polyakov. For example, the Northlock Holdings website becoquin.com is hosted at the same IP address as Iwantblacks.com, which is registered to Polyakov’s Together Networks Holdings Limited.

At least 24 (out of 40) domains registered to the Tortola address have no holding company listed. But these have been or are currently registered to a server belonging to Together Networks or held by a company described above as already having been linked to Polyakov:

Affairdating, DelightSexy, DammiSesso, AffairDating, BlackWink, GibMirSex, MaturesForFuck, Naughtysporty, NoiteDeSexo, QuieroRollo, SexeFemMemure, SexigDate, sexinfidele, SexLugar, SexyBlackPeople, SnuskFlirt, SoloAvventure, TreffeGirls, TuhmaMeille, MomsGetNaughty, Bestsexmatch, NastyHookUps, MeetMeSexy, and SportyHottie.

Given that the remaining dating websites without holding companies are largely identical from a layout and user experience perspective, and share a P.O Box with several holding companies dedicated to online dating websites that we have already tied to Polyakov, it strains credulity to imagine that these remaining 16 Tortola registered dating websites are unrelated to Polyakov.

The Malta Companies (14% of TopOffers)

Some 30 domains (14%) are registered to three Malta shell companies. Each mailing address appears to be unique:

  • Norfex Services Ltd: Floor 5, 115A, Msida Valley Road, Birkirkara, BKR 9024, Malta
  • Timespace Services Limited: Vincenti Buildings, 28/19, Suite 1485, Strait Street, Valletta VLT 1432, Malta
  • Together Networks Holdings: 19 Giovanni Curmi Str., Lija LJA 1071, Malta

Those websites can be found in this spreadsheet:

TopOffers.com Dating Websites Registered to Malta Addresses

Norfex Services Ltd., in addition to being the registered address for several dating sites,  appears to provide both the charging platform and the place for people to contest charges. Some of these websites were registered with the email address norfexltd@gmail.com, which has also been used to register numerous other dating websites, as well. In many cases, these other dating websites belong to companies already linked to Polyakov. As an example, the previously discussed company Timespace Holdings Limited maintains the site “Blistyggnu.com,” but this website was originally registered using the Norfex Services Ltd email address.

Timespace Services Limited has a website that is one of only two hosted on the same server as Timespace Holdings Limited, which we linked to Polyakov in our section on Tortola companies above.

Per the previously discussed British Virgin Island case, Polyakov owned dating websites “grouped under the name ‘Together Networks.'” We therefore infer that previously discussed BVI-registered Together Networks Holdings Limited and the Malta-registered Together Networks Holdings (and also a Delaware-registered, California-based company once named Together Networks USA) are part of “Together Networks” ultimately owned by the Polyakov-tied, BVI-registered company Phoenix Holdings Ltd.

Seven U.K.-Registered Dating Sites (3% of TopOffers)

Seven TopOffer domains are registered to one company in London:

  • NSI (Holdings) Ltd.: 2, Angel Square, London, EC1V 1NY, England, United Kingdom.

Those websites can be found in this spreadsheet:

TopOffers.com Dating Websites Registered in London

NSI (Holdings) Ltd., based on filings made by Polyakov and Dobbie’s company Cupid plc, represents a portion of “traditional assets” not sold off in 2013, when Cupid originally sought to remove itself from the “casual” dating market. In 2014, when Cupid decided to leave the dating business entirely, those assets were sold off as well, to the previously discussed Polyakov properties housed under Together Networks Limited. This notice makes explicit that that sale included NSI (Holdings) Ltd.:

The Company has entered into conditional agreements to sell or procure the sale of the Traditional Dating Assets to (a) Tradax IP Licensing Limited, a company registered in the British Virgin Islands, in respect of domain names and trade marks of the Group (including the Uniform Dating assets held by NSI); (b) Together Networks Limited, a company incorporated in Malta, in respect of all other assets and the shares in NSI; and (c) Together Networks Holdings Limited, a company incorporated in the British Virgin Islands, in respect of the Ukrainian Subsidiaries for a total consideration of £3 million.

Additional ties exist as well. NSI (Holdings) Ltd.’s corporate website is hosted on the same server as several other dating websites and/or corporate websites for shell companies previously linked to Polyakov, including Northlock Holdings  Ltd, Together Networks, and the Timespace Services Limited-run website myforeigngirlfriend.com. More current Polyakov-connections can be found in the court case Guzman v. NSI (Holdings) Ltd. Laura Edison has responded on behalf of that company in her capacity as director of NSI (Holdings) Ltd. She is also an employee of Polyakov via Noospheres and several other ventures, and has worked with Polyakov in a legal capacity since Cupid Plc.

As a final tie, according to British Company records, a Ukrainian man named “Sergii Spodin” owns over 75% of NSI (Holdings) Ltd.’s voting rights. Spodin’s name, with a slightly different spelling, appears in the Phoenix Holdings lawsuit filed in BVI court as well. There he is apparently described as an associate of Polyakov’s father, Valeriy Polyakov, who apparently sold his shares to Spodin in an effort to allegedly “frustrate attempts” by other associates to execute on the shares: 

The appellants claim that they were induced by representations made to them by [Max] Polakov to sign a Share Transfer Agreement for purchasing shares in Phoenix. The representations were incorporated into the Share Transfer Agreement. The appellants allege that the representations were made fraudulently and claimed rescission of the Share Transfer Agreement and payment of $12 million.

Shortly after filing the claim, the appellants discovered that [Max] Polyakov’s father, Mr. Valeriy Polyakov, had transferred his shares in Phoenix to a Mr. Sergei Spodin for no consideration. … Bannister J heard the discharge application. He found that the gift of the shares to Mr. Spodin was done to frustrate any attempts by the appellants to execute on the shares … Bannister J also found that the appellants had a good arguable case in fraud but he discharged the injunction because he found, inter alia, that there was no reliable evidence of the value of the appellants’ shares and that the appellants had no prospects of recovering $12 million or any amount remotely approaching that sum.

Because U.K. law differs from that of the jurisdictions in which most of the other Polyakov companies reside, we know that Spodin currently controls voting rights as of the time of this reporting.

The Leftovers (10% of TopOffers)

Twenty-three domains listed on TopOffers.com are registered to companies other than the ones mentioned above. Unlike the previous sites, these often look different in layout and appear to be the work of companies unassociated with any Polyakov venture.

Those sites can be found in this database:

TopOffers.com Dating Websites Apparently Unrelated to Polyakov

The Final Tally (90% of TopOffers Linked to Polyakov)

Adding together all the dating websites owned or operated by the companies we tied to Polyakov above results in a tally of 194 sites out of the 218 listed on TopOffers.com (88.9%). The full list of dating websites we tie to Polyakov can be found in this database:

TopOffers.com Websites Snopes Links to Max Polyakov