UNITED ST.ATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATL.0T.1 DIVISION
) 1
FEDERAL TRADE COMMISSION, 1
1
Plaintiff, 1 Case No.
1 1 OC-C-.V-1582
V. 1 ) )
JEFFREY L. LAYDERS, ) 1
Defendant. ) )
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), for its Complaint
alleges:
1. This is an action under Section 13(b) of the Federal Trade Commission
("FTC Act"), 15 U.S.C. $ 53(b), to secure preliminary and permanent injunctive relief,
of contracts, restitution, disgorgement, and other equitable relief for defendant's
or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. 5 45(a).
JURISDICTION AlVD VENUE
2. This Court has jurisdiction over this matter pursuant to 15 U.S.C. $5
53(b) and 28 U.S.C. $4 1331, 1337(a) and 1345.
3. Venue in the United States District Court for the Northern District of
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proper under 15 U.S.C. 5 53(b) and 28 U.S.C. 4 1391(b) and (c).
PL4INTIFF
4. Plaintiff Federal Trade Commission is an independent agency of the United
Government created by statute. 15 U.S.C. $5 41-58. The Commission enforces Section 5(a) of
SNIPPETS:
Plaintiff, the Federal Trade Commission, for its Complaint
This is an action under Section 13of the Federal Trade Commission Act
of contracts, restitution, disgorgement, and other equitable relief for defendant's deceptive
or practices in violation of Section 5of the FTC Act,
Venue in the United States District Court for the Northern District of Georgia is
Plaintiff Federal Trade Commission is an independent agency of the United States
attorneys to enjoin violations of the FTC Act and to secure such equitable relief as may be
including restitution for injured consumers.
Defendant Jeffrey L. Landers does business as Adpro,
the acts and practices alleged herein, has been and is in or affecting commerce, as
Since at least February 1, 1999, defendant, directly or through his representatives,
has mailed to consumers a letter that states, either expressly or by implication, that the
The letter, titled "Authorization
Replys without $89.00 fee will not be processed.
consumers do not receive a monetary prize or anything of value.
`5365,930 cash money and property prizes, or other substantial awards.
defendant has been unjustly enriched as a result of his unlawful practices.
The Court, in the exercise of its equitable jurisdiction, may award other ancillary
relief to remedy injury caused by defendant's violations.
Award plaintiff such temporary preliminary injunctive and ancillary relief as may
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