Momentum Tech Review: CodeMojo AI slop securities fraud
Momentum Tech operates in the AI slop MLM niche.
The company provides a suite address in Wyoming, which is assumed to tie into a registered shell company.
Heading up Momentum Tech we have co-founders Ed Garza (CTO) and James Penny (CEO).
Other cited Momentum Tech execs are:
- Jennette Garza – Director of Latin Markets & Customer Service Manager
- Christine Deane – “The Networking Diva” (???)
- Stan Harris – Chief Breakthrough Officer
- Angelina Martinez – Event Logistics & Non Profit Liaison
As far as I can tell, Ed Garza doesn’t have an MLM history. Prior to Momentum Tech James Penny was promoting The Great Discovery, a $40 a month “courses” MLM company that lends itself to being a pyramid scheme.
What does it mean to be an “Active Affiliate”?
Active status is required to qualify for certain commissions and bonuses. An Affiliate is considered Active if they:
- Maintain an active Genius Club subscription (any tier), or
- Generate $40 USD in new personal sales or purchases within the prior 5-week period
Penny’s marketing of The Great Discovery featured Stan Harris:
Stan Harris is known to BehindMLM as a promoter of the notorious OneCoin Ponzi scheme. Harris was named among a group of top OneCoin investors in a 2019 civil class-action.
After OneCoin Harris continued to defraud consumers through various MLM schemes. BehindMLM has noted Harris’ involvement in Kingdom Wealth Alliance, MyDHLife and FreeMart.
As to where Momentum Tech is actually operated from, Momentum Tech operates from two known website domains:
- momentumtech.info – privately registered on September 20th, 2025
- momentumtechai.com – privately registered on October 11th, 2025
If we look at the source-code of “momentumtechai.com”, we find a reference to CodeMojo:
CodeMojo is an AI slop factory co-founded by… Ed Garza and James Penny:
As above, CodeMojo represents it is “built in Franklin, Tennessee”. But even that is misleading.
As per their respective FaceBook profiles, Garza and Penny are based out of Texas. For all intents and purposes, Momentum Tech and CodeMojo appear to be operated from Texas.
We’ll explore the relationship between Momentum Tech and CodeMojo further in the conclusion section of the review.
Read on for a full review of Momentum Tech’s MLM opportunity.
Momentum Tech’s Products
Momentum Tech has no retailable products or services.
Promoters are only able to market Momentum Tech promoter membership itself.
Momentum Tech promoter membership provides access to over 40 CodeMojo AI slop tools.
Momentum Tech’s Compensation Plan
Momentum Tech’s compensation plan pays on recruitment of promoters who each pay $39 a month.
Momentum Tech Promoter Ranks
There are are six promoter ranks within Momentum Tech’s compensation plan.
Along with their respective qualification criteria, they are as follows:
- Consultant – sign up as a Momentum Tech promoter for $39 a month or recruit a promoter who has an active $39 a month subscription
- Bronze – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, and maintain at least one personally recruited promoter with an active subscription
- Silver – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, recruit ten promoters and have a total downline of twenty promoters, or generate at least three downline legs with a Bronze or higher ranked promoter in each and a total downline of twenty promoters
- Gold – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, generate at least three downline legs with a Silver or higher ranked promoter in each and a total downline of one hundred promoters, or have a total downline of one hundred promoters with an active subscription (max 40 from any one recruitment leg)
- Platinum – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, recruit one hundred promoters and have a total downline of five hundred promoters, or generate at least three downline legs with a Gold or higher ranked promoter in each and a total downline of five hundred promoters, or have a total downline of five hundred promoters with an active subscription (max 150 from any one recruitment leg)
- Diamond – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, generate at least three downline legs with a Platinum or higher ranked promoter in each and a total downline of two thousand five hundred promoters, or have a total downline of two thousand five hundred promoters with an active subscription (max 500 from any one recruitment leg)
- Crown Diamond – maintain a $39 a month subscription or recruit a new promoter with an active subscription each month, and generate a total downline of 50,000 promoters with an active subscription (max 10,000 from any one recruitment leg)
Recruitment Commissions
Momentum Tech pays recruitment commissions via a unilevel compensation structure.
A unilevel compensation structure places a promoter at the top of a unilevel team, with every personally recruited promoter placed directly under them (level 1):
If any level 1 promoters recruit new promoters, they are placed on level 2 of the original promoter’s unilevel team.
If any level 2 promoters recruit new promoters, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.
Momentum Tech caps payable unilevel team levels at ten.
Recruitment commissions are paid out as a percentage of initial $39 fees paid across these ten levels based on rank.
- Consultants earn 100% on level 1 (personally recruited promoters
- Bronze ranked promoters earn 100% on level 1 and 3% on level 2
- Silver ranked promoters earn 100% on level 1, 3% on level 2 and 2% on level 3
- Gold ranked promoters earn 100% on level 1, 3% on level 2, 2% on level 3 and 1% on level 4
- Platinum ranked promoters earn 100% on level 1, 3% on level 2, 2% on level 3 and 1% on levels 4 and 5
- Diamond and Crown Diamond ranked promoters earn 100% on level 1, 3% on level 2, 2% on level 3 and 1% on levels 4 to 10
Note Momentum Tech’s compensation plan is misleading. 100% is quoted as the direct commission rate, however this is 100% of the assigned commissionable sales volume on each $39 initial subscription fee.
Momentum Tech doesn’t disclose the assigned sales volume value to each $39 initial subscription fee payment, so actual recruitment commission amounts are withheld from consumers.
Residual Commissions
Momentum Tech pays residual commissions through a 2×15 matrix.
A 2×15 matrix places a Momentum Tech promoter at the top of a matrix, with two positions directly under them.
These first two positions form the first level of the matrix. The second level of the matrix is generated by splitting these first two positions into another two positions each (4 positions).
Levels three to fifteen of the matrix are generated in the same manner, with each new level of the matrix housing twice as many positions as the previous level.
Momentum Tech pays a 5% residual commission rate on second and subsequent $39 a month subscription fee payments.
How many levels of the 2×15 matrix a Momentum Tech promoter earns residual commissions on is determined by rank:
- Consultants earn 5% on up to 12 matrix levels
- Bronze and Silver ranked promoters earn 5% on up to 13 matrix levels
- Gold and Platinum ranked promoters earn 5% on up to 14 matrix levels
- Diamond ranked promoters earn 5% on up to 15 ranked promoters
Matching Bonus
Momentum Tech pays a Matching Bonus on residual commissions earned by downline promoters.
The Matching Bonus is paid on up to five unilevel team levels based on rank:
- Bronze ranked promoters earn a 10% match on level 1 (personally recruited promoters)
- Silver ranked promoters earn a 12% match on level 1 and 1% on level 2
- Gold ranked promoters earn a 15% match on level 1 and 2% on level 2
- Platinum ranked promoters earn a 16% match on level 1 and 2% on levels 2 and 3
- Diamond ranked promoters earn a 20% match on level 1, 2% on level 2 and 1% on levels 3 and 4
- Crown Diamond ranked promoters earn a 30% match on level 1, 2% on levels 2 and 3 and 1% on levels 4 and 5
For an explanation on the unilevel team refer to “Recruitment Commissions” above.
Gold Bonus
The Gold Bonus is a generational bonus, paid out as a percentage of generated Gold Bonus sales volume.
A generation in a unilevel team leg is defined when a Gold or higher ranked promoter is found in the leg.
This ranked promoter caps off the first generation for that leg, with the second generation beginning immediately after.
If there are no more Gold or higher ranked promoters deeper in the leg, the second generation extends down the full depth of leg.
Using this generational structure, the Gold Bonus pays Gold or higher ranked promoters on up to three generations per unilevel team leg:
- the first generation of a unilevel team leg pays out 58%
- the second generation of a unilevel team leg pays out 29%
- the third generation of a unilevel team leg pays out 13%
Note that Momentum Tech doesn’t disclose the exact Gold Bonus sales volume from a $39 subscription.
Producer Bonus Pool
Momentum Tech takes 5% of company-wide subscription volume and places it into a Producer Bonus Pool.
30% of the Producer Bonus Pool is paid to Momentum Tech’s “key employees”.
The other 70% is paid monthly to Momentum Tech’s “top 10 producers” by subscription sales volume (must be Platinum rank or higher).
Joining Momentum Tech
Momentum Tech promoter membership is $39 a month.
Note Momentum Tech misleads consumers by representing promoter membership is “free”. While one can sign up for a free seven-day account, a promoter must pay $39 to become active after the 7 days.
From Momentum Tech’s website FAQ;
What if I dont activate in time?
After 7 days, your reserved position is released to the next person. You can re-join later, but your original placement wont be held. Snooze, you lose.
Momentum Tech Conclusion
Momentum Tech is essentially a defacto MLM pyramid scheme attached to an AI slop factory.
Instead of being upfront with consumers about pricing, CodeMojo wastes their time by making them sit through a “30-minute onboarding session to set up your account.”
This is likely to avoid comparison’s to Momentum Tech’s $39 a month price. Regardless, from this we can surmise CodeMojo itself has little to no customers.
This tracks with CodeMojo’s website domain being registered only a few months prior to Momentum Tech’s primary website domain.
Momentum Tech pretends to have retail customers, however the distinction is the old “choose not recruit” pseudo-compliance:
This pseudo-compliance was shot down in court in both the FTC’s Vemma and Herbalife cases.
More to the point, having no actual distinction between retail customers and promoters lends itself to Momentum Tech being full of promoters getting paid on subscription fees paid by directly and indirectly recruited promoters.
This is a classic autoship recruitment scheme (autoship in this instance being a monthly access fee).
With this model, the CodeMojo AI slop becomes a marketing tool to market Momentum Tech itself. It’s a closed-loop pyramid scheme where promoter subscriptions are the primary source of revenue (recruitment).
Seemingly wanting to preempt due-diligence questions related to it being a pyramid scheme, Momentum Tech states this in its website FAQ;
Is this a pyramid scheme?
No. We sell real AI tools and training. Pyramid schemes have no products. We have 40+ AI tools that people actually use and love.
Whether Momentum Tech sells “real AI tools and training” is irrelevant to it being a pyramid scheme. An MLM company is a pyramid scheme if the majority of company-wide revenue is generated through recruitment instead of retail sales.
A variation of the classic “no products” pyramid scheme is the aptly named product-based pyramid scheme.
In both the FTC and Vemma cases, it was determined that the company’s products were tied to a recruitment-driven compensation plan. Whether HerbaLife’s and Vemma’s products were “real” or not was irrelevant.
I also want to note Momentum Tech’s compensation plan is a mess. Earlier presentations quote completely different figures to the current March 2026 compensation plan hosted on Momentum Tech’s website.
And that March 2026 compensation plan doesn’t match what is presented on Momentum Tech’s website.
This is indicative of multiple compensation plan revisions, over a a few months – suggesting math isn’t adding up on the backend (maybe there’s an AI for that).
Finally, we have securities fraud.
In an official marketing webinar doing the rounds in late 2025, co-founder James Penny pitched consumers on unregistered shares and “stockholder” ownership.
[0:44] Now the extra thing that I’m going to give to you today is an opportunity to not only be a consultant in Momentum Tech, but actually have some ownership in Momentum Tech.
And it’s pretty simple. For the first ten people who reach the Gold promotion level, those ten people will each receive one thousand shares of stock in Momentum Tech. Just by getting to Gold.
Next, for the next level, the first ten people that get to Platinum, they will receive one thousand shares of stock in Momentum Tech.
Yes, one thousand shares of stock. Issued in writing, signed by me and countersigned by my incredible business partner Ed Garza.
It’s unclear how many shares Momentum Tech has issued to its promoters and/or executives and employees.
What we can confirm is neither Momentum Tech, CodeMojo, James Penny or Ed Garza are registered with the SEC.
This makes any virtual shares Momentum Tech has issued an unregistered securities offering. And if those virtual shares are secretly still in play (there’s no mention of shares on Momentum Tech’s website or in its March 2026 compensation documentation), ongoing securities fraud.
As with all MLM pyramid schemes, once recruitment dries up so too will commission payments.
This will see promoters at the bottom of Momentum Tech’s compensation plan eventually stop paying $39 a month.
In turn promoters above these promoters will stop getting paid. Unless new recruits are found, eventually these promoters will also stop paying $39 a month.
Once enough Momentum Tech promoters stop paying $39 a month, an irreversible collapse is triggered.
Math guarantees that when a pyramid scheme collapses, the majority of participants lose money.
