IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
__________________________________________)
FEDERAL TRADE COMMISSION, )
)
Plaintiff, ))
v. ) Civil Action No. 4:96CV02162SNL
JOSEPH HAYES, )
individually, d/b/a Retail Sales )
& Marketing, and as an officer )
of Automated Guest Directories, Inc., ))
THELMA HAYES, )
individually, d/b/a Retail Sales )
& Marketing, and as an officer )
of Automated Guest Directories, Inc., ))
ALLAN O HEARN, )
individually, d/b/a Retail Sales )
& Marketing, and as an officer of )
Automated Guest Directories, Inc., ))
ANN FOX, )
individually, d/b/a Retail Sales )
& Marketing, and as an officer of )
Automated Guest Directories, Inc., and )
)
AUTOMATED GUEST DIRECTORIES, INC., )
a Nevada corporation, )
)
Defendants. )
__________________________________________)
COMPLAINT FOR PERMANENT INJUNCTION
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 13(b) and 19 of the Federal Trade
Commission Act ("FTC Act"), 15 U.S.C. 53(b) and 57b, to secure preliminary and permanent
injunctive relief, rescission of contracts, restitution, disgorgement, and other equitable relief
defendants' unfair and deceptive acts and practices in violation of Section 5(a) of the FTC Act,
15 U.S.C. 45(a), and the FTC's Trade Regulation Rule entitled "Disclosure Requirements and
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
COMPLAINT FOR PERMANENT INJUNCTION
AND OTHER EQUITABLE RELIEF
Plaintiff, the Federal Trade Commission, for its complaint
The FTC brings this action under Sections 13and 19 of the Federal Trade
Commission Act, 15 U.S.C. 53and 57b, to secure preliminary and permanent
defendants' unfair and deceptive acts and practices in violation of Section 5of the FTC Act,
Prohibitions Concerning Franchising and Business Opportunity Ventures" ("the Franchise Rule"
Venue in the United States District Court for the Eastern District of Missouri is
Defendant Joseph Hayes has conducted business as Retail Sales & Marketing and
is an owner and officer of defendant Automated Guest Directories,
transacted business within the Eastern District of Missouri.
participated in the acts and practices set forth in this complaint.
AGD promotes and sells business opportunities involving the sale of advertising space on
automated guest directory boards placed in hotel lobbies.
selling advertising space on the directory boards to local businesses.
Without notice to existing business opportunity purchasers,
VIOLATIONS OF SECTION 5 OF THE FTC ACT
In the course of offering for sale and selling automated guest directory business
reasonably expect to achieve a specific level of earnings, such as $91,800 annually.
defendants representations as set forth in Paragraph 15 are false and
Consumers in many areas of the United States have suffered substantial monetary
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