While some might think that starting a blog is an arduous effort, when you understand the precise steps you need to take, it becomes far easier. It all starts in the decision of choosing a profitable niche and picking the right domain name. From there, you need to build your offers. You can easily sell things like mini-email courses, trainings and ebooks.
If you have a good idea for an app, and the skills to create it, then producing your own premium app can be profitable. However, with so many free apps available, it may be hard to convince people to pay. If you want to go down the premium app route, consider having a basic free version to encourage people to download the app in the first place. You can then provide the option of upgrading to a premium plan once users realize how useful the app is.
Recent corporate changes and folding 2Checkout into a larger company that is involved in payment processing and e-commerce means that the affiliate program can sometimes feel somewhat neglected. But the ability to generate custom coupon codes and the comprehensive knowledge base make 2Checkout a good option for experienced affiliates with an established user base. But if you’re just entering the affiliate field for the first time, 2Checkout might not be where you want to start.
28. Subscription – If you think of something valuable (newsletter, online magazine, etc.) that you can consistently offer on a certain basis (weekly, monthly, etc.), you may want to offer a subscription service. This could be a fee charged each time your product is sent out or on a monthly basis. Either way, this has to be something that your customers can only get by subscribing to your website.

I have been with WA 2 years this month and I wouldn’t look back, the knowledge and financial freedom I have gained is a credit to the platform set up by WA. Some people say how $49 is too much a month however when you consider what’s included like hosting, training, great community, tools and more I would argue that they set the price to low as there is alot of value.
Tradedoubler was founded in 1999 by two young Swedish entrepreneurs. They have offices in the UK and multiple countries throughout Europe, including Sweden, Germany, France, Poland and Spain. Their focus has always been to provide smarter results for both clients and affiliates through technology. In 18 years, they’ve amassed an army of 180,000 active publishers, connecting them to over 2,000 merchants in Europe and the UK. Many of these merchants are household names.
The terms of an affiliate marketing program are set by the company wanting to advertise. Early on, companies were largely paying cost per click (traffic) or cost per mile (impressions) on banner advertisements. As the technology evolved, the focus turned to commissions on actual sales or qualified leads. The early affiliate marketing programs were vulnerable to fraud because clicks could be generated by software, as could impressions.
For example, when I first started back in 2009, I learned from a service called Solo Build It. I knew absolutely nothing about building an online business, let alone what “affiliate marketing” even meant. However, they changed my life and taught me how to build money-making websites online, which is what I’ve been doing with my life ever since. This is another great service to consider and you can read my review of Solo Build It here.
The concept of affiliate marketing on the Internet was conceived of, put into practice and patented by William J. Tobin, the founder of PC Flowers & Gifts. Launched on the Prodigy Network in 1989, PC Flowers & Gifts remained on the service until 1996. By 1993, PC Flowers & Gifts generated sales in excess of $6 million per year on the Prodigy service. In 1998, PC Flowers and Gifts developed the business model of paying a commission on sales to the Prodigy Network.[8][9]

Hi Jamie! Thank you for the great information. I just learned about affiliate marketing last week. The source however, is an older couple who work for World Wide Dreams Builders (WWDB). So, basically Amway. After researching a bit. I have no interest in WWDB and. (It sounds like years of recruiting people with minimal payout) Though, I am highly intrigued by e-commerce and affiliate marketing. Before your post the company I recognized was Amazon. Can you please tell me if that will be the best 1st step. I am currently an unemployed student Veteran. So plan to fully emerge into this business regime and would greatly appreciate your advice on this!!!
Commercial use requires 'releases' - editorial use doesn't. Stock photos can be sold for commercial (eg, marketing) or editorial (ie, journalistic) use. You'll have more opportunities to make cash if your photos are available for both, but photos containing people or property (including branding and logos) need signed releases to be sold commercially.
Refinish old furniture from thrift stores, yard sales, or online ads. Sand down the furniture to smooth out the surfaces and buff off some of the old paint or stain. If you want to restain it, use a lacquer or paint thinner to remove the stain. Then, re-stain the piece. If you plan to repaint it, apply a primer and let it dry. Next, apply at least 2 coats of paint, letting each coat dry for at least 24 hours. If necessary, add new hardware to finish the piece.[13]
Tools & Resources: I’ve written a pretty comprehensive guide on the best web design software that covers both free and premium software packages. If you’re serious about becoming a web designer, then I recommend purchasing the full Adobe Creative Cloud Suite. At $49.99 per month, this is probably a bargain considering what you can achieve with this set of tools.
Wealthy Affiliate is different than anything out there, and you will understand that as soon as you step foot into the community. We always recommend you get started on the free Starter membership, that way any insecurity or apprehension about this industry is removed. Then you can make your own educated decision as to how WA fits into your life/business.
When you lack the luxury of time, making money on or offline can seem like an impossible task. How are you supposed to do that when you're working at a life-sucking nine-to-five job? While the stability of full-time employment might allow most to sleep well at night, it doesn't empower your creative juices to search for new income-producing strategies.

Rake yards in autumn if you live where leaves fall. Grab a rake and a few large trash bags and go from house to house offering your services. Ask your neighbors what areas of their lawn they want raked and where you should put the leaves, like on the curb for collection or dumped in a wooded area behind their house. Rake leaves into a large pile, then stuff them into a trash bag and tie it closed.
For me I would choose a program with Recurring commission. You can build a real passive income. Its the best way to go! One suggestion is contact companies who sell services and ask if you can sell their service for them. Sometimes popular affiliate programs like these have just way too many people trying to sell their service. I personally went to sitecare.ca and asked them if I could sell their service and I couldn’t be happier! So find a service you believe in and go for it!
Français: se faire de l'argent en ligne, Italiano: Guadagnare Online, Español: ganar dinero en Internet, Português: Ganhar Dinheiro Online, Deutsch: Online Geld verdienen, Русский: заработать в интернете, 中文: 在网上赚钱, Bahasa Indonesia: Menghasilkan Uang Secara Online, Čeština: Jak vydělávat peníze online, Nederlands: Online geld verdienen, العربية: كسب المال بواسطة العمل عبر الإنترنت, Tiếng Việt: Kiếm tiền Trực tuyến, हिन्दी: ऑनलाइन पैसे कमाएँ, 한국어: 온라인으로 돈 버는 법, ไทย: หาเงินออนไลน์, Türkçe: İnternet'ten Nasıl Para Kazanılır, 日本語: オンライン上でお金を稼ぐ
There are numerous printing companies that will print your designs onto not just T-shirts, but also hoodies, hats, posters, cushions, bags, and phone cases, to name a few items. These businesses also offer fulfillment services. This means that you promote the merchandise on your own site and once you sell a product the printing company will not only print your design but also send the item directly to the buyer. So all you have to do is concentrate on the marketing and selling of your products, and the fulfillment company will take care of the rest.

Since the emergence of affiliate marketing, there has been little control over affiliate activity. Unscrupulous affiliates have used spam, false advertising, forced clicks (to get tracking cookies set on users' computers), adware, and other methods to drive traffic to their sponsors. Although many affiliate programs have terms of service that contain rules against spam, this marketing method has historically proven to attract abuse from spammers.


Yes! Wealthy Affiliate is most certainly an evolving affiliate marketing platform and even if you were away for a few months, you would likely notice a vast number of improvements. This is why it is the most trusted and recommended program in the industry for both aspiring and successful affiliate marketers, because they actually evolve and innovate frequently.
The Market Health Affiliate Program allows you to market and promote the world’s leading health and beauty offers online. We offer the highest paying affiliate program and best tracking software in our industry. If you have a web site and are interested in making money off the explosive sales in the health and beauty industry, then MarketHealth.com is perfect for you. Offers include products in the health, beauty, supplement, weight loss, and skin care industries.
Working as a freelancer is a great way to make money online from the comfort of your own home. The beauty of freelancing is that you can tailor it to suit your needs. You can freelance for a couple of hours a week in the evenings to help save up for a holiday or some much-needed home improvements. Or carve out a full-time job for yourself, giving you a more satisfying work-life balance and enabling you to do the simpler things in life like taking the kids to school. With so many jobs available online, freelancing is becoming more and more popular.
Become a freelancer in an area where you have expertise. If you have a skill that’s in demand, you can sell your services directly to clients who need them. Advertise your services on a personal website and look for freelancing jobs on sites like Upwork, Freelancer, and Fivrr. Additionally, hand out business cards and encourage happy clients to tell others about your work. Here are some ways you can earn money as a freelancer:[15]

The question is how much can you make within the Intenret business world. The answer is, as much as you want. Wealthy Affiliate is less of an “opportunity” and more of an all-inclusive environment where you can create and grow a business online…and do so to any level. Everything is included that you need to create your business, and managed it. Really the only missing piece is you and a bit of hard work and dedication.
…But doesn’t being an affiliate for Wealthy Affiliate make me just another one of those affiliate marketers who is being biased and just trying to make a buck off of you? Well, ummmm…. Sort of! But at least I’m honest about it, right? I hope you give me a chance by continuing to read this Wealthy Affiliate review. I have no intention of making this one big sales pitch. I just want to provide you with the information and allow you to make your own decision. If I get a commission, great! If not, that’s ok too. Here’s a screenshot of my Wealthy Affiliate profile.
For example, when I first started back in 2009, I learned from a service called Solo Build It. I knew absolutely nothing about building an online business, let alone what “affiliate marketing” even meant. However, they changed my life and taught me how to build money-making websites online, which is what I’ve been doing with my life ever since. This is another great service to consider and you can read my review of Solo Build It here.
Français: se faire de l'argent en ligne, Italiano: Guadagnare Online, Español: ganar dinero en Internet, Português: Ganhar Dinheiro Online, Deutsch: Online Geld verdienen, Русский: заработать в интернете, 中文: 在网上赚钱, Bahasa Indonesia: Menghasilkan Uang Secara Online, Čeština: Jak vydělávat peníze online, Nederlands: Online geld verdienen, العربية: كسب المال بواسطة العمل عبر الإنترنت, Tiếng Việt: Kiếm tiền Trực tuyến, हिन्दी: ऑनलाइन पैसे कमाएँ, 한국어: 온라인으로 돈 버는 법, ไทย: หาเงินออนไลน์, Türkçe: İnternet'ten Nasıl Para Kazanılır, 日本語: オンライン上でお金を稼ぐ
I finally decide to go premium with WA earlier this year and even though I’ve just now chosen a niche, I can officially say that through all of the ups and downs, everyone in the community has been super supportive and so encouraging. Another thing I love about WA is that no matter where I am in my blogging journey, I can always count on an answer from the community or I can always go back and refresh my memory with the training that’s provided. I’m looking forward to seeing how far I can go and I love that I have so much time to work on my site now, since I’ve cut my hours at work and already purchased the yearly membership.
Always disclose your affiliate relationship. Most visitors will probably understand that graphic ad will lead to your getting paid, but if you write a review or use an in-text link as a recommendation, you want your readers to know that may lead to compensation as well. This ensures you retain transparency and trust with your readers, but also, it's required by the FTC's endorsement rules.
Given that I am still in reading and preparation phase, I am mainly interested to overlap my niche with real life interests so I could have motivation to produce content on regular basis. Two that I am highly interested are PC parts and Fitness. I am aware they are too general subjects with lot of sites doing the same, but my idea is to produce constant review on PC parts, Laptops, Mobile devices, Accessories all in different categories, create lists like top5 or 10 under XX budget etc. Similar approach I would use if I I decide to go with Fitness path and divide content training advice, review of fat loss methods, supplementation, nutrition etc. I am aware that this will be a long journey and that it can pass few months before sales start to kick in and that’s the risk I am ready to take. My questions are:
Take care of your neighbors’ gardens in the spring if they have them. Volunteer to weed the garden, plant flowers, water the plants, or mulch the garden. People begin tending to their gardens as early as March so start advertising your services at the end of February or the beginning of March. It’s a great way to get outside and learn how to garden.
Consider selling in lots. A lot is a collection of similar items that is sold in a group. For example, if you have a collection of books, magazines or similar pieces of jewelry, consider selling them all at once in a lot. You many not make as much money as you would have if you sold each item separately. However, the items will likely sell more quickly in a lot than they would individually.[29]
Multi-vendor marketplaces, like ThemeForest, can be very successful. Chose a niche and create a vendor website for it. Your marketplace could be anything, from a platform for local artists to sell their work on, to an online digital product store. Once set up, invite people in that industry to sell their products on your site. You take a percentage of their profits when items sell.

Best Forex Partners (BFP) was established in 2011 by a group of international financiers and global online marketing professionals who saw a need to change the nature of affiliate marketing for the better.  In a few short years they combined their over 60 years of combined financial and marketing experience to create a new way to affiliate market and have never looked back!
SkimLinks is probably best for bloggers who want to write content around the affiliate link rather than add affiliate links to existing products. SkimLinks offers a lot of tools to compare commission rates and offers in order to customize your content to optimize your income. Once nice aspect of SkimLinks is that it offers lots of products for non-US creators, including popular UK brands like John Lewis and Tesco.
Drop shipping is another great ‘hands-off’ way to sell products. Firstly you will need to find businesses that sell products in your niche that offer a drop shipping service. Then you will need to create a website promoting and selling the products. When you make a sale, you take the payment on your site and then the manufacturer ships the goods to the buyer. The profit comes from charging a higher rate than the manufacturer, and if you are selling a high number of products this can quickly add up to a healthy revenue.

Best Forex Partners (BFP) was established in 2011 by a group of international financiers and global online marketing professionals who saw a need to change the nature of affiliate marketing for the better.  In a few short years they combined their over 60 years of combined financial and marketing experience to create a new way to affiliate market and have never looked back!


Websites like Care.com connect parents with babysitters. The company does all the background checking and other due diligence to put parents' minds at ease. Of course, you can appeal directly to people in your personal network, but if you're looking to generate recurring revenue sign up with a site marketing to parents looking for child care services.
Wealthy Affiliate has existed since 2005, so they’ve been around for a long time. However, they have never once increased their price, even though every year they add new features. Wealthy Affiliate has never been as helpful or advanced as it is today, and the “help and be helped” community has never been bigger. If you’ve been putting off joining Wealthy Affiliate, now is the absolute best time to join the community. 

It is important to note, however, that StudioPress is now a subsidiary of WPEngine which is the company that actually does the web hosting on which StudioPress’s Genesis framework runs. The affiliate program only works with choosing the StudioPress framework and themes, not the actual hosting on WPEngine. WPEngine has a separate affiliate program for its hosting services, which yes, is a bit confusing.
Selling digital products can be just as successful as selling physical products. Graphics, software, eBooks, design elements, sound effects, songs, and videos are just a few types of digital products that are in popular demand. So if you can turn your hand to creating digital products, let’s have a look at how you can make money online from this skill…
If you have graphic design skills then you could make money online by creating and selling your own design elements, like templates, fonts, graphics, and other assets. This is a great way to earn extra money and build up a portfolio of work, which could lead to you picking up freelance graphic design jobs. Websites like Envato Elements pay you a fee per element sold, which can become quite profitable if your work is popular.
For example, when I first started back in 2009, I learned from a service called Solo Build It. I knew absolutely nothing about building an online business, let alone what “affiliate marketing” even meant. However, they changed my life and taught me how to build money-making websites online, which is what I’ve been doing with my life ever since. This is another great service to consider and you can read my review of Solo Build It here.
Hunt for under-priced used books that you can sell online. Download an app that reads ISBN numbers so you can scan the barcodes on books. This will pull up the book’s current price on Amazon so you can see if it’s worth trying to resell it. Then, visit used book stores, thrift stores, and garage sales to look for high value books. Post the books for sale online using sites like Amazon or Ebay.[9]
The biggest reason I love recommending Wealthy Affiliate to new affiliate marketers is because it literally provides EVERYTHING you will ever need. You don’t need to buy a domain name in one place then get hosting in another place while you sign up for training at yet another place. Everything you need is in one spot, for one consistent monthly cost. Plus, they don’t just provide the tools, but they give step-by-step training instructions on how to use all the tools properly. If you still don’t understand something, just ask the community or go into live chat, and you could get an answer in literally seconds.
Yes, if you log back into your account and you weren’t a premium member in the past, you should see the $19 offer there. If you forget your password, there is a password reset on the login page. And of course, Wealthy Affiliate gives you the flexibility and full control of your Premium membership. You can move to the yearly membership (and save on the overall membership fees) at any time.
When I say that I love Wealthy Affiliate, I’m not just saying that because I’m an affiliate for them. I’m a very active premium member at Wealthy Affiliate and love interacting with people on a daily basis. If you join, you’ll see me posting on people’s profiles, answering questions, chatting in the live chat area, and I have private personal messaging conversations multiple times per day.
JVZoo lets you both host and create landing pages on their own website, so it’s far better suited for professional marketers who want to flood the internet with offers, many of them for courses to make money. You don’t need your own website to participate in JVZoo, but you will need to know how to drive traffic to a landing or squeeze page in order to profit from being a JVZoo affiliate.
What are the best ways to make money right away? While a search online when you're in need of some fast cash will produce millions of results, not all will be legitimate. It's up to you to filter through the so-called noise. These 32 strategies will help put you in the black, even if it's in a very small way. Once you are, resume planning and focusing on the bigger picture. 
Again, if your blog has a large reader base, then businesses may be interested in paying you to review their services or products. Not only will you get a free trial using whatever these businesses are selling, but you will also get a fee for writing them a review and posting it to your site. Paid reviews (and other paid and sponsored content) can be big money, so advertise this service on your contact page to generate business.
The concept of affiliate marketing on the Internet was conceived of, put into practice and patented by William J. Tobin, the founder of PC Flowers & Gifts. Launched on the Prodigy Network in 1989, PC Flowers & Gifts remained on the service until 1996. By 1993, PC Flowers & Gifts generated sales in excess of $6 million per year on the Prodigy service. In 1998, PC Flowers and Gifts developed the business model of paying a commission on sales to the Prodigy Network.[8][9]

Colmex Pro is the leading European Regulated CFD Broker. Offering Tier 2 CFD’s, as well as Live Equities, Indices, Commodities, Futures, and Forex, Colmex Pro offers nearly every investment vehicle available on the US Stock Market to international day traders. Coupled with their partner’s educational packages and trade room access Colmex Pro offers investors the best opportunity to grow and learn how to day trade successfully. CPA up to $1000
I would personally agree with linkshare.com as a great affiliate marketing platform to join as a publisher. Here’s why. Back in 2005 when I knew nothing about affiliate marketing and was using blogger.com as a free blogging platform without any experience whatsoever and joining Walmart.com as my first official affiliate program, I was able to insert Walmart affiliate in its in my blogger blog and earn a $72 commission. I was onto affiliate marketing for life from there.
Always disclose your affiliate relationship. Most visitors will probably understand that graphic ad will lead to your getting paid, but if you write a review or use an in-text link as a recommendation, you want your readers to know that may lead to compensation as well. This ensures you retain transparency and trust with your readers, but also, it's required by the FTC's endorsement rules.
I finally decide to go premium with WA earlier this year and even though I’ve just now chosen a niche, I can officially say that through all of the ups and downs, everyone in the community has been super supportive and so encouraging. Another thing I love about WA is that no matter where I am in my blogging journey, I can always count on an answer from the community or I can always go back and refresh my memory with the training that’s provided. I’m looking forward to seeing how far I can go and I love that I have so much time to work on my site now, since I’ve cut my hours at work and already purchased the yearly membership.
Warrior Forum WSO’s – This is the only option on the list I will actually tell you to stay away from. Warrior Forum WSO’s are almost always a rip-off and no amount of them will adequately teach you how to truly build a real online business. This forum community is owned by Freelancer.com and they will allow just about anyone to sell just about anything. The majority of them are very cheap, but once you give them your email address, get ready to be spammed. They also almost always include “upsells” where the initial product may only cost a few bucks, but all the other products they sell you within the first product costs substantially more. I could write all day about why you should never purchase a Warrior Forum WSO, but if you want to learn more, you can read my article about Warrior Forum WSO’s here.
Given that I am still in reading and preparation phase, I am mainly interested to overlap my niche with real life interests so I could have motivation to produce content on regular basis. Two that I am highly interested are PC parts and Fitness. I am aware they are too general subjects with lot of sites doing the same, but my idea is to produce constant review on PC parts, Laptops, Mobile devices, Accessories all in different categories, create lists like top5 or 10 under XX budget etc. Similar approach I would use if I I decide to go with Fitness path and divide content training advice, review of fat loss methods, supplementation, nutrition etc. I am aware that this will be a long journey and that it can pass few months before sales start to kick in and that’s the risk I am ready to take. My questions are:
You will want a website, that is provided for you within Wealthy Affiliate on their top tier hosting. You get this included in your membership. A website is important as it is the foundation for your business (your storefront so to speak). The process is not technical these days so don’t be scared by the idea of “creating a website”. You are going to be just fine.
With that said, I want to fully disclose that I am indeed an affiliate for Wealthy Affiliate. If you click on any of my affiliate links, like this one, I get credit in the event you sign up for a paid membership option. If you do want to sign up for Wealthy Affiliate, clicking on my affiliate link is actually beneficial for you, too. If you sign up after clicking my link, I get notified and we are able to have private 1-on-1 conversations within’ the Wealthy Affiliate  community. This is a huge added benefit and all you have to do is use my affiliate link before signing up for your free account.
If you have an eye for design and some experience of creating websites, then you could offer your services as a freelance web designer. You will need to create your own stylish website and have a few other projects that you can show potential clients to demonstrate your skills. You will also need to initially spend time emailing businesses to promote your services and find work.
Here are some additional pictures from the conference. This first picture is from the Wynn Hotel. Kyle and Carson, the owners of Wealthy Affiliate, rented out an incredible 2 story suite for us to party in. They had top shelf drinks, entertainment, mouth-watering food, and we were simply treated like ballers. Networking and making connections with these other successful affiliate marketers was invaluable.
A lifestyle blogger writes about their everyday life, hobbies, and interests. From fashion, beauty tips, and male grooming, to food, restaurants, and travel, anything that you experience can be blogged about. And famous lifestyle bloggers can make big bucks. Once you have built up a following, there are many ways to make a profit. Add affiliate links to your website, promote sponsored services, create your own product range, and much more.
Wealthy Affiliate has existed since 2005, so they’ve been around for a long time. However, they have never once increased their price, even though every year they add new features. Wealthy Affiliate has never been as helpful or advanced as it is today, and the “help and be helped” community has never been bigger. If you’ve been putting off joining Wealthy Affiliate, now is the absolute best time to join the community.

If you have a background in marketing and a passion for a particular niche, then organizing a virtual event may be just up your street. A virtual event could span across a day or longer. Individual live sessions would be run by experts in the field. And conference features would include live question and answer sessions, forums, and plenty of free giveaways. Visitors to the virtual event would pay to attend, so the more effective your promotion of the event the more money you would make.
People are turning to audio and visuals when it comes to technical subjects. However, you should consider doing an ebook first and turning it into an audiobook through a resource like Audible's ACX platform. You can hire a producer either through a royalty share program, so you don't have to shell out upfront cash, or you can do a pay-per-hour hire as well.

Yes, it costs money, but starting any business takes an investment. The key is to invest wisely, be frugal, and make sure you’re investing in the right things. With Wealthy Affiliate Premium you are literally getting absolutely everything you’ll need to start a successful business online. From the training to the web building tools to the website hosting, backup, security, and support – it’s all there in one place at a very reasonable price.

While some might think that starting a blog is an arduous effort, when you understand the precise steps you need to take, it becomes far easier. It all starts in the decision of choosing a profitable niche and picking the right domain name. From there, you need to build your offers. You can easily sell things like mini-email courses, trainings and ebooks.

SkimLinks is primarily for established content producers (bloggers) who want to monetize their content. With a powerful WordPress plugin and scripts for just about any website type, setting up SkimLinks is very easy. And because you have access to all offers on their platform after you’re approved, SkimLinks is very well designed for affiliates who don’t want to spend a lot of time fiddling around with settings and other fine-tuning.


Again, if your blog has a large reader base, then businesses may be interested in paying you to review their services or products. Not only will you get a free trial using whatever these businesses are selling, but you will also get a fee for writing them a review and posting it to your site. Paid reviews (and other paid and sponsored content) can be big money, so advertise this service on your contact page to generate business.
Since the emergence of affiliate marketing, there has been little control over affiliate activity. Unscrupulous affiliates have used spam, false advertising, forced clicks (to get tracking cookies set on users' computers), adware, and other methods to drive traffic to their sponsors. Although many affiliate programs have terms of service that contain rules against spam, this marketing method has historically proven to attract abuse from spammers.
In April 2008 the State of New York inserted an item in the state budget asserting sales tax jurisdiction over Amazon.com sales to residents of New York, based on the existence of affiliate links from New York–based websites to Amazon.[45] The state asserts that even one such affiliate constitutes Amazon having a business presence in the state, and is sufficient to allow New York to tax all Amazon sales to state residents. Amazon challenged the amendment and lost at the trial level in January 2009. The case is currently making its way through the New York appeals courts.
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