UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
FEDERAL TRADE COMMISSION
Plaintiff
v.
INNOVATIVE PRODUCTIONS, a Nevada corporation; and
SHANE D. WALLS, individually and as an officer of the corporation.
Defendants.
Civil Action No.:
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "the Commission"),
for its complaint alleges:
1. The FTC brings this action under Sections 5(a) and 13(b) of the FTC
Act, 15 U.S.C. §§ 45(a) and 53(b), to obtain temporary, preliminary,
and permanent injunctive relief, rescission of contracts, restitution,
disgorgement, and other equitable relief for defendants' violations of
Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).
JURISDICTION AND VENUE
2. This Court has subject matter jurisdiction over this action
pursuant to 28 U.S.C. §§ 1331, 1337(a), and 1345, and 15 U.S.C.
§§ 53(b). This action arises under 15 U.S.C. § 45(a)(1).
3. Venue in the United States District Court for the Northern District
of Texas is proper under 28 U.S.C. §§ 1391(b) and (c), and 15 U.S.C.
§ 53(b).
THE PARTIES
4. Plaintiff, the Federal Trade Commission, is an independent agency
of the United States Government created by statute. 15 U.S.C. § 41 et
seq. The Commission is charged, inter alia, with enforcement of
Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair
or deceptive acts or practices in or affecting commerce. The
Commission is authorized to initiate federal district court
proceedings, by its own attorneys, to enjoin violations of the FTC Act
in order to secure such equitable relief as may be appropriate in each
case, and to obtain consumer redress. 15 U.S.C. § 53(b).
5. Defendant Innovative Productions, a Nevada corporation using a
mailing address at 18352 N. Dallas Parkway, #136, PMB 518, Dallas, TX
SNIPPETS:
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission, for its complaint alleges:
The FTC brings this action under Sections 5and 13of the FTC Act, 15 U.S.C. §§ 45and 53, to
Venue in the United States District Court for the Northern District of Texas is proper under
Plaintiff, the Federal Trade Commission, is an independent agency of the United States
The Commission is charged, inter alia, with enforcement of Section 5of the FTC Act, 15 U.S.C.
The Commission is authorized to initiate federal district court proceedings, by its own
At all times relevant to this complaint, the defendants have maintained a substantial course
Since at least February of 1998, and continuing thereafter, defendants have offered and sold
The defendants have promoted their employment opportunities to prospective purchasers in a
You will be paid $4 for every envelope you stuff with my sales materials and your payments
consumers who leave their names and addresses in response to defendants' message receive by
And for a limited time, I'm looking for people just like you who want to improve their
Just follow my easy instructions and you will get paid - every single time - guaranteed.
You will not be required or asked to pay for any additional materials or supplies.
In as much as we would like to send you our program without the small registration fee, we
I understand I am protected by your 90 Day Money-Back Guarantee.
Instead, defendants tell consumers to place advertisements in weekly newspapers and on
In numerous instances, consumers who unsuccessfully attempted to obtain refunds from the
|