Sarah Koch (formerly Coffey) brings skills in both civil and criminal law to her work for Ifrah Law clients. Sarah has built a strong track record in cases regarding i-gaming, e-commerce, government contracts, and criminal fraud.
Sarah helps i-gaming clients navigate the changing landscape of internet gaming law by tracking developments on the state and federal level as they occur. This real-time analysis gives clients the opportunity to quickly make informed decisions and seize opportunities in limited markets ahead of their competitors. Sarah has advised some of the biggest i-gaming companies in the world on issues relating to licensure, regulatory compliance, acquisitions, and litigation.
During her time as a Federal Trade Commission (FTC) law clerk, Sarah worked on investigations and enforcement actions involving Internet marketing campaigns, negative-option continuity plans, and trade regulation compliance. Today, she uses an insider’s knowledge of consumer protection law to advise e-commerce clients on compliance with advertising guidelines, and to assist them in state and federal government enforcement actions. At a time when the FTC is stepping up its scrutiny of affiliate networks and social media marketing, her experience is invaluable to businesses engaged in Internet advertising and marketing.
For Ifrah Law’s government contractor clients, Sarah has assisted with bid protests, SBA proceedings, and employment law matters including COBRA and ERISA disputes. She has also worked on a number of cases brought by the Commodity Futures Trading Commission (CFTC) alleging violations of the Commodity Exchange Act.
Sarah’s other criminal defense cases have included charges of mortgage fraud, marriage fraud, and military BAH fraud. Sarah also acts as a pro bono guardian ad litem in D.C. Superior Court, where she represents the best interest of the child in custody disputes.
Sarah was first published in Case Western Reserve’s Journal of International Law, with an article regarding property rights to natural resources in outer space. This article received the Note of the Year award. Sarah has also published articles in Gambling Insider (“State of Opportunity,” February 2014); Gaming Intelligence (“The Law According to NJ,” September 2013); World Online Gambling Law Report (“New Jersey’s Draft Regulations: Beyond Gaming Operators,” July 2013;“One Governor, Two Vetoes: New Jersey’s I-Gaming Bills,” February 2013; “Tainted Asset Rules Decrease US State I-Gaming Success,” June 2012), iGaming Business North America (“The Reid-Kyl Bill and the Federal Cause,” December/January 2012/13), and iGaming Business Magazine (“The Momentous Law for US Poker,” May/June 2011).
|"State of Opportunity," Gambling Insider||February 2014|
|"The Law According to NJ," Gaming Intelligence||September 2013|
|"New Jersey’s Draft Regulations: Beyond Gaming Operators," World Online Gambling Law Report||July 2013|
|Jeff Ifrah, Speaker; Sarah Coffey, Moderator, "Home Truths: New Jersey’s Path to I-Gaming Regulation and its Future in the US Online Gaming Market" EGR North America Panel, The Pier Shops at Caesars in Atlantic City, NJ||May 20, 2013|
|"The future of egaming: Bet on New Jersey," EGR North America||March 2013|
|"One Governor, two vetoes: New Jersey’s i-gaming bills," World Online Gambling Law Report||February 2013|
|"The Reid-Kyl Bill and the Federal Cause" iGaming Business North America Magazine||December/January 2012/13|
|"Tainted Asset Rules Decrease US State i-Gaming Success," World Online Gambling Law Report||June 2012|
|"The Momentous Law for US Poker," iGaming Business Magazine||May/June 2011|
Turning the Tables on Fraudulent Direct Marketing Tactics
When an Internet retailer of consumer products discovered fraud by the direct marketing agency it had retained to promote its products online, Ifrah PLLC helped the retailer turn the tables.
Although the direct marketing agency, or affiliate network, agreed to craft a marketing campaign that complied with all advertising and consumer protection laws, it failed to do so. The network drove millions of leads to the retailer, a substantial number of those turned out to be from webpages containing claims the retailer did not approve.
This resulted in a substantial loss of advertising dollars for our client, the possible loss of good will among its customers, and exposure to state and federal consumer protection claims.
After we advised the retailer to stop paying the affiliate network, it filed a breach-of-contract lawsuit in federal court in California seeking $2.5 million in damages. We responded by filing a countersuit for the non-compliant webpages.
In our analysis of the lawsuit, we discovered a legal flaw in the agency’s case that would require the court to dismiss it. Rather than immediately attempt to litigate this issue, we contacted the agency’s lawyers and gave them several opportunities to withdraw the case voluntarily.
When the agency ignored our invitation, we filed a motion to dismiss its lawsuit based on the flawed filings. The judge not only granted our motion, but he also chastised the agency for ignoring our invitations to resolve this without involving the court.
Because our litigation of the motion unnecessarily required our client to incur legal fees, we then filed a request that the judge order the agency to pay our client’s fees. Just as vigorously as it had fought our first motion, the agency fought that request. The judge awarded our client legal fees not only for the motion to dismiss, but also for having to fight its fee request.
In the end, we resolved the dispute in an out-of-court settlement on terms favorable to our client.
Domain Name Seizure Reversed, Favorable Settlement Gained
Ifrah Law’s client, a Russian corporation, was charged in the United States District Court
for the District of Columbia with violating the Commodity Futures Trading Commission
The company is comprised of a group of financial and investment companies that provide
online trading services. The government alleged that the defendants operated a foreign
currency exchange business over the Internet, which served U.S. customers but did not
register with the CFTC, as is required by law. The government was seeking $280,000 in
potential fines and the worldwide shutdown of the lucrative web site.
After the government obtained a default judgment against the defendant, they turned to
Ifrah Law. With our representation and expertise in financial matters, the case was settled
for a small fine and the web site remains operable outside of the United States.
(CFTC v. InstaForex, Case No. 1:11-cv-00188 (U.S. District Court, District of Columbia))
A Favorable Settlement for an Online Merchant
A dispute arose between an e-commerce merchant and an interactive advertising agency
involving over $2.5 million in damages. The merchant retained Ifrah Law and we utilized
our experience representing individuals and corporations in the online marketing arena to
negotiate a favorable settlement for the e-commerce merchant and obtain a dismissal of
The ad agency was a large network that rolled out a sales campaign for the merchant’s
product. They claimed they were owed commissions from the merchant’s sales and
brought a case against our client and sued the individuals associated with the company, as
We argued that they you couldn’t assess liability against individuals for the liability of
the company unless there was a specific basis to do so and we moved to dismiss. The
advertising agency challenged us, and we won a judgment for the plaintiff as well as for
our attorney fees.
Then the advertising agency litigated that result – and lost. The judge found our legal fees
to be fair and reasonable.
By the time this wrangling was completed, Ifrah had won a judgment of $250,000 before
the actual case had even started. Normally, it’s impossible for a defendant to win legal
fees – but not with Ifrah Law.
Successfully Defending a Government Contractor Against a Terminated Employee’s Health Care Claim
Ifrah Law successfully defended a government contractor against claims by a terminated company employee. Our client, a health care professional supplier, faced allegations that it failed to offer the former employee COBRA insurance coverage, as required under the COBRA statute.
Ifrah Law conducted a bench trial in the U.S. District Court for the Eastern District of Virginia in January 2012. The judge sustained minimal claims and awarded the plaintiff a mere $500.
(Middlebrooks v. Godwin Corporation, U.S. District Court, Eastern District of Virginia, No. 1:10CV1306))