It shall be unlawful for any person, directly or indirectly . . . (a) [t]o employ any device, scheme, or artifice to defraud, (b) [t]o make any untrue statement of a material fact or to omit to state ...

People thinking about adopting a child may start with an online search for “adoption agencies near me,” but end up with what’s known as an “adoption intermediary” that may not deliver on its promises.